8900.1 CHG 725



Section 3  Evaluate Airworthiness Issues of a Part 141 Pilot School

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2-1121    REPORTING SYSTEM. Use Safety Assurance System (SAS) automation and the associated Data Collection Tools (DCT).

NOTE:  Title 14 of the Code of Federal Regulations (14 CFR) part 141 functions are listed in Peer Group I of the SAS Master List of Functions (MLF). To view the MLF, see Volume 10, Chapter 1, Section 2.

2-1122    OBJECTIVE. This section describes how to evaluate an applicant’s aircraft for a part 141 Pilot School Certificate.

2-1123    GENERAL.

A.    Certification Process. The certification process establishes interaction between an applicant and the Federal Aviation Administration (FAA), from initial inquiry to certificate issuance or denial. It ensures that programs, systems, and intended methods of compliance are thoroughly reviewed, evaluated, and tested.

1)    The certification process consists of five phases:
a)    Preapplication Phase,
b)    Formal Application Phase,
c)    Document Compliance Phase,
d)    Demonstration and Inspection Phase, and
e)    Certification Phase.
2)    Due to the nature of part 141 operations, the usage of the five phases will depend on the size and complexity of the proposed operation. Tasks performed during these phases may overlap.

B.    Certification Project Manager (CPM). The CPM must closely coordinate all activities with the appropriate specialties.

C.    Importance of Maintaining Training Aircraft. Training aircraft are subject to greater wear and deterioration because of frequent takeoffs and landings. Malfunctions controlled by an experienced pilot could place a relatively inexperienced student pilot in a critical situation. This is particularly true in complex aircraft with controllable propellers and retractable gear. The frequency of takeoffs and landings on a training aircraft can make engines vulnerable to damage from overheating and rapid cooling.

D.    Contract Maintenance. Schools may conduct maintenance under contract arrangement, providing enough certificated mechanics are available to maintain the school’s aircraft. Arrangements for maintenance by other than school-operated facilities and personnel should be described in a written statement.


A.    Prerequisites. Familiarity with the type of equipment to be used by an applicant.

B.    Coordination. This task will require coordination with Maintenance, Avionics, and Operations inspectors.


A.    References (current editions):

    Title 14 CFR Parts 43, 45, 47, 65, 91, 133, 137, and 141.

    Advisory Circular (AC) 141-1, Part 141 Pilot Schools, Application, Certification, and Compliance.

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    Volume 1, Chapter 3, Section 1, Safety Assurance System: Responsibilities of Aviation Safety Inspectors.

    Volume 2, Chapter 9, Section 1, Initial Certification or Renewal of a Part 141 Pilot School.

    Volume 2, Chapter 9, Section 2, Introduction to Part 141 Airworthiness Related Tasks.

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    Volume 10, Safety Assurance System Policy and Procedures.

    Volume 14, Chapter 1, Section 2, Flight Standards Service Compliance Action Decision Procedure.

B.    Forms:

    FAA Form 8420-8, Application for Pilot School Certificate.

    FAA Form 8000-4, Air Agency Certificate.

C.    Job Aids. None.


A.    Application Form. Provide the applicant with necessary information and an application form. Advise the applicant to submit a Letter of Intent (LOI).

B.    Preapplication Meeting. Schedule a preapplication meeting with the applicant to discuss the following if known:

1)    Make and model of training aircraft.
2)    Number of each type of training aircraft, and if available, aircraft registration.
3)    Maintenance on the proposed training aircraft, and if they will be contracting their maintenance out to another source.
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2-1127    FORMAL APPLICATION PHASE. The preapplication phase ends and the formal application phase begins with receipt of the completed application, FAA Form 8420-8. After review of the submission, inspectors discuss with the applicant obvious deficiencies in the application and suggest corrective actions.

2-1128    DOCUMENT COMPLIANCE PHASE. Inspectors review the maintenance processes in detail for completeness and accuracy. If necessary, meet with the applicant to resolve deficiencies and answer questions.

A.    Application of Maintenance Processes. Inspectors should encourage pilot schools to use system safety concepts to develop maintenance processes that ensure aircraft meet the requirements of part 141, § 141.39 and are maintained and inspected in accordance with the requirements for aircraft operated for hire under part 91 subpart E.

B.    Maintenance Process Safety. Experience has shown that safety is enhanced when pilot schools develop and document maintenance processes that include:

1)    Define management organizational structure.
2)    Establish and define aircraft maintenance chain of command.
3)    Provide individual maintenance personnel job descriptions, explaining scope and detail of authority and responsibility.
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4)    Provide specific maintenance job accomplishment instructions. Develop a shift turnover process, especially when multiple work shifts are utilized.
5)    Provide controls for tracking and scheduling of aircraft for inspection(s) and maintenance.
6)    Provide controls to ensure aircraft compliance with the airworthiness limitations (AL) section of the manufacturer’s maintenance manual.
7)    Provide controls to ensure aircraft compliance with the instructions for continued airworthiness (ICA).
8)    Provide controls to ensure aircraft compliance with any inspection program approved under part 91, § 91.409.
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9)    Provide controls to ensure applicability and compliance with all Airworthiness Directives (AD) within the specified timeframes.
10)    Provide controls to ensure aircraft meet the requirements of § 141.39 and are maintained and inspected in accordance with the requirements for aircraft operated for hire under part 91 subpart E.
11)    Establish scope and detail of maintenance inspections.
12)    Ensure correction and recording in aircraft records of pilot-recorded discrepancies.
13)    Provide controls for maintenance of aircraft operated under lease agreements.

2-1129    DEMONSTRATION AND INSPECTION PHASE. Inspectors must validate the school’s ability to ensure that each aircraft used by the school for flight training and solo flights meets the requirements of § 141.39 and are maintained and inspected in accordance with the requirements for aircraft operated for hire under part 91 subpart E.

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A.    Inspect Aircraft. Inspect aircraft for certification, registration, airworthiness, and condition for safe operations, including the inspection status of the aircraft. Ensure the aircraft that the operator has available are equipped and appropriately certificated to perform functions required for the course of training. When unairworthy aircraft are encountered, the inspector should work with the operator to ensure that the unairworthy condition is resolved prior to operation of the aircraft. Inspectors should:

1)    Ensure the aircraft registration is properly displayed and the aircraft is a civil aircraft of the United States. If the school’s training facility is located outside the United States, and the training will be conducted outside the United States, the aircraft may be a civil aircraft of foreign registry.
2)    Ensure the aircraft Airworthiness Certificate is properly displayed and the aircraft is certificated with a Standard Airworthiness Certificate, a primary Airworthiness Certificate, or a Special Airworthiness Certificate in the light-sport category, unless the FAA determines otherwise because of the nature of the approved course. The FAA has determined that restricted category aircraft may also be used; however, the use of these aircraft are limited to the special purpose in which the aircraft was certificated. If the school’s training facility is located outside the United States, and the training will be conducted outside the United States, the aircraft must have a standard or primary Airworthiness Certificate or an equivalent certification from the foreign aviation authority (AA).
3)    Ensure the aircraft has two pilot stations with engine-power controls that can be easily reached and operated in a normal manner from both pilot stations (for flight training).
4)    Ensure the aircraft is equipped and maintained for instrument flight rules (IFR) operations if used in a course involving IFR en route operations and instrument approaches. For training in the control and precision maneuvering of an aircraft by reference to instruments, the aircraft may be equipped as provided in the approved course of training.
5)    Ensure the aircraft is equipped to perform functions appropriate for the course of training provided.
6)    Inspect and verify that the aircraft is in an airworthy condition for safe operations.
7)    Inspect special-purpose equipment installed on aircraft for approved data, such as external-load equipment, agricultural dispensing equipment, and modifications for students with a disability.
8)    Ensure the aircraft and the equipment list agree.

B.    Inspect Aircraft Maintenance Records. Inspect aircraft maintenance and alteration records to determine that all aircraft have current, appropriate inspections and meet all CFR requirements. Inspectors should:

1)    Ensure aircraft are maintained and inspected in accordance with the requirements for aircraft operated for hire under part 91 subpart E. If the school’s training facility is located outside the United States and the training will be conducted outside the United States, the aircraft may meet equivalent maintenance and inspection requirements from the foreign AA.
2)    Ensure compliance with all applicable AD and life-limited part requirements.
3)    Ensure that current Weight and Balance (W&B) information is available to the pilot of the aircraft.
4)    Ensure the flight school has procedures in place to ascertain that all discrepancies are corrected and recorded in the aircraft records.

C.    Ensure Adequate Personnel, Facilities, and Equipment. Ensure the applicant has access to properly certificated and trained maintenance personnel with facilities and equipment adequate to maintain the school’s aircraft. A part 141 pilot school is not required to have its own maintenance facilities, but it should maintain a point of contact (POC) with a maintenance provider (MP) for all maintenance issues. Any contract maintenance agreements should be described in writing and provide for a sufficient number of certificated mechanics readily available to maintain the school’s aircraft.

D.    Analyze Findings. Discuss any deficiencies or problem areas found with the CPM.

2-1130    CERTIFICATION PHASE. When the applicant has met all regulatory requirements for certification, the CPM must prepare FAA Form 8000-4, Air Agency Certificate.

2-1131    TASK OUTCOMES.

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A.    Conduct Debriefing. Brief the certificate holder on the inspection results. Discuss all deficiencies, certificate holder corrective actions, and FAA actions. The aviation safety inspector (ASI) can find instructions for conducting briefings in Volume 1, Chapter 3, Section 1.

B.    Compliance and Enforcement Action. If safety issues and/or regulatory noncompliance are identified, follow the process contained in Volume 14, Chapter 1, Section 2 to determine the appropriate FAA compliance or enforcement action.

C.    Complete the Task. Follow Volume 10 SAS guidance for completion of SAS Activity Recording or DCTs.

2-1132    FUTURE ACTIVITIES. Follow Volume 10 SAS guidance to plan future risk-based surveillance in SAS.

RESERVED. Paragraphs 2-1133 through 2-1150.