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VOLUME 3  GENERAL TECHNICAL ADMINISTRATION

CHAPTER 22  AIRCRAFT DISPATCHER TRAINING AND QUALIFICATION PROGRAMS

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Section 2  Safety Assurance System: Training and Qualification Program Approval Process

Source Basis:

    Section 121.400, Applicability and Terms Used.

    Section 121.401, Training Program: General.

    Section 121.403, Training Program: Curriculum.

    Section 121.405, Training Program and Revision: Initial and Final Approval.

    Section 121.415, Crewmember and Dispatcher Training Program Requirements.

    Section 121.1001, Applicability and Definitions.

    Section 121.1003, Hazardous Materials Training: General.

3-1621    REPORTING SYSTEM(S).

A.    Safety Assurance System (SAS) Activity Recording (AR). Use activity codes Initial Approval: 1306; Final Approval: 1309.

B.    Safety Assurance System (SAS). This section is related to SAS Element 3.1.1 (OP) Training and Qualification of Aircraft Dispatchers and Flight Followers.

3-1622    GENERAL.

A.    Overview. Training and qualification curriculum approvals follow the five-phase general process for approval or acceptance described in Volume 3, Chapter 1, Section 1. The basic steps of this process must be followed. Each phase, however, may be adjusted to accommodate existing circumstances. The approval process applies to each certificate holder (CH) requesting approval of a new curriculum or a revision to a currently approved curriculum. Inherent in the approval process is the Federal Aviation Administration’s (FAA) responsibility to deny approval of any training or qualification curriculum which does not meet regulatory requirements or which has been found to be deficient. Training and qualification curricula which have been granted approval and later found either to be in conflict with regulatory requirements, or to be ineffective must be appropriately modified by the CH, or FAA approval must be withdrawn. This section establishes procedures for granting or withdrawing approval of all or part of a training and qualification curriculum. When appropriate, job aids have been developed to assist inspectors in the approval process of curriculum segments. Volume 3, Chapter 22, Sections 3 through 7 discuss these job aids.

B.    Applicability. The training and qualification program approval process discussed in this section applies only to CHs conducting Title 14 of the Code of Federal Regulations (14 CFR) part 121 domestic and flag operations.

C.    Part 121 Supplemental Operations. CHs conducting supplemental operations are not required to have an approved training and qualification program in accordance with part 121 subparts N and P. However, these CHs are required to provide training to persons authorized to exercise operational control. Certain portions of the training must be approved or accepted. See Volume 3, Chapter 22, Section 7 for detailed information regarding training and qualification for persons authorized to exercise operational control of supplemental operations.

3-1623    INITIATING THE APPROVAL PROCESS—PHASE ONE.

A.    Approval Process Initiation. Either the CH or the FAA can initiate the training and qualification program approval process, as follows:

1)    CH-Initiated. The CH informs the FAA that it is planning to establish a new training and qualification curriculum or change an existing curriculum.
2)    FAA-Initiated. The FAA informs a CH that revisions to its training and qualification program are required based on recently acquired information relative to training techniques, aviation technology, aircraft operational history, CH performance, or regulatory changes.

B.    Needed Information. When a proposal is initiated by the CH, one of the first steps the Principal Operations Inspector (POI) or certification project manager (CPM) should take is to obtain the following basic information:

    Type of operation;

    Type of aircraft to be operated;

    Geographic areas of operation;

    Proposed training and qualification schedules;

    Proposed date of revenue operations;

    Proposed contract training, if any; and

    Facilities to be used.

3-1624    FAA INVOLVEMENT IN PHASE ONE.

A.    POI Responsibilities. Early in the process, the FAA and the CH should establish, through discussion, a common understanding of both the regulatory training and qualification requirements and the direction and guidance provided in this order. The POI or CPM and the CH must examine the entire operation to ensure that any training and qualification necessitated by operational requirements, authorizations, or limitations (such as those in the operations specifications (OpSpecs), minimum equipment lists (MEL), deviations, and exemptions) is included in the CH’s training and qualification curricula. The training and qualification program is the area most affected by operational changes. The POI should review all general requirements in the regulations and in this order that apply to the proposed operation. The POI should be aware of changes to the information initially provided by the CH. The POI should discuss with the CH the sequence and timing of events that occur in the development and granting of initial and final approval of a training and qualification curriculum. If the CH’s proposal involves complex operations (such as long-range navigation or polar navigation operations), the POI must consult appropriate sections of this order and other relevant documents and be prepared to advise the CH during this phase. In such a case, the POI should also determine whether assistance from an FAA specialist is necessary.

B.    Advice and Guidance Given to the CH. An FAA inspector should be prepared to provide advice to a CH during training and qualification curriculum development. During phase one, the FAA inspector must inform the CH of the procedure for requesting initial approval and the types of additional supporting information the POI will require the CH to submit. An inspector should be prepared to provide advice and guidance to the CH on the following:

    The general format and content of curricula, curriculum segments, and training modules;

    Courseware;

    Facilities;

    Qualifications of instructor personnel; and

    Other areas of the CH’s proposed training and qualification program.

C.    Importance of Early Involvement. Early FAA involvement is also important for the following reasons:

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1)    FAA advice and guidance during development of training and qualification may provide a useful service to the CH. This advice may save the CH and the FAA from unnecessary use of resources. It may also prevent the CH from submitting a training and qualification curriculum proposal that would not be approved by the FAA.
2)    The POI can become familiar with the material the CH intends to submit. This facilitates review of the proposal before the granting of initial approval.
3)    The POI can begin planning long-range needs, such as qualification of inspectors on the CH’s aircraft and evaluation of the program’s overall effectiveness.
4)    Early involvement of an Aviation Safety Inspector—Aircraft Dispatch (ASI-AD) in the development of training and qualification programs is appropriate. An ASI-AD, however, must act in an advisory capacity only. The ASI-AD must avoid active participation in the actual training and qualification program development. The CH is responsible for the development of its own training and qualification program. The ASI‑AD must not assume that responsibility.

D.    Additional Help. As the CH’s proposals solidify, any significant requirements that may affect office inspector resources should be discussed with the office manager. Requests for inspectors from outside the office to assist in the training and qualification program approval process may be necessary.

E.    Potential Causes of Approval Delays. The CH should be aware of the potential for delays in approval. Such delays may be caused by any of the following reasons:

    The applicant for a certificate not meeting the schedule of events;

    The CH failing to expeditiously transmit information to the FAA;

    A change in plans (e.g., changing either the training locations or the type of aircraft);

    Inadequate, insufficient, or unclear material submitted in phase two;

    Deficiencies in the training or qualification discovered during phases two, three, or four; and

    Higher priority work (such as accidents) assigned to the POI or other inspectors associated with the training and qualification program approval process.

3-1625    REQUESTS FOR INITIAL APPROVAL—PHASE TWO.

A.    Overview. Phase two begins when the CH submits its training and qualification proposal for initial approval in writing to the FAA. The CH is required to submit to the FAA an outline of each curriculum or curriculum segment and any additional relevant supporting information requested by the POI. These outlines, any additional supporting information, and a letter must be submitted to the FAA. This letter should request FAA approval of the training and qualification curriculum. Two copies of each curriculum or curriculum segment outline should be forwarded along with the letter of request to the FAA.

B.    Required Information in Curricula. Each CH must submit its own specific curriculum segment outlines appropriate for its type of aircraft and kinds of operations. These outlines may differ from one CH to another and from one category of training to another in terms of format, detail, and presentation. Each curriculum should be easy to revise and should contain a method for controlling revisions, such as a revision numbering system. Each curriculum and curriculum segment outline must include the following information:

    The CH’s name;

    Type of aircraft;

    Duty position;

    Title of curriculum and/or curriculum segment, including the category of training;

    Consecutive page numbers; and

    Page revision control dates and revision numbers.

C.    Required Curriculum Segment Items. Each curriculum and curriculum segment must also include the following items, as appropriate:

1)    Prerequisites prescribed by 14 CFR or required by the CH for enrollment in the curriculum.
2)    Statements of objectives of the entire curriculum and a statement of the objective of each curriculum segment.
3)    A list of each training facility and training aids that will be used in the curriculum.
4)    An outline of each module within each curriculum segment. Each module should contain sufficient detail to ensure that the main features of the principal elements or events will be addressed during instruction.
5)    Training hours that will be applied to each curriculum segment and the total curriculum.
6)    The qualification modules of the qualification curriculum segment used to determine successful course completion.

3-1626    ADDITIONAL RELEVANT SUPPORTING INFORMATION—PHASE TWO. As specified in part 121, § 121.405(a)(2), a CH must submit any additional relevant supporting information requested by the POI. This is additional information the POI finds necessary for determining whether the proposed training and qualification program is feasible and adequately supported. It is information that would be difficult to include in a curriculum outline format. The type and amount of supporting information needed will vary depending on the type of training, aircraft types to be operated, and kinds of operations. The POI must determine the appropriate types of supporting information to be required. This should be limited to only that information critical to the determination of the proposed training and qualification program’s acceptability. The following list of types of relevant supporting information is not all‑inclusive, but includes information that is typical.

A.    Description of Facilities. A description of facilities is appropriate if the POI is unfamiliar with the facilities, or if the facilities are not readily available for evaluation.

B.    List Instructors and Qualifications. The POI may request a list of instructors and their qualifications. This information is particularly important if the CH intends to use contract instructors.

C.    Description of Qualification and Enrollment Prerequisites. A detailed description of minimum aircraft dispatcher qualifications and enrollment prerequisites is appropriate when such prerequisites are not described in detail in the curriculum. Examples of these prerequisites, which may need to be detailed as supporting information, include previous training and qualification and experience with other part 121 air carriers. This description may be useful to the POI when determining whether the proposed amount of detail outlined in training modules and the proposed training hours are adequate.

D.    Recordkeeping Requirements. Copies of training forms and records to be used for recording aircraft dispatcher progress and the completion of training and qualification may be required. This ensures the CH has planned for the 14 CFR recordkeeping requirements. This type of supporting information is required of applicants for an air carrier certificate. It may also be required of CHs with any significant revision to existing training and qualification programs. These forms or records must be designed so that attendance and curriculum/curriculum segment/module completion information is recorded and retrievable for verifying regulatory compliance. See Volume 3, Chapter 31, Section 3 for information regarding aircraft dispatcher record retention requirements.

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E.    Supporting Information. Supporting information may include samples of courseware, such as lesson plans and instructor guides. Descriptions of other types of courseware, such as distance learning and computer-based instruction (CBI), should be in enough detail to provide an understanding of how the training will be administered and of the proposed instructional delivery method. This information should describe the instructor–aircraft dispatcher interaction and indicate methods for measuring aircraft dispatcher learning.

3-1627    INITIAL REVIEW OF REQUESTS FOR APPROVAL—PHASE TWO. In phase two, the POI must review the submitted training and qualification curriculum and supporting information for completeness, general content, and overall quality. A detailed examination of the documents is not required during phase two. If after initial review, the submission appears to be complete and of acceptable quality, or if the deficiencies are immediately brought to the CH’s attention and can be quickly resolved, the POI may begin the phase three indepth review. If the submission is determined to be incomplete or obviously unacceptable, the approval process is terminated and the POI must immediately return the documents (preferably within 5 business-days) with an explanation of the deficiencies. The documents must be immediately returned so the CH will not erroneously assume the POI is continuing the process to the next phase. The approval process can resume when the revised training and qualification curriculum or curriculum segment is resubmitted.

3-1628    TRAINING AND QUALIFICATION CURRICULA SUBMITTED WITH AIR CARRIER CERTIFICATE APPLICATIONS. An applicant for a certificate in the early stages of certification may be unable to provide all information required for its training and qualification program. For example, the applicant may not yet know what training facilities it intends to use. The lack of such information in the formal application does not necessarily indicate that the training and qualification curriculum must be returned. There should be an understanding between the applicant and the CPM that such portions are missing. The CPM may initiate the phase three indepth review without this type of information. However, initial approval of a curriculum segment must be withheld until all portions pertinent to the curriculum segment have been examined. However, effective evaluation of training and qualification curricula can be hampered when an excessive number of incomplete curriculum segments are permitted. The CPM must either delay initial approval of training and qualification curricula or return them to the applicant when an excessive number of incomplete curriculum segments have been submitted with the formal application.

3-1629    INDEPTH REVIEW OF SUBMITTED CURRICULA—PHASE THREE.

A.    Specialists and/or FAA Offices. Phase three is initiated when the FAA begins a detailed analysis and evaluation of a training and qualification curriculum or curriculum segment. The purpose of this phase is to determine the acceptability of training and qualification curricula for initial approval. This phase ends either with the initial approval or the rejection of all or part of the training and qualification curriculum. The POI may need to involve other FAA personnel early in this phase to complete an evaluation.

1)    The Principal Security Inspector (PSI) should be involved in evaluating security and hazardous materials (HAZMAT) training.
2)    The Air Transportation Division (AFS-200) may need to be involved with deviation and exemption requests.
3)    The POI’s office manager may need to be involved with locating and directing additional FAA resources to accomplish the approval process.

B.    Required Evaluations. Before granting initial approval for a specific curriculum or curriculum segment, the POI must ensure that the following evaluations are accomplished:

1)    A side-by-side examination of the curriculum outline with the appropriate regulations and with the direction provided in this order must be performed. This examination is to ensure that training will be given in at least the required subjects.
2)    An examination of the courseware developed or being developed by the CH must be performed. This review should include a sampling of available courseware such as lesson plans, audiovisual programs, and handouts. The courseware must be consistent with each curriculum and curriculum segment outline. From this review, the POI should be able to determine whether the CH is capable of developing and producing effective courseware.
3)    An inspection of training facilities and instructional aids (which will be used to support the training) must be performed if the POI is not familiar with the CH’s training and qualification program capabilities.
4)    The training hours specified in each curriculum segment outline must be evaluated. An inspector should not attempt to measure the quality or sufficiency of training by the number of training hours alone. This can only be determined by direct observation of training and testing (or checking) in progress, or by examination of surveillance and investigation reports. The specified training hours must be realistic, however, in terms of the amount of time it will take to accomplish the training outlined in the curriculum segment so as to achieve the stated training objectives. During the examination of courseware, an inspector should note the times allotted by the CH for each training module. These times should be realistic in terms of the complexity of the individual training modules. The number of training hours for any particular curriculum segment depends upon many factors. Some of the primary factors are as follows:

    The aircraft group in which the specific aircraft belongs;

    The complexity of the specific aircraft;

    The complexity of the kind of operation;

    The amount of detail that needs to be covered;

    The experience and knowledge level of the aircraft dispatchers; and

    The efficiency and sophistication of the CH’s entire training and qualification program (including items such as instructor proficiency, training aids, facilities, courseware, and the CH’s experience with the aircraft).

C.    Criteria for Approval. If, after completing these evaluations, the POI determines that the curriculum or curriculum segment is satisfactory and adequately supported and that the training hours are realistic, he or she should grant initial approval. Sometimes a portion of the submittal may appear to be satisfactory. However, if that portion is dependent upon another undeveloped portion or another unsatisfactory portion, initial approval must be withheld. If any portion of the curriculum is unsatisfactory, it is inappropriate to grant initial approval.

D.    Establishment of Priorities. During phase three of the approval process, the POI must establish priorities to ensure that, if appropriate, the granting of initial approval is not unnecessarily delayed. These priorities should assure that deficiencies are resolved so that initial approval can be granted before the CH’s planned starting date for training.

3-1630    EXPIRATION DATES FOR INITIAL APPROVALS. When the POI determines that a training and qualification curriculum or curriculum segment should be initially approved, the POI must also determine an appropriate expiration date for the initial approval. The expiration date is important throughout phase four of the approval process. Section 121.401(a)(1) requires the CH to obtain final approval of training and qualification curricula. The expiration date provides an incentive to the CH for refining all aspects of the program to assure that this regulatory requirement is met. The expiration date also provides the POI with a timeframe with which to plan evaluation activities for determining the effectiveness of the training and qualification. The expiration date assigned to an initially approved training and qualification curriculum must not exceed 24 calendar-months from the date of initial approval. The POI may reduce the expiration date of initial approval if it is apparent that a 24‑calendar-month timeframe will unnecessarily delay final approval. The POI should be aware that shortening the initial approval expiration date will commit him or her to completing the final approval phase within the shorter time period. Upon satisfactory completion of phase four, the POI may grant final approval any time before the expiration date. Except when unforeseen circumstances preclude an adequate evaluation of training and qualification effectiveness, an extension to the initial approval expiration date should not be permitted. A new expiration date, however, may be established for a curriculum segment when there are significant revisions to an initially approved curriculum segment.

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3-1631    METHOD OF GRANTING INITIAL APPROVAL.

A.    Initial Approval Is Granted by Letter. Figure 3-207, Sample Letter of Initial Approval, provides a sample letter granting initial approval. The initial approval letter must include at least the following information:

    Specific identification of the curricula and/or curriculum segments initially approved, including page numbers and revision control dates;

    A statement that initial approval is granted, including the effective and expiration dates;

    Any specific conditions affecting the initial approval, if applicable;

    A request for advance notice of training and qualification schedules so that training may be evaluated in accordance with § 121.405; and

    If the POI is authorizing a reduction in the programmed hours specified by part 121, a statement concerning the basis for reduction.

B.    Other Acceptable Methods. An initial approval letter serves as the primary record of curriculum or curriculum segment pages that are currently effective. In the past, initial approval was stamped on each page of a curriculum. Although this method is no longer necessary, the POI and each CH may agree to use the method to account for revisions to training and qualification documents. If this method is used, the stamp must clearly indicate initial approval and the expiration date. Other acceptable methods include a list of effective curriculum or curriculum segment pages, or pages with preprinted signature and date blocks.

C.    Return of Originals. The original pages of the curriculum or curriculum segment must be returned to the CH with the initial approval letter. The CH should retain these documents as an official record. A copy of the training and qualification curriculum or curriculum segment, with a copy of the initial approval letter attached, and all additional relevant supporting information, must be maintained on file in the responsible Flight Standards office by the POI during the period that the initial approval is valid.

3-1632    METHOD OF DENYING INITIAL APPROVAL. If the POI determines that initial approval of a proposed training and qualification curriculum or curriculum segment must be denied, he or she must notify the CH in writing of the reasons for denial. This letter must contain an identification of the deficient areas of the training and qualification curriculum and a statement that initial approval is denied. It is not necessary that each minor deficiency which resulted in the denial be identified; however, the major deficiencies should be outlined in the letter. It is the CH’s responsibility to redevelop or correct the deficient area before resubmission to the FAA. The responsible Flight Standards office must keep a copy of the denial letter and a copy of the proposed training and qualification curriculum or curriculum segment on file. Figure 3-208, Sample Letter of Denial of Initial Approval, is a sample letter of a denial of initial approval.

3-1633    EVALUATING INITIALLY APPROVED TRAINING AND QUALIFICATION CURRICULA—PHASE FOUR.

A.    Overview. Phase four begins when the CH starts training under the initially approved curriculum. This phase should provide the CH with adequate time to test the program and the flexibility to adjust the program during FAA evaluation. The POI must require a CH to provide ongoing schedules of all training and checking to be accomplished under an initially approved training and qualification curriculum. The POI must closely monitor training and qualification conducted under initial approval. Whenever possible, the POI or an ASI-AD should monitor the first session of training conducted under initial approval. An FAA inspector does not need to observe every training and qualification session. A sufficient sampling of the training and qualification sessions, however, should be observed as a basis for a realistic evaluation. Inspectors and other individuals knowledgeable of the curriculum subject matter should assist in evaluating the training and qualification. During training and qualification under initial approval, the CH is expected to evaluate and appropriately adjust training methods as needed. Often, adjustments can be made by changing courseware and instructional delivery without (or with only minor) revisions to the initially approved curriculum. Conversely, it may be necessary for the CH to substantially change the curriculum, which may require another initial approval action by the POI before the changes can be put into effect. Sometimes proposed revisions may be transmitted to the POI just before the initial approval expiration date. If the change is significant, the POI may need to establish a different expiration date for the curriculum segment, or for the revised portions, to allow adequate time for a proper evaluation.

B.    Identification and Correction of Curriculum Deficiencies. During phase four, the CH must demonstrate the ability to train aircraft dispatchers effectively. Each deficiency identified during the evaluation of training and qualification conducted under an initially approved curriculum must be discussed with the CH. Inspectors must document deficiencies and keep them on file. In most cases, when the cause of a deficiency has been accurately identified, the CH will make the necessary changes to correct the deficiency to obtain final approval. The CH must immediately correct each significant deficiency that has been accurately identified. If a CH does not take appropriate corrective action, the POI must advise the CH in writing that initial approval is withdrawn. See paragraph 3-1637 below.

3-1634    COMPONENTS AVAILABLE FOR EVALUATING TRAINING AND QUALIFICATION—PHASE FOUR. The POI must develop a plan for systematically evaluating training and qualification given under the initially approved training and qualification curriculum. This plan should remain in effect throughout the initial approval period. Five components can be evaluated when assessing the overall effectiveness of training and qualification programs. These are curriculum segment outlines, courseware, instructional delivery methods and training environment, testing and checking, and surveillance and investigation of CH activities. These components are interrelated; however, each can be evaluated separately. See Table 3-80, Components for Training and Qualification Evaluation, for a summary of the five components.

A.    Curriculum Segment Outlines. Before evaluating a training and qualification program, an inspector must become familiar with the contents of the curricula or curriculum segments to be evaluated. This preparation is essential if an inspector is to determine whether a CH has developed an effective course of instruction from its initially approved training and qualification curriculum.

B.    Examination of Courseware. Direct examination of courseware includes reviewing materials such as lesson plans, workbooks, or instructor guides. The inspector must determine whether the courseware is consistent with the curriculum or curriculum segment and that it has been organized to facilitate effective instructional delivery. Courseware is usually the training and qualification program component that is most adaptable to revision or refinement. Inspectors must review at least a sampling of the courseware.

C.    Observation of Instructional Delivery Methods and Training Environments. Direct observation of instructional delivery includes surveillance of training methods, such as instructor lectures, CBI presentations, and on-the-job instruction. Effective learning can only occur when an instructor is organized and prepared and properly uses the courseware and various training aids. The inspector must determine that the instructional delivery is consistent with the courseware. For example, the inspector should note whether the instructor teaches the topics specified in the lesson plan. Training aids should function as intended during the instructional delivery. In addition, during training, the inspector should be sensitive to the type of questions being asked by aircraft dispatchers and should identify the reasons for any excessive repetition. These conditions may indicate ineffective instructional delivery or courseware. The inspector must also determine if the instructional environment is conducive to learning. Distractions that adversely affect instructional delivery, such as excessive temperatures, extraneous noises, poor lighting, or cramped classrooms or workspaces, are deficiencies because they interfere with learning.

D.    Observation of Testing and Checking. Direct observation of testing and checking is an effective method for determining whether learning has occurred. Examining the results of tests, such as oral or written tests or checks, provides a quantifiable method for measuring training effectiveness. The POI must examine and determine the causal factors of significant failure trends.

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E.    Surveillance and Investigation of Training and Checking in Progress. Direct observation of training and checking in progress is an effective method of evaluating training. However, sometimes the opportunity for direct observation will be limited. In such cases, the POI will have to rely more on his or her evaluation of other sources of information, such as reports of surveillance and investigations. The POI should review the results of inspection reports, incident or accident reports, compliance and enforcement actions, and other relevant information about the CH’s performance for indications of training effectiveness. The POI must establish methods to evaluate these sources of information for trends which may develop while training is being conducted under initial approval (e.g., repeated reports of deficiencies, such as missed weather alerts or incorrect MEL application, may be traceable to a lack of specific training or ineffective training). Such information may provide indications that a curriculum segment and/or module needs revisions or refinements. This information should be used when developing the Comprehensive Assessment Plan (CAP) in SAS Module 2, Planning (see Volume 10, Chapter 3).

3-1635    METHOD FOR GRANTING FINAL APPROVAL—PHASE FIVE. This phase involves the granting of final approval of a CH’s training and qualification curriculum. Based on the results of the evaluation, the POI must determine whether to grant or deny final approval of a training and qualification curriculum. This determination must be made before the expiration date of the initial approval. If the POI decides not to grant final approval, the procedures outlined in paragraph 3-1638 or 3-1639 below must be followed. If the POI decides that final approval should be granted, the following procedures apply.

A.    Programs That Contain a List of Effective Pages (LEP). The POI documents the final approval of the training and qualification curriculum on the LEP. This means that the FAA has given final approval of every page of the CH’s training and qualification curriculum, as listed on the LEP, but only one FAA approval must be completed and signed.

1)    The POI must date and sign the page that documents final approval of the training and qualification curriculum and/or curriculum segment; the approval must include at least the information shown in Figure 3-209, FAA Final Approval.
2)    The original curriculum and/or curriculum segment must contain the one page that documents FAA approval of the LEP. The curriculum and/or curriculum segment must be transmitted to the CH with an approval letter signed by the POI in accordance with this section.

B.    Programs That Do Not Contain an LEP. The original and a copy of each page of the training and qualification curriculum and/or curriculum segment must be dated and signed by the POI and must include at least the information shown in Figure 3-209.

C.    Original Approved Curriculum. The original approved curriculum or curriculum segment must be transmitted to the CH with an approval letter signed by the POI. This letter must specifically identify the curriculum or curriculum segment, contain a statement that final approval is granted, and provide the effective date of approval. This letter must also state that final approval will remain in effect until otherwise notified by the FAA that a revision is necessary in accordance with § 121.405(e), provided the CH continues to train in accordance with the approved curriculum. If the POI is authorizing a reduction in the programmed hours specified by part 121, the letter must contain a statement concerning the basis for reduction. The responsible Flight Standards office must keep a copy of the approved curriculum or curriculum segment and a copy of the approval letter on file (see Figure 3-210, Sample Letter of Final Approval).

3-1636    REVISIONS TO TRAINING AND QUALIFICATION CURRICULA.

A.    Final Approval of Proposed Revisions. Revisions to initially approved training and qualification curricula must be processed as described in paragraphs 3-1623 through 3-1634 above. To incorporate significant revisions into training and qualification curriculum with final approval usually requires the full training and qualification program approval process. Final approval, however, may be directly granted to a proposed revision if the revision involves any of the following situations:

    Correction of administrative errors, such as typographical or printing errors;

    A reorganization of training or any changes in the sequence of training that does not affect the quality or quantity of training; and

    An improvement to the quality, or an increase in the quantity, of training.

B.    Probable Causes of Revisions. Other proposed revisions, including any proposal to reduce the approved number of training hours, are subject to the training and qualification program approval process. Although each step in the process must be completed, the process may be abbreviated in proportion to the complexity and extent of the proposal. Many factors could require revisions to training and qualification curricula. These include the following:

    The effects and interrelationships of changes in the kind of operations,

    The size and complexity of an operation,

    The type of aircraft being used,

    Any special authorizations through OpSpecs,

    A revised MEL, and

    Any exemptions or deviations.

3-1637    WITHDRAWING APPROVAL OF TRAINING AND QUALIFICATION CURRICULA. Before withdrawing approval of a CH’s training and qualification curriculum or curriculum segment, the POI must make reasonable efforts to convince the CH to make the necessary revisions. It is important to understand that withdrawing approval could be detrimental to the CH’s business. The CH’s ability to continue to hold a certificate may be in question if a new curriculum is not submitted for initial approval within a reasonable period of time. A decision to withdraw approval must be based on sound judgment and justifiable safety reasons. When sufficient reasons are established, it is mandatory for the POI to take immediate action to remove FAA approval from an ineffective or noncompliant training and qualification curriculum. When an approval is withdrawn, the POI must ensure that the CH clearly understands that any further training conducted under an unapproved curriculum is contrary to 14 CFR requirements. The FAA must take compliance or enforcement action (see Volume 14) if any company employee who received unapproved training is used in part 121 operations. The three methods for withdrawing approval of a training and qualification curriculum are as follows:

    Allowing an initially approved training and qualification curriculum to expire without granting final approval (see paragraph 3-1638),

    Withdrawing approval of an initially approved training and qualification curriculum before the expiration date (see paragraph 3-1639), and

    Withdrawing approval of a training and qualification curriculum which has already received final approval in accordance with § 121.405(e) (see paragraph 3-1640).

Indicates new/changed information.

3-1638    EXPIRED TRAINING AND QUALIFICATION CURRICULA. A training and qualification curriculum granted initial approval has an expiration date. Usually, this date may not be later than 24 calendar‑months after the initial approval date. If the POI does not grant final approval before the expiration date, training under that curriculum must terminate as of that date. Therefore, the POI must not allow an initially approved curriculum to expire due to the FAA’s inability to administratively grant final approval. Final approval may not be granted to a CH’s training and qualification curriculum for several reasons. One example may be the CH’s inability to achieve an acceptable level of training effectiveness during phase four of the approval process. Another example of a reason for not granting final approval is the discontinued use of the initially approved curriculum. When the POI decides not to grant final approval before the expiration date, he or she must notify the CH of this decision in writing, at least 30 calendar-days before the expiration date of the initially approved curriculum. A CH not so notified may mistakenly assume that the initial approval will continue in effect until receipt of notification of either final approval or termination. The notification letter should contain the reasons for allowing the curriculum to expire and should state that any further training under the expired curriculum will not be in compliance with regulatory requirements. A POI who fails to provide this 30-calendar-day notification must establish a new expiration date so that appropriate notification can then be given to the CH.

3-1639    WITHDRAWAL OF INITIAL APPROVAL OF TRAINING AND QUALIFICATION CURRICULA. A POI may decide to withdraw initial approval any time during phase four of the approval process. This action may be necessary if the training or qualification is not in regulatory compliance, does not provide for safe operating practices, or is ineffective in meeting training objectives. A CH who has received a letter withdrawing approval must revise or refine the training and qualification curriculum and resubmit it for initial approval. The POI must ensure that the CH understands that it is its responsibility to correct each deficiency in the training and qualification program. The POI withdraws initial approval of training and qualification curricula by letter. This letter must contain both a statement informing the CH that initial approval is withdrawn and the effective date of the withdrawal. This letter must include the reasons for withdrawal of approval and a precaution concerning the use of persons trained under a curriculum which is not FAA approved. Figure 3-211, Sample Letter of Withdrawal of Initial Approval, provides a sample letter for withdrawing initial approval.

3-1640    WITHDRAWAL OF FINAL APPROVAL OF TRAINING AND QUALIFICATION CURRICULA. Each CH is responsible for ensuring that its training and qualification curricula, once they have been granted final approval, continue to provide training in accordance with the conditions under which final approval was granted. In accordance with § 121.405(e), whenever the FAA determines that revisions to a curriculum that has been granted final approval are necessary, the CH must, after notification, make the necessary changes to ensure the effectiveness and acceptability of its training. Such notification by the FAA effectively withdraws final approval. These regulations also provide the CH with certain appeal rights. Therefore, the following procedures will be applied when a decision is made to withdraw final approval of a training and qualification curriculum.

A.    Required Items of the Notification Letter. The responsible Flight Standards office must inform the appropriate Office of Air Carrier Safety Assurance division of the impending action to withdraw final approval. The POI must notify the CH in writing that revisions are required in accordance with § 121.405(e). See Figure 3-212, Sample Letter of Withdrawal of Final Approval, for a sample letter of a notification for withdrawing final approval. The notification letter must contain the following:

    A statement that FAA approval of the training and qualification curriculum is withdrawn,

    A list of the revisions that must be made,

    A brief description of the reasons necessitating the revisions,

    A precautionary statement concerning the use of personnel trained under a curriculum which is not FAA approved,

    A statement that the actions specified in the letter may be appealed, and

    Instructions on how to make an appeal.

B.    Revisions. If the CH chooses to revise the training and qualification program in response to the notification letter, the proposed revision will be processed in the same manner as a request for initial approval. The POI must reinitiate the five-phase approval process previously described.

C.    Appeal of Decision by CH. If a CH decides to appeal the POI’s action, it must, within 30 calendar‑days after receiving notification, petition the responsible Flight Standards office manager for reconsideration of the withdrawal of final approval. The petition must be in writing and contain a detailed explanation on why the CH believes the revisions described in the withdrawal notice are unnecessary.

1)    If upon receipt of a petition, the office manager believes that an emergency exists which directly impacts aviation safety, he or she must immediately inform the CH in writing of his or her decision. The office manager’s letter must include a statement that an emergency exists, a brief description of the revisions that must be made, and the reasons the revisions are necessary. In this case, the office manager’s letter upholds the POI’s decision to withdraw final approval. Consultation with the appropriate Safety Assurance division and AFS-200 may be advisable. The CH must revise its training and qualification program if FAA approval is to be obtained.
2)    If the office manager does not believe an emergency exists, he or she must give careful consideration to both the CH’s petition and the POI’s reasons for withdrawal of approval. The CH’s petition stays the POI’s withdrawal of final approval and the CH may continue to train under the training and qualification curriculum, pending the office manager’s decision. The office manager may need to conduct additional evaluations of the CH’s training and qualification program. It may be appropriate for the office manager to obtain additional facts from other sources. Consultation with the appropriate Safety Assurance division and AFS-200 may be advisable.
3)    The office manager must make a decision within 60 calendar-days after receipt of a CH’s petition. If the office manager accepts the CH’s explanations, he or she will direct the POI to rescind the letter that withdrew final approval, either partially or fully. If the decision is to uphold the POI’s action, the office manager must respond to the CH’s petition in writing.
4)    The letter denying the petition should indicate that careful consideration was given to the petition. The letter must also contain the reasons for denying the petition and a statement that confirms the withdrawal of final approval. The letter must also contain a statement that any training conducted under the unapproved training and qualification curriculum is contrary to 14 CFR.

3-1641    ORGANIZATION OF OFFICE TRAINING AND QUALIFICATION PROGRAM FILES. The POI must maintain a separate training and qualification program file for each CH at the responsible Flight Standards office. Each CH’s training and qualification program file will be organized and maintained to keep each major curriculum type and any revisions together. Superseded training and qualification curriculum pages must be kept on file for 2 years. All correspondence and additional relevant supporting information associated with each training and qualification curriculum will be filed with the curriculum or curriculum segment, as appropriate.

Figure 3-207.  Sample Letter of Initial Approval

ABC Airlines

Director of Operations

1 Park Avenue

New York, NY 11001

Dear Mr. Townsend:

This letter is in reference to ABC Airline’s Aircraft Dispatcher Initial Equipment curriculum, pages 100/1 through 100/15, dated April 14, 2018. This curriculum is granted initial approval, effective April 30, 2018.

The expiration date of this initial approval is April 30, 2020. This office requests ABC Airlines provide at least 7 days advance notice of any training to be conducted under this curriculum to allow for evaluation of the training in accordance with Title 14 of the Code of Federal Regulations (14 CFR) part 121, § 121.405(b) and (c).

Sincerely,

Principal Operations Inspector

Figure 3-208.  Sample Letter of Denial of Initial Approval

ARK Airlines

Director of Operations

48 Turnover Place

Indicates new/changed information.

Landover, MD 20765

Dear Mr. Townsend:

This letter is in response to your request for initial approval of Revision 2 to ARK Airlines’ Aircraft Dispatcher Recurrent Ground Training curriculum, dated August 2, 2018. Your request for initial approval for Revision 2 is denied for the following reason:

More than 70 percent of your scheduled operations occur in areas that during the winter months are subject to cold weather, snow, ice, and sleet. Your aircraft dispatcher workforce must have adequate training in the safe operating practices associated with a cold weather environment to enable them to cope effectively with such hazards. Revision 2 deletes training previously given on major aspects of cold weather operations and does not provide any identifiable instruction to your aircraft dispatchers for dispatching flights in such conditions. Presently, there is not another course of training for ARK Airlines’ aircraft dispatchers containing adequate information on cold weather procedures.

Sincerely,

Principal Operations Inspector

Table 3-80.  Components for Training and Qualification Evaluation

 

COMPONENTS AVAILABLE FOR EVALUATING TRAINING AND QUALIFICATION

CURRICULUM SEGMENT OUTLINES

Curriculum segment outlines contain the specific modules and the amount of time allocated for the curriculum segment. The modules must be consistent with regulatory requirements and safe operating practices. This component requires direct examination.

COURSEWARE

Courseware converts curriculum outline information into usable instructional material. Courseware must be consistent with the curriculum outline and be organized to permit effective instructional delivery. It is readily adaptable to adjustments and refinement by the CH. This component usually requires direct examination.

INSTRUCTIONAL DELIVERY METHODS AND TRAINING ENVIRONMENT

Instructional delivery methods are used to convey information to the aircraft dispatcher. Effective learning is maximized if the instructional delivery adheres to and properly uses the courseware. The training environment should be conductive to effective learning. This component requires direct observation.

TESTING AND CHECKING

Testing and checking is a method for determining whether learning has occurred. Testing and checking standards are used to determine that a desired level of knowledge and skill has been acquired. Testing and checking also measures the effectiveness of courseware and instructional delivery. This component requires direct observation. It can be supplemented by examining CH records of tests and checks.

SURVEILLANCE AND INVESTIGATION OF CH ACTIVITIES

Surveillance and investigations produce information about a CH’s overall performance. A high rate of satisfactory performance usually indicates a strong, effective training and qualification program. Repeated unsatisfactory performances can often be traced to deficiencies in a training and qualification program. This component requires the examination and analysis of surveillance and investigative reports.

Figure 3-209.  FAA Final Approval

Figure 3-209. FAA Final Approval

Figure 3-210.  Sample Letter of Final Approval

ABC Airlines, Inc.

Director of Operations

417 Oakton Boulevard

Enid, OK 78154

Dear Mr. Townsend:

Final approval is granted to ABC Airlines’ Aircraft Dispatcher Recurrent Ground Training curriculum, for pages 1 through 5, dated May 21, 2017, and for pages 6 through 7, dated April 15, 2018.

The effective date of final approval is January 20, 2019. ABC Airlines may continue to train in accordance with this curriculum until a revision is required by the Federal Aviation Administration (FAA) under Title 14 of the Code of Federal Regulations (14 CFR) part 121, § 121.405(e) or until ABC Airlines revises the curriculum.

Approval of the reduced training hours from the programmed hours required by § 121.427(c)(3)(iii) to 15 hours is based on the improved training techniques available from your use of computer-based training (CBT).

Sincerely,

Principal Operations Inspector

Figure 3-211.  Sample Letter of Withdrawal of Initial Approval

ABC Airlines

Director of Operations

49 Wheat Drive

Barley, Iowa 96496

Dear Mr. Roberts:

This letter notifies you that the Federal Aviation Administration’s (FAA) initial approval of the following training curriculum segments is withdrawn, effective April 1, 2018:

Indicates new/changed information.

1.  The aircraft systems training segment for the Aircraft Dispatcher Initial New-Hire curriculum, pages 9.1 through 9.3, dated November 15, 2016.

2.  The minimum equipment list (MEL) segment for the Aircraft Dispatcher Initial New-Hire curriculum, pages 9.31 through 9.33, dated June 1, 2017.

The investigation of the incident that occurred on ABC Airlines’ Flight 943 on July 10, 2017, revealed that the aircraft dispatcher did not take positive action to apply MEL restrictions for MEL 28-05A. During the FAA interview, the aircraft dispatcher displayed a lack of concern about the importance of applying the restriction that called for all fuel in the center tank to be shown as unusable fuel. In addition, since this incident, inspectors from this office have been emphasizing MEL restrictions to aircraft dispatchers taking the above listed training. These inspectors have observed that many of your aircraft dispatchers have a serious lack of knowledge about aircraft systems procedures and application of MEL restrictions. We have discussed these deficiencies with your staff and they have effectively revised the aircraft systems curriculum segment. Your staff, however, advises that they will not revise the training curricula for MEL restrictions. Therefore, FAA initial approval is withdrawn. Initial approval can be reobtained by revising the curriculum to require detailed instruction on MEL restriction procedures. It is contrary to Title 14 of the Code of Federal Regulations (14 CFR) part 121 to use aircraft dispatchers who have not been trained in accordance with an approved training and qualification curriculum.

Sincerely,

Principal Operations Inspector

Figure 3-212.  Sample Letter of Withdrawal of Final Approval

ABC Airlines, Inc.

Director of Operations

49 Wheat Drive

Barley, Iowa

Dear Mr. Roberts:

This letter notifies you that, effective April 7, 2018, final approval of your Boeing 737 Aircraft Dispatcher Transition curriculum, dated March 15, 2017, is withdrawn in accordance with Title 14 Code of Federal Regulations (14 CFR) part 121, § 121.405(e). This curriculum must be revised as discussed below if the Federal Aviation Administration (FAA) initial approval is to be reobtained.

The revised curriculum is required to have more detailed instruction on the performance and limitations of the Boeing 737. During the past 3 months, aircraft dispatchers who completed the above curriculum provided incorrect takeoff and climb performance on multiple dispatch releases. The FAA has determined, through interviews with these aircraft dispatchers, that the training being given does not provide sufficient knowledge for proper calculation of Boeing 737 takeoff and climb performance.

You may file a petition for reconsideration of this withdrawal of final approval within 30 calendar-days after receipt of this letter by writing to Mr. Belsole, Manager, Great Atlantic Certificate Management Office (CMO). Your letter should contain a complete explanation of why you believe final approval of the Boeing 737 Aircraft Dispatcher Transition curriculum should not be withdrawn. It is contrary to part 121 to use aircraft dispatchers who have not been trained and qualified in accordance with an FAA-approved training and qualification curriculum.

Sincerely,

Principal Operations Inspector

RESERVED. Paragraphs 3-1642 through 3-1650.