September 24, 2012

The NBAA Domestic Operations Committee and its Part 135 lead hope to broker new language in guidance to FAA principal operations inspectors (POIs) that will ease the interpretation of guidelines that have forced at least one operator to ground both crews and aircraft because of training and certification issues, and have led some Part 142 training centers to pull the qualifications of instructors and check airmen.

At issue is FAA 8900.1 Volume 3 Chapter 54 Section 5. Paragraph 3-4415 Subparagraph F 3, which states:

“Before an air carrier authorizes a contract instructor or nominates an individual to become a contract check airman, the air carrier must provide its POI with evidence that these individuals have completed at least one air carrier’s initial training and qualification curriculum as a flight crewmember for an operator certificated under the same CFR part. Providing the operator and the assigned POI find this training and qualification acceptable, individuals may be considered to have met the non-aircraft-specific training requirements to become a contract instructor/check airman. The completion of an operator’s line check requirement(s) is not required. Following the completion of an appropriate differences training curriculum, the subject individuals may be authorized as contract instructors and nominated to become contract check airman. This process should preclude an individual from conducting training and checking in an air carrier environment without ever having had the benefit of, at a minimum, the training required to qualify an individual to act as required crewmember for an air carrier.”

“The indoc [indoctrination] training covers everything from the policies and procedures of a particular carrier to the company’s safety management system and how they use it to report hazards,” explained NBAA Project Manager Mark Larsen.

“That’s not a bad thing,” added NBAA Domestic Operations Committee Part 135 Lead Allan Mann, who is director of operations at Reynolds Jet Management in Cincinnati, OH. “The FAA guidance is that, in order for the POI to approve those instructors and check airmen to work with my flight crews, they must first have an idea of how my people work in the real world. The thinking behind that is laudable.”

Many instructors at Part 142 training centers have plenty of real-world experience as flight crewmembers for Part 135 operators. The problem is proving that in a way that is acceptable to the POI, according to Mann. “There’s no guidance from FAA on acceptable documentation.”

Already, without that guidance, one NBAA Member has been forced to ground two aircraft and several flight crewmembers, according to Larsen.

“There are check airmen and instructors at the Part 142 training centers whose qualifications have basically now been pulled, which forces the operators to then train in the airplane,” he said. ”That particularly concerns us because simulators are ideal platforms for training on challenging maneuvers like engine failures on takeoff… things we can’t as safely replicate in the airplane as we can in the sim.”

Mann said members of the Domestic Operations Committee and Part 142 training center operators have formed a working group in hopes of requalifying check airmen and instructors at simulator facilities nationwide. Almost immediately, he said, the group plans to present the draft of a proposed interim solution to FAA that all parties might find acceptable until a long-term solution is found.

“It would be a note in the FAA guidance that would suggest acceptable courses of indoctrination documentation that might include logbook endorsement, a statement from a previous POI, training records that indicate completion of an indoc course, or logs showing PIC flights flown for a Part 135 operator. It could be a statement from a company or former company official or personnel records that indicate the instructor or check airman was a pilot in command (PIC) or second in command (SIC) at Part 135 company,” Mann said.