Updated May 23, 2013
Many Part 135 operators utilize the services of Part 142 Training Centers to perform at least a portion of the training contained in the operator’s Federal Aviation Administration (FAA) approved training program. The FAA has clarified its expectations of operators in this area over the last months. A group of NBAA-Member Part 135 operators, Part 142 training centers, and FAA Flight Standards officials have been working through the concerns of all parties on this topic.
Required Training for Contract Instructors and Check Airmen
Sections 135.337 and 135.339, specify the qualification and training requirements for check airmen. Sections 135.338 and 135.340 specify the qualification and training requirements for flight instructors. Further guidance on this can be found in FAA Order 8900.1, Volume 3, Chapter 20, Section 1
The FAA notes in FAA Order 8900.1, Volume 3, Chapter 54, Section 5, Para 3-4415(f)(3):
“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 crew member for an air carrier.”
Training Records for Contract Instructors and Check Airmen
The following training records are required for initial authorization of a check airman. Operators should keep current a record with copies of the following for each contract flight instructor and check airman to be utilized, as outlined in FAA Order 8900.1, Volume 3, Chapter 20, Section 2:
- The airman’s initial new hire training and qualification records (except line check) as a flight crewmember under the same CFR part.
- Aircraft specific training records, including the airman’s initial, transition, or upgrade training and qualification in the applicable aircraft type;
- The airman’s most recent aircraft specific recurrent training and qualification records (as applicable);
- Appropriate flight instructor/check airman training records, completed under the applicable CFR part.
Contract Instructor and Check Airman Training Record Review
In February 2013, the FAA issued Notice 8900.208, “Initial Training Program Records for Contract Instructors and Contract Check Airmen.” This notice requires Part 121 and 135 operators and Part 91K Program Managers that utilize contract instructors and/or check airmen to review the records for those individuals and validate that all required documentation exists.
In the event that an individual has completed at least one air carrier or program manager’s initial training and qualification curriculum as a flightcrew member under the same CFR part, but has lost the records, or cannot obtain the records because the air carrier or program manager is now defunct or still in existence but no longer has the records, the notice prescribes an affidavit process that can be used to substantiate that the training took place.
Notice 8900.208 provided 120 days for operators to review the records available for the contract flight instructors and check airmen it nominated. In May 2013, the FAA released an additional notice, Notice 8900.215, that extended the compliance period until September 30, 2013.
NBAA will continue its dialog with FAA officials on the topic of contract flight instructors and check airmen. Part 135 operators and Part 91(K) program managers are encouraged to provide feedback on their experiences with their FSDO for this topic via email to NBAA’s Operations Service Group.