Working with Air Carriers 142 Training Center Perspective

Rick Bedard FlightSafety International

Topics for Discussion

• Review of the 142 Training Center model

• Changing Regulatory Environment

• Current and Future Actions

142 Training Center Model • 14 CFR Part 142 effective 3 August 1998

– 142.1 (a) This subpart prescribes the requirements governing the certification and operation of training centers. Except as provided in paragraph (b) of this section, this part provides an alternative means to accomplish training required by parts 61, 63, 65, 91, 121, 125, 135, or 137 of this chapter.

• Order 8900.1, Vol. 3, Ch 54, Sec 5 (Chg 170)

– “NOTE: “Alternative means” as used in part 142 has in some cases been misunderstood and has been interpreted to mean that compliance with a training center’s approved courses will meet the training requirements required by the appropriate operating rules for an operator. This is not the case.

– “Alternative means” permits an operator to outsource or arrange to have its approved training conducted by a third party. It does not mean that an operator has an “alternative means” to meet the training approval requirements governing its particular operation. Programs approved in accordance with part 142 may not be used as an alternative means of satisfying the requirements of the appropriate operating rules as approved by the operator’s POI. ”

142 Training Center Model

• Aircraft-specific training IAW Air Carrier’s approved training program:

– Option 1 – Air Carrier program based on 142 Core Curriculum: • Identify and document differences between the 142 core

curriculum and the air carrier program

• Provide differences training to the contract instructors/check airmen

• more flexible, less overhead

142 Training Center Model

• Aircraft-specific training IAW Air Carrier’s approved training program:

– Option 2 – Air Carrier program NOT based on 142 Core Curriculum: • “source of training” identifies what the 142 Training Center will

provide for training/checking

• Air Carrier must provide courseware and training for contract instructor/check airman

• less flexible; more overhead

142 Training Center Model

• Qualified 142 Training Center Evaluators/Instructors as contract check airmen/instructors: – Per 135.337/.338 (b)(2): “has satisfactorily completed the training

phases for the aircraft, including recurrent training, that are required to serve as pilot in command in operations under this part;” and

– (b)(4) :“has satisfactorily completed the applicable training requirements of 135.339/.340.”

142 Training Center Model

• Previously accepted means of compliance: – Remain qualified as 142 Training Center Flight/Simulator Instructor/TCE

(135.339/.340)

– ATP and Typed in the aircraft training phases for the aircraft…” (135.337/.338 (b)(2))

– Current 135.293 (a) (2) and (3), and 135.297 (135.339/.340 (b)(3) -(limit of checking autho)

– Observation Prof. Check every 24 months by an FAA inspector or operator DE.

– Instructors approved by operator; Check airman LOA from POI

– Training for differences between 142 core curriculum and operators training program.

– Participate in the training center’s USDOT/FAA Drug and Alcohol Testing Program

Changing Regulatory Environment • Changes to Contract Instructor/Check Airmen

Training and Qualification Requirements – Jan 2010 – Aug 2011: “Creeping Guidance” - prove that contract

instructors/check airmen had completed one air carriers “basic indoc” – Aug 2011: Order 8900.1, Sec 3, Ch 54, Sec 5 (Chg 170)

• “…contract instructor or contract check airman nominee has completed at least one air carrier or program manager’s initial training and qualification curriculum as a flight crew member under the same 14 CFR part…”

• Line check not required – Feb 2013: Order 8900.208/215

• Allowed use of affidavit to document completion of an INH from previous employer if records are not available;

• Established deadline of 30 Sep 2013 for POIs and air carriers to have INH documentation for all contract instructors/check airmen

Changing Regulatory Environment

• As of 30 Sep 13: Est. 55% of 142 Instructors/TCEs meet the INH requirement. Impact: – Training centers have Less capacity, availability, and flexibility to

support air carrier training

– Increase cost for operators and training providers to get 142 instructors/check airmen trained

– Added distractions for operators and training providers to comply with non-value added requirements

– Trend for operators to return to training/checking in the aircraft

• What’s Next??

Current Actions

• What have we done?

– 142 Training Centers met with AFS-210 in May 2011 to voice concerns and offer suggestions.

– “Call to Action” working group submitted an Air Carrier Equivalency Training Program to AFS-200 (Nov 2011, and Jan 2013)…still under review.

– Hosting bi-monthly FAA/Industry telecons with AFS-200 to discuss current issues

Future Actions

• What more can we do?

– Keep our “eye on the ball” – Operate Safely & Train for Excellence!

– Unite in purpose – Sound Off!

• Industry groups

• Congressional

– Press for Rulemaking Action to address the issues from the 135/125 ARC in 2009

Changing Regulatory Environment

Changing Regulatory Environment

Working with 135 Air Carriers

Thank You!

Rick Bedard – Cell: 561.543.4399