Aviation Business Journal Third Quarter 2011 - (Page 21)

Avoid a Training Credit Crisis By Lindsey C. McFarren, McFarren Aviation Consulting O ne of the hottest topics at the recent NATA Air Charter Summit was the legality of transferring or giving credit for pilot training from one air carrier to another. Here’s an example: The Part 135 air carrier for which you work hires Fred, a Falcon 50 pilot. Fred is currently flying the Falcon 50 as pilot-in-command for another Part 135 air carrier. He has over one thousand hours in the Falcon 50. He also completed Falcon 50 training at a Part 142 training center just two months ago and has fresh 135.293 (oral/written company information and basic flight proficiency), 135.297 (instrument proficiency) and 135.299 (line/route) checks. That’s why you hired him — he’s experienced and just completed training. You’ve found the perfect candidate. In fact, you’re going to put him through your company indoctrination class and schedule him for a trip next week. But wait a minute! How much of Fred’s training and checking is really relevant to your operation? Does the FAA allow you to transfer the simulator training he just completed and accept his 135.293, 135.297 and 135.299 checks? Most people probably agree that company indoctrination is required and an oral/written company check [135.293(a) (1) and (4-8)] must be completed. And it’s pretty clear that hazardous materials training is operator-specific as the regulations require hazardous materials training be conducted by each air carrier. FAR 135.505(a), which states: “No certificate holder may use any crewmember or person to perform any of the job functions . . . unless that person has satisfactorily completed the certificate holder’s FAA-approved initial or recurrent hazardous materials training program within the past 24 months.” It is a common practice in the charter industry for one air carrier to accept the training provided by another air carrier. Until just a few years ago, this practice was often conducted with the FAA’s knowledge and approval. In 2009, a Californian air carrier asked the FAA for guidance on this issue. The air carrier had reached an impasse with its principle operations inspector (POI) regarding the level of aircraft training required of a pilot before that pilot could be used in contract service for the air carrier. The POI told the air carrier that any pilot planning to fly for the air carrier had to undergo full initial training on each aircraft the pilot would fly before conducting commercial flights for the air carrier. In Falcon 50 Fred’s case, if you wanted to hire Fred as a contract pilot for your air carrier he would have to undergo full initial aircraft training even if he had just completed Falcon 50 training for another air carrier. The Part 135 air carrier wrote FAA headquarters under the Consistency and Standardization Initiative (CSI) requesting clarification of training requirements. The request pointed to old FAA inspector guidance found in the Flight Standards Handbook Bulletin for Air Transport (HBAT) 99-12, which outlined the FAA’s policy in respect to reduced ground training hours and reduced flight training hours for pilots of part 135 carriers who are not current and qualified in a particular aircraft with a particular part 135 operator. A pilot who was still current or fewer than 12 months out of currency with another Part 135 air carrier could be given as little as four hours aircraft specific ground training and four hours of flight or simulator training. Going back to Fred, who is current in the Falcon 50 with Air Carrier A, the old HBAT policy would have allowed Air Carrier B to reduce Fred’s aircraft specific ground and flight or simulator to just four hours each. But even when this HBAT was in effect, it was not blanket permission to reduce a pilot’s training hours. Most air carriers missed the critical sentence: “Any reduction in training hours is at the discretion of the POI.” Further, this HBAT did not permit wholesale acceptance of another air carrier’s program — it only allowed a reduction in training hours based on a pilot’s previous training. It also did not address credit for checking, such as the 135.299 line checks. The FAA’s response to the air carrier requesting guidance was not favorable to the industry: “For one operator to accept the training conducted under another operator’s approved curriculum, without first conducting a detailed side-by-side comparison designed to identify the differences between the curriculums, is not consistent with sound operating practices… For one operator to assume that another operator’s training program meets these operator specific requirements, without a detailed comparison, again is not consistent with applicable Continued on page 23 Aviation Business Journal | 3rd Quarter 2011 21

Table of Contents for the Digital Edition of Aviation Business Journal Third Quarter 2011

Aviation Business Journal Third Quarter 2011

Aviation Business Journal Third Quarter 2011 - (Page 1)
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