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FAA Addresses Industry Concern on Use of Part 142 Training Centers

July 11, 2008

Issue Overview

The FAA has published additional guidance that responds to concerns raised by NBAA regarding the use of Part 142 training centers. In April the FAA published Notice 8900.37 which provided guidance for Principal Operations Inspectors (POI) to use in reviewing the training programs of commercial air carriers authorized to contract for training, checking, or testing services with Part 142 training centers. One of the concerns raised by NBAA members was the requirement for all contract check airmen and instructors to complete an in-flight line observation program with each operator they are authorized to conduct instruction or checking for. This line observation requirement must be met every 12 calendar months.

In response to this concern, the FAA has provided operators with an alternate method that may be used to satisfy the line observation requirements. The alternate method allows an operator’s contract instructors or check airmen who instruct or check in simulators that replicate eligible aircraft to meet the observation requirement by performing a Line Operational Simulation (LOS). Through a LOS program contract instructors or check airmen obtain current real-world operational knowledge by conducting specific air carrier procedures in a flight simulator.

  • Eligible Aircraft: For the purpose of this policy, the FAA defines an eligible aircraft as an airplane that does not have a cockpit jump seat. An eligible aircraft may also be an airplane with a jump seat that is operated at a remote distance from a training center or that for sound operational reasons is otherwise not reasonably available for use by training center personnel. The determination of eligible aircraft is at the discretion of the POI and, where appropriate, the training center program manager.

Operators with aircraft not meeting the eligible definition would be unable to utilize the alternate method. In these cases, the contract check airman could meet the observation requirement by using one of the following methods:

  1. Fly at least two flight segments as a required crewmember in an airplane that is the same category and class (and type if applicable) as one of the types in which that person is authorized to conduct checking.
  2. Satisfactorily complete an approved in-flight line-observation program (consisting of two flight segments minimum) for one operator for which that person is an authorized check airman.

It is important to note that a check airman who meets the line observation requirements described above for one operator is deemed to have met the requirements for all operators he/she conducts checking for. The accomplishment of one operator’s line observation program in a 12-month period is considered sufficient. For additional information, download the FAA policy statement or contact NBAA’s Operations Service Group at