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Mon, Dec 19, 2005

EAA, NAFI Help Secure Waiver For 'In-Month' Recurrency Requirement

Agencies Ask TSA To Help Flight Schools, Instructors With Security Training

Thanks to direct involvement from the Experimental Aircraft Association (EAA), the National Association of Flight Instructors (NAFI), and other aviation organizations, the TSA has waived a requirement for flight school employees and independent CFIs to receive recurrent security training in the same month as when they received initial security awareness training. The waiver instead allows 18 months to get annual security awareness recurrency training.

In addition, the EAA and the NAFI are asking the Transportation Security Administration (TSA) to help flight schools and independent flight instructors comply with mandated recurrent security training.

"We (EAA and NAFI) have received several phone calls from our members who are confused by the current process and find it difficult to locate specific regulatory and administrative requirements within the TSA website," said EAA Government Relations Director Randy Hansen. "Part of the confusion lies in the lack of information on the website about which TSA officials the public should contact when questions arise concerning either the initial or the recurrent security awareness training programs. We hope our discussions with TSA will eliminate these issues."

Specifically, the member organizations would like TSA to create a free and field-accessible program to help ensure compliance with TSA regulation 49 CFR Part 1552, "Flight Training for Aliens and Other Designated Individuals; Security Awareness Training for Flight School Employees."

EAA and NAFI are also asking TSA to make finding regulatory requirements within the TSA website a much simpler process by creating web links to specific Department of Homeland Security (DHS) and Department of Transportation (DOT) regulations that impact initial and recurrent training.

The TSA initially published the Security Training Awareness Training program for Flight Schools and Independent CFIs in the Federal Register on September 2004, creating 49 CFR 1552. The initial training requirements required flight school employees hired on or before January 18, 2005, receive the initial training no later than January 18, 2005.

For employees hired after January 18, 2005, initial training must be completed no later than 60 days after date of hire. A key component of this new rule is the requirement for those same employees to complete recurrent training each year "in the same month as the month they received initial training." Training requirements of 14 CFR 1552 include procedures for verifying citizenship of those seeking flight training, procedures for non-U.S. citizens (aliens) seeking flight training; and mandatory security awareness training for all flight school employees and independent CFIs.

The one-year anniversary date for those first trained has passed, as many instructors and flight schools personnel completed their initial training in October 2004. Many of these individuals and others who completed training in November 2004, December 2004, and January 2005 may not of completed the recurrent training requirements, simply because the TSA regulatory guidance was, or is, very difficult to locate.

FMI: www.eaa.org, www.nafinet.org

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