This post is the third in a series about common errors or concerns I see while conducting safety and operational audits. The first and second posts are linked here: “Internal Evaluation Programs: Headache or Helpful Tool?” and “Managing Flying Managers”. (Incidentally, will you be at the NATA Air Charter Summit in DC next week? I’ll be there presenting “Regulatory Adventures from the Field”. If you don’t attend, you’re not only missing my witty banter but also a really great conference. It’s not too late to register and join us for networking, education, and FUN!)
Let’s have a frank discussion (the only kind I know how to have) about crewmember records. Training records should really be a no-brainer, yet many audit findings are based on training record deficiencies. Are your records in order or are pages falling out of the folder or binder haphazardly? Are the files all organized in the same fashion or does someone just stick a page in the folder on occasion? Do you have duty assignment records in each pilot folder or does an auditor or inspector get to guess the pilot’s aircraft and position assignment?
Duty Assignment Records
One of the very first pages of your pilot crew files should be a duty assignment record. Duty assignment records are not just a “Lindsey thinks it’s a good idea” item. I believe they’re a regulatory requirement. See 135.63(a)(4)(iv), which states you must keep an “individual record” of “the pilot’s current duties and the date of the pilot’s assignment to those duties”. The duty assignment record should list the pilot’s current duties, including aircraft type / position assignment, and the date of assignment. (I recommend keeping historical assignment data as well if the pilot has flown more than one aircraft type and/or position for your company.) I’m often given a FOS or other scheduling software print out report of duty assignments. Aside from the fact these print outs are usually out of date or otherwise inaccurate, I don’t believe this is really the intent of the regulation. I believe the regulation means for EACH pilot file to have a duty assignment sheet.
Further, the duty assignment information is an absolutely critical piece of information and DESERVES to be front and center in each pilot’s file. It shows an auditor (or FAA inspector) how far back to look that this pilot was qualified in this aircraft. It helps the auditor determine if Pilot Records Improvement Act (PRIA) requirements and drug testing were completed at the appropriate time. It also tells an auditor not to bust your chops if the pilot doesn’t have a 135.299 check because they know from the sheet that he’s an SIC and isn’t required to have one, or to know that a pilot once flew the Hawker 800 but has since been assigned to a different aircraft so not to bother looking for Hawker currency. Help me, help you. Have clear, concise duty assignment records.
“Archived” records are another issue. You must be able to show current compliance (so keep the most the recent training records and 8710s), one round of preceding training records and 8710, and initial compliance (first training in the aircraft for your company). So if a pilot did a recurrent in 2013, keep 2013, 2012, and initial in the main pilot file. If he’s been with you in the same aircraft since 1980, feel free to put the interim files in an archive somewhere. If you’ve hired a pilot who flew the same aircraft with another company, ideally you’ll have his/her initial type rating and other training records from the previous employer. However, we all know PRIA isn’t perfect. (Holy Toledo – it’s not?) Operators fail to respond. The previous employer could be a Part 91 operator and therefore not required to keep extremely detailed training records. The previous employer could be out of business. The previous employer could just be a loser who didn’t respond appropriately. In any case, you should have the pilot’s initial type rating and other training records to verify the pilot’s previous experience, but at the very least, make sure you have the pilot’s records of initial training with YOUR company.
It’s not surprising that operators often struggle with these records. Most operators don’t have a very structured process for ensuring compliance with these requirements. Training records are received or downloaded from training centers weeks after the training was completed. Records for in-house training lack detail, aren’t signed, or are missing completion dates and times. Schedulers or flight followers rely on data from scheduling software to verify compliance with training requirements but don’t know how that information was entered into the software, where it came from, or who is responsible for upkeep. If you don’t have a defined, structured process for managing training records, you should. There’s really no excuse for not maintaining these records properly and it’s a very easy area for an FAA inspector to pile on findings during an inspection – or worse – investigation. Pilot records violations can cost your company thousands of dollars in civil penalties or be used to support certificate enforcement action against your operation. In other words, don’t leave low hanging fruit.
What do your training records look like? Do you have accurate duty assignment records in each file? If an auditor or inspector wants to verify a pilot’s compliance with training requirements, is the trail easy to follow or are your records a mess with most information archived in a basement? Do you have a documented process for maintaining and auditing your training records?
I have worked with many air charter operators to improve their training records and develop processes for maintaining and auditing those records. This is one of those tasks that appears to be a paperwork shuffle but could really save your tail in the event of a critical FAA inspection. The process of cleaning up records and establishing a process to keep these records isn’t exactly a weekend at the beach but it’s not impossible with some objective assistance. Do you need advice on how to manage these important compliance documents? No need to reinvent the wheel. Contact me at Lindsey@mcfarrenaviation.com or by phone at 703-445-2450 and we can talk about your operation’s challenges.