Occasionally, someone tells me I’m too picky about the accuracy of pilot records or I am unreasonable because I expect perfection in training and checking compliance. Do you know who else expects perfection? The FAA. Do you know what an error or oversight can cost you? Tens of thousands of dollars.
(The FAA and I both have allowances for human error. See the section about the Voluntary Disclosure Reporting Program below. The FAA isn’t totally heartless. Neither am I.)
The FAA recently proposed an $84,700 civil penalty against an Illinois-based Part 135 air carrier operating two aircraft. The FAA alleges the air carrier allowed one of its pilots to fly at least 16 revenue flights between June and September 2014 when he had not passed a required FAA competency check within the past 12 months for the category, class and type of aircraft he was operating.
With civil penalties related to training or checking violations, the dollars don’t just add up – they multiply. Typically there’s a penalty for the training or checking violation itself PLUS an additional penalty for each Part 135 revenue flight conducted by that pilot until the training or checking event is successfully completed. You can see how a minor oversight or error can turn into big bucks, even over a fairly short period of time!
The FAA publishes these proposed penalties in the form of very short press releases, leaving a lot of questions for those reading the release until the enforcement case is finally closed (usually settled for an amount less than that proposed) but there are some lessons to be learned even from the little information presented in the press release.
- Your company isn’t “too small” be noticed. This air carrier operates two airplanes.
- An error or oversight you make now can cost you a fair chunk of change – even if it takes the FAA almost a year to make a decision on civil penalties.
- Frequent auditing of your pilot records can save you a bundle.
- If you catch an error or oversight in your pilot records, the FAA’s voluntary disclosure reporting program (VDRP) might be your best friend – assuming you have a log-in for the website so you can submit a report within 24 hours of your discovery.
You DO have a log-in for the website, right? If not, go get one! It is not uncommon for me to discover training or checking violations in formal audits, gap assessments, or routine consulting projects. The client who already has a log-in for the VDRP’s website can avoid an awkward phone call with their FSDO.
(Please note this organization has the right to respond to the FAA and appeal the allegations. It’s my unofficial policy not to name an organization against which the FAA has alleged violations unless and until the case is settled.)
I’ve talked about training and checking violations, crewmember records, records retention, and internal auditing procedures before. Read up on suggestions and guidance in previous posts by clicking the links.