There is significant confusion in the industry on this topic, and Noverant has gone to extensive lengths to research the background, history and intent of 49 CFR 1552. The comments below are the opinion of Noverant, and while we feel strongly in our position, we encourage individuals to check with their local FSDO and TSA office for additional guidance.
In short, the regulation is intended to make those involved in flight training aware of security risks that may arise in their operations. In 49 CFR 1552, TSA has (appropriately) defined flight school in a broad sense: “any pilot school, flight training center, air carrier flight training facility, or flight instructor certified under 14 CFR 1552 part 61, 121, 135, 141, or 142; or any other person or entity that provides instruction under 49 U.S.C. Subtitle VII, Part A, in the operation of any aircraft or aircraft simulator.”
Further, as it pertains to security awareness training, TSA has defined “Flight school employee” to mean: “a flight instructor or ground instructor certified under 14 CFR part 61, 141, or 142; a chief instructor certified under 14 CFR part 141; a director of training certified under 14 CFR part 142; or any other person employed by a flight school, including an independent contractor, who has direct contact with a flight school student. This includes an independent or solo flight instructor certified under 14 CFR part 61.”
So, generally speaking, if you come in direct contact with individuals involved in any type of flight training, then you are most likely required to take the TSA training. Specific examples of those required to take the training include:
1. Certified Flight Instructors – Any type of certified flight instructor (CFI, CGI, AGI) is clearly required to take the training, whether acting as a freelance, contract, or employee of a flight school.
2. Other Instructors – Any other individual who is not certified as a CFI but is involved in instruction or training (e.g., chief pilot, instructor pilot and others in Part 121 or Part 135 operations).
3. Flight School Employees – Individuals with direct contact to students (e.g., customer service, dispatch, line staff, etc.). Note that this is a very large group and may actually be the largest group of individuals required to take the training.
4. FBO Employees – In many cases, an FBO does not directly provide flight training, however they directly or indirectly authorize flight training at their facility through a third party flight school or via independent instructors. In such a case, the FBO can easily be viewed as facilitating flight training, particularly if the FBO employees are involved in providing access to ramp, aircraft, keys, logs, etc. Noverant Aviation Training & Verification (NATV) now offers a free online link to satisfy the TSA initial and recurrent security training. To take either the initial or recurrent training, visit www.noverantatv.com to register and, you’re done!
About Noverant
Noverant Inc. (www.Noverant.com): Noverant is a leading provider of training software and services for small to mid-size companies. Originally focused on industries governed by the U.S. Food and Drug Administration (FDA), the company’s expanded technology now provides web-based solutions for a variety of industries including aviation, legal, biomedical, pharmaceutical, board governance and education. The company’s unique software and service offerings improve the effectiveness and reduce the cost of training, while ensuring 21 CFR Part 11 compliance for electronic signature, management and archival of critical records. The company is headquartered in Research Triangle Park, NC. For further information, please visit www.Noverant.com.