Good question you ask, Jeff. Let me see if I can add anything from my time
with SimuFlite, FlightSafety International, and now Raytheon Flight
Training. I'll start with a history lesson, followed by some answers to
your questions.
FAR 142 was intended to fix a problem that was created in FAR 121 when the
Advanced Simulation Plan (FAR 121, Appendix H) was introduced in the 1980's.
The wording was such that only an airline (certificate holder) could take
advantage of the ASP. It soon became clear that independent training
providers such as SimuFlite and FlightSafety would need a waiver to train
under Appendix H. Additionally, airline training centers needed a waiver to
train crew members from another certificate holder.
As you can imagine, before long there were a LOT of people applying for
waivers to do simulator training. FAA had built themselves a great big
paperwork machine without meaning to. FAR 142 was FAA's solution to this
problem. By creating the certificated Training Center, FAR 142 provided a
regulatory structure for third parties to offer simulator training without
dragging everyone through the waiver process.
As you probably know from reading FAR 142, it requires a well structured
program of approved curriculum, qualified instructors, approved training
devices, and suitable facilities. In my opinion, it is a reasonably well
done piece of rule making. Originally, an Advisory Circular was supposed to
be issued to accompany the rule and provide additional guidance for both
POIs and applicants. It still hasn't been issued.
Obtaining a certificate under FAR 142 simply to offer CRM training seems to
be a bit excessive, and having to obtain waivers of the various requirements
would just put FAA back into the waiver business again. If I were faced
with this problem, I would likely pursue licensing my course to the air
carrier so they could get it approved under their own certificate. Lots
easier that way.
Best regards,
Neil Krey
neilkrey_at_mail.airmail.net
http://web2.airmail.net/neilkrey/
-----Original Message-----
From: owner-crm-devel_at_db.erau.edu [mailto:owner-crm-devel_at_db.erau.edu]On
Behalf Of Jeff Brown
Sent: Friday, August 14, 1998 1:18 PM
To: crm-devel_at_db.erau.edu
Subject: Part 142 certification for management consulting firm
Hello,
I am a partner in an aviation division start-up for an established
management consulting firm. We plan to provide resource management
training as a component of our human factors integration work. Our flight
standards office has advised us that we need to be certifed under Part 142
(Training Center) should we work with pilots, dispatchers, and cabin crew
operating under Part 121.
Has anyone gone through the Part 142 certification process, in order to
provide resource management training in Part 121 operations? I'd be very
interested to learn about how this requirement is being met by training and
development firms that provide their services at their clients' facilities.
Thank you for your consideration.
Jeff Brown