Neil, thank you for the background on Part 142, and your advice. At this
point our FSDO no longer believes that we should seek certification under
Part 142, and is investigating options for DRM/CRM course approval. I'll
keep the group informed as we progress, should the information be of value
to others.
I greatly appreciate the benefit of your insight.
Thanks,
Jeff
-----Original Message-----
From: Neil C. Krey <neilkrey_at_mail.airmail.net>
To: crm-devel_at_db.erau.edu <crm-devel_at_db.erau.edu>
Date: Tuesday, August 18, 1998 3:44 AM
Subject: RE: Part 142 certification for management consulting firm
>
>Good Afternoon CRMers!
>
>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
>
>