Part 135 Contract Training and Checking (A031)
Part 135 (A031) Contract Training and Checking
The ability for Helicopter Institute Inc. (HII) to provide Part 135 training and checking services is identified within the following regulations as special rules:
• Title 14 of the Code of Federal Regulations (14 CFR)
o Part 91.1075
o Part 135.324
These special rules define the conditions necessary for a Part 135 certificate holder (hereafter referred to as a customer) to contract with or make arrangements with HII to conduct training, checking, or testing on their behalf. They provide a path for the FAA to issue Operating Specifications (OpSpec) A031 Contract Training and Checking to those customers that are using HII to provide training and checking services via the requesting customers FAA training program.
It is important to note that HII is only facilitating training and checking under our customers training program, not HII’s training program.
Prior to A031 training or checking for a customer, HII and the customers training leadership must review the customers FAA approved training program and evaluate any differences between that of the HII Part 135 FAA approved training program. When differences exist, they must be captured and identified within the A031 Standardization Review document. This process allows the A031 training program to move forward. Once the training is completed, the customer will provide to their FAA Part 135 POI a Standardization Review document within 60 days of completion of the training and thereafter, each 24-months. If differences are identified further, the Standardization Review document will be modified to capture these differences accordingly.
When a customer is approved to receive A031 contract training from HII, this does not mean the customer is limited to training with HII exclusively. The training may be shared between HII and the customers’ internal training staff. This process is clearly captured and identified in the Source of Training documentation required for FAA approval prior to OpSpec A031 issuance. The Source of Training document will identify each regulatory element of the Part 135 training to be conducted and identify both the customer and HII to complete an element of the training, or entity individually.
A common mistake by FAA POIs when approving A031 Contract Training and Checking programs is a misunderstanding of the role provided by HII. In many cases, the FAA will attempt to process the A031 process viewing HII as a Part 142 Training Center. This occurs simply because the FAA policy and guidance is focused on Part 142 approvals, other Part 135 operators such as HII providing A031 services.
This confusion is most evident during the A031 Check Pilot approval process. Unlike a Part 142 TCE, an HII Part 135 Check Pilot has met and is qualified to act in the capacity of a Part 135 pilot, instructor, and check pilot. We are not tasked to meet an equivalent level of safety as we already hold a Part 119 approval. To gain approval to provide A031 checking for a customer, HII provides the customers POI with all personal information to include a resume, Part 135 training records to include initial and recurrent training, and existing Part 135 Check Pilot approval letters which must match the same make/model aircraft of the A031 checking event. That’s about it!
HII is here to help keep your Part 135 training and checking program a high-quality, well-oiled process. Let us help with your Part 135 training, checking, scheduling, and even records!