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NAFI and EAA Press TSA on Recurrent Security Awareness Training
December 13, 2005 - With numerous flight instructors facing looming deadlines and the threat of dire penalties, NAFI and EAA are working hard with TSA to compel rapid changes. The problems arise from TSA’s mandate, announced in the fall of 2004, that all flight school employees undergo security awareness training by January 18, 2005 and further receive annual recurrent training in the anniversary of the initial session. Because of vagueness in some aspects of the TSA rule, some instructors who took initial training prior to the January deadline are technically in default of their recurrency requirement.

NAFI seeks three goals in its current efforts:

Develop a system that would make it easier for flight school employees and independent flight instructors to satisfy their annual recurrent security training requirement by creating a free and field-accessible program to help ensure compliance with the TSA requirements.

Provide web links directly to relevant Department of Homeland Security (DHS) and Department of Transportation (DOT) regulations regarding initial and recurrent training. This should enable instructors in the field to find regulatory requirements within the TSA web site a much simpler process.

Create and announce an amnesty and waiver for those instructors who received initial security awareness training prior to January 18, 2004.

NAFI Executive Director Rusty Sachs, EAA Government Relations Director Randy Hansen, and EAA Government Relations Vice President Doug Macnair made the requests during a series of discussions with TSA officials. “NAFI and EAA received several phone calls from members confused by the current process and the inability to locate regulatory and administrative requirements within the TSA web site” stated Hansen. “Part of the confusion arises from the lack of information within the TSA web site about whom to contact with questions about security awareness training programs. We hope our discussions with TSA will eliminate these issues.”

TSA initially published the Security Training Awareness Training program for Flight Schools (and Independent CFIs, whom the TSA considers “flight schools” for the purposes of the regulation) in the Federal Register on September 2004. The training requirements required flight school employees to receive initial training no later than January 18, 2005. For employees hired after January 18, 2005, initial training must be completed within 60 days of hiring. The rule also requires all employees to complete annual recurrent training in the same month as the month they received initial training. Related training requirements include verification of citizenship of individuals seeking flight training and screening procedures for aliens seeking flight training.

As a direct result of discussions with TSA officials, NAFI has developed guidance for flight schools and independent CFIs to complete the recurrency requirements.

TSA regulation 1552.23(d):

(d) Recurrent security awareness training program.

A flight school must ensure that each flight school employee receives recurrent security awareness training each year in the same month as the month the flight school employee received initial security awareness training in accordance with this subpart.

: For those instructors and employees trained in January 2005, your recurrency deadline, January 31, 2006, is fast approaching.

NAFI Note:
EAA’s Doug Macnair recently learned that TSA is in the process of developing a blanket waiver, to be published in the Federal Register, that will provide relief to flight schools and independent CFI’s easing the stringency of the “same month” requirement. This waiver will allow flight schools and independent CFIs some flexibility when meeting the TSA mandated recurrent training requirements.

At a minimum, a recurrent security awareness training program must contain information regarding

Any new security measures or procedures implemented by the flight school;

NAFI Note:
This involves a security briefing by a designated individual -- chief pilot, school owner, school security officer, or the like. It should also include a review of airport security and airport watch procedures in a briefing conducted by an airport official (manager or designated representative).

NAFI Note:
For independent CFIs, this section may be met by a security briefing from the airport manager or designated security representative.

Any security incidents at the flight school, and any lessons learned as a result of such incidents;

NAFI Note:
This requirement may be met in the same manner as above -- briefings to review security issues at the flight school and airport -- including lessons learned. The personnel noted above may conduct the review.

(iii) Any new threats posed by or incidents involving general aviation aircraft contained on the TSA website;

NAFI Note:
TSA has not yet posted this information on its website. Once it has done so, this requirement becomes a mandatory component of all recurrent security awareness-training programs covered by this regulation.

(iv) Any new TSA guidelines or recommendations concerning the security of general aviation aircraft, airports, or flight schools.

NAFI Note:
NAFI encourages all members to visit the TSA general aviation website and review the information. Items of importance include at least those topics listed under the General Aviation Security Initiatives section. A review of the TSA document Security Guidelines for General Aviation Airports is also appropriate. Several sections of this document discuss security measures applicable to flight schools and training aircraft.

NAFI Note:
For independent CFIs operating out of airports without airport managers, this element of the recurrent training requirement may be met by an airport security briefing from the law enforcement agency with geographical responsibility for that airport, by meeting with other airport tenants to review airport/aircraft security issues that occurred at the airport over the past year, and reviewing the GA Airport Security Guidelines and security awareness topics posted on the TSA web page.

NAFI Note:
If an independent CFI ever feels the need for a basic review of the overall TSA security awareness program, the TSA Flight School Security Awareness Training program is available. It may be purchased from NAFI for ten dollars plus shipping.

The goal of the TSA security awareness recurrent training is to provide individuals with the latest available information pertinent to general aviation flight training.

It is important to note that TSA regulations require that each individual receiving initial or recurrent security awareness training receive documentation of the training. For recurrent training the documentation may be a memorandum, letter, or diploma stating that the CFI has received recurrent training in the specific areas listed above, signed by the appropriate person. For independent CFIs who receive a briefing from their airport manager or appropriate law enforcement official, that individual’s signature on the document is appropriate. The proof-of-training document must be maintained in the trained individual’s employee record; independent CFIs may keep it in their logbooks or other appropriate locations.

If you have any additional questions on security awareness recurrent training, please make contact with:

Monty Thompson
, TSA Security Awareness Training Manager, 571.227.2428, [email protected] or Rusty Sachs, Executive Director, National Association of Flight Instructors, 800.236.4800 ext. 6801, [email protected]