The FAA has published new guidance explaining operator options for crafting Initial New Hire (INH) training programs for pilots who may have previous aircraft and/or air carrier experience.
In late 2011, the FAA published a draft notice on this issue and accepted industry comments. The final version of the guidance, Notice 8900.197, will require inspectors to ensure that no Part 135 training programs contain provisions allowing for issuance of credit for prior training or evaluations. Inspectors are required to conduct a review of training programs under their supervision within 90 days and notify operators of any changes that must be made to conform to the guidance. Operators will then have to submit training program revisions to their inspector for approval within twelve calendar months.
As suggested in the draft version, the final guidance does allow for operators to craft multiple curricula for training that take into consideration the pilot's prior experience and provides for a reduced number of training hours.
The FAA provides examples of the types of reduced training hour programs that an operator could develop, including:
• Pilots that have previous experience in Part 135 operations in the same aircraft and flightcrew member duty position
• Pilots that have previous experience in Part 135 operations in the same aircraft, but in a different flightcrew member duty position
• Pilots that have previous experience in Part 135 operations in a different aircraft; or
• Pilots that have previous experience in 14 CFR Part 91, subpart K (Part 91K) operations.
For nearly two years, the requirements for training newly hired pilots who have prior experience have been unclear as some FAA inspectors were requiring a full INH program, even for those pilots who are current and qualified on the aircraft and have current Part 135 experience. In contrast, many operators were previously permitted to provide some sort of "credit" to experienced pilots.