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AOPA's Flight School Checklist for Transportation Security Administration (TSA) Inspections

On September 21, 2004, the Transportation Security Administration (TSA) issued an interim final rule on flight training for non-U.S. citizens, non-U.S. nationals, and other designated individuals. As a result of this rule, TSA inspectors have been tasked with inspecting flight schools and instructors for compliance. For guidance on this rule, contact AOPA's Pilot Information Center at 800/USA-AOPA or visit AOPA's Web site.

AOPA created this checklist to help flight schools and independent instructors prepare for TSA inspections.

TSA inspectors have had responsibility for larger airports and recently have been tasked with visits to GA facilities. AOPA recommends that TSA inspectors be received with professionalism, courtesy, and patience.

TSA includes in its definition of "flight school" flight training centers and independent instructors certificated under parts 61, 141, and 142 that provide training in an aircraft or flight simulators.

1. Security Awareness Training

Active instructors and flight school employees who have direct contact with flight students must complete annual security awareness training.

Initial Security Awareness Training

Each flight school employee or independent instructor should have completed initial training by January 18, 2005.
New employees or instructors must complete the initial training within 60 days of being hired or certificated.

Recurrent Security Awareness Training

Each flight school employee or independent instructor must receive recurrent security awareness training every 12 months from the month of their initial training. A TSA exemption grants first-time recurrent training recipients an additional six months to complete this training. This exemption will remain in effect until January 1, 2007.

More information on recurrent security awareness training and the exemption can be found online.

Documentation of Security Awareness Training

(We recommend that you keep all required documentation in a secure and accessible location.) Flight schools must issue a document to each flight school employee when initial or recurrent security awareness training is received. It must include:

The flight school employee's name and a distinct identification number. (The flight school should develop its own numbering system. We recommend using the same ID number on the initial and recurrent training documents.)
The date on which the security awareness training was received.
The name of the instructor who conducted the training, if any. (Independent instructors who have conducted this training on their own may list their own name.)
A statement certifying that the flight school employee or independent instructor received the security awareness training.
The type of training received (initial or recurrent).
If the flight school uses an alternative training program, the document must contain a statement certifying that the alternative training program used by the flight school meets the requirements of 1552.23(c).
The flight school employee or instructor and an authorized official of the flight school must sign the document.
Check your initial security awareness training completion certificate to be sure it also includes the items above.

Flight School Recordkeeping Requirements

Flight schools must keep a copy of the security awareness training document(s) for one year after an individual is no longer a flight school employee.

2. Documentation Requirements for U.S. Citizens

Flight schools or instructors have two options for recording their documentation of U.S. citizens to whom they have provided flight training. Note: These also apply to U.S. citizens who are receiving training outside the United States for a U.S. airman certificate:

Keep for five years a copy of the documents that are used to prove citizenship. Evidence of U.S. citizenship must be shown by one of the following:
  • Valid, unexpired U.S. passport.
  • Original birth certificate of the United States, American Samoa, or Swains Island and government-issued picture ID.
  • Original certification of birth abroad with raised seal (Form FS-545 or DS-1350) and government-issued picture ID.
  • Original certificate of U.S. citizenship with raised seal (Form N-560 or N-561), or a Certificate of Repatriation (Form N-581), and government-issued picture ID.
  • Original U.S. Naturalization Certificate with raised seal (Form N-550 or N-570) and a government-issued picture ID.

Make an endorsement in both the instructor's logbook, or other record used by the instructor to record flight student endorsements, and the student's logbook with the following:

"I certify that [insert student's name] has presented me a [insert type of document presented, such as a U.S. birth certificate or U.S. passport, and the relevant control or sequential number on the document, if any] establishing that [he or she] is a U.S. citizen or national in accordance with 49 CFR 1552.3(h). [Insert date and instructor's signature and CFI number.]" Click here for the TSA letter explaining this logbook endorsement.


3. Documentation Requirements for Non-U.S. citizens and Non-U.S. nationals

TSA defines a non-U.S. citizen and non-U.S. national as any person who is not a citizen or national of the United States. This definition includes resident non-U.S. citizen (green-card holders) and visa holders in the United States. These requirements also apply to non-U.S. citizens and non-U.S. nationals receiving training outside the United States for a U.S. airman certificate.

Non-U.S. citizen or non-U.S. national candidate — Flight school and candidate registration
Flight school has registered with TSA for training Non-U.S. citizen or non-U.S. national candidates.
Non-U.S. citizen or non-U.S. national candidate has registered with TSA to receive flight training.

Non-U.S. citizen or non-U.S. national candidates— Flight school record keeping requirements

Flight schools and instructors that provide flight training to non-U.S. citizen or non-U.S. national candidates must keep certain records for five years, including:

The photograph of the candidate (same photograph sent to TSA).
A copy of the approval sent by the TSA confirming the candidate's eligibility for flight training. (Both the candidate and the flight training provider will receive an e-mail with the subject "Permission to Initiate Training/Fingerprint Receipt" when all of the required information has been received and verified by TSA.)
Candidate's full name, gender, and date of birth.
Candidate's ID number created by the TSA.
Copy of candidate's valid, unexpired passport and visa.
Copy of all previous passports and visas held by the candidate and all the information necessary to obtain a passport and visa.
Candidate's country of birth, current country or countries of citizenship, and each previous country of citizenship, if any.
Candidate's requested dates, type, and location of training.
Candidate's current U.S. pilot certificate and certificate number (if any).
Candidate's current address and phone number and each address for the previous five years.
Copy of receipt confirming that the $130 was paid (printable from TSA Web site after candidate makes payment).
For DoD endorsees, a copy of the required written statement and picture ID.

Visit AOPA's Web site for a step-by-step registration process for both flight schools and non-U.S. citizen or non-U.S. national candidates.

AOPA's Pilot Information Center at 800/872-2672 is interested in receiving any comments regarding your experiences with TSA inspections at your flight school.

Posted Thursday, February 16, 2006 11:24:11 AM