The good news is that, based on feedback to AOPA from flight schools and instructors who have already been visited, these initial inspections are more educational than punitive in nature. Schools that already have been inspected suggest that you be polite, professional, and patient when TSA inspectors visit--and above all, show them what you're doing to comply with the rule.
While TSA has been responsible for airline passenger screening since shortly after the terrorist attacks of September 11, 2001, it's important to remember that its inspectors have only recently been tasked with visits to GA facilities. As a result, some inspectors may not be thoroughly familiar with the structure and operation of a flight school.
You should expect the TSA inspectors to ask about your documentation and recordkeeping of students, both U.S. citizens and aliens, in addition to completion of TSA security awareness training by active ground and flight instructors, as well as flight school employees. The initial training should have been completed by January 18, 2005, and if it hasn't, it should be completed as soon as possible; new employees and newly certificated instructors must complete the training within 60 days after they're hired or certificated.
AOPA has created a checklist to help flight schools and independent CFIs prepare for TSA inspections. An inspection should require a minimal amount of time; schools already inspected have indicated the inspections generally took an hour or less. Independent instructors can meet with TSA inspectors at their homes if they wish, or arrange to meet at another location. Keeping all required documentation in a secure but accessible location will facilitate the process. AOPA's TSA inspection checklist is available online.
Arlynn McMahon, vice president and training center manager at Aero-Tech, a flight school in Lexington, Kentucky, said she had worked to develop a professional relationship with a local TSA manager. "We are visible, and we work with a wide variety of people," she said. Because of international businesses and a major university, 5 to 10 percent of students at her school are foreign. "Having that personal relationship, it wasn't so scary when he called and said, 'I need to do an inspection.' "
The inspectors asked to see how the school was keeping records. "Suddenly we had this huge disconnect," she said. "They were expecting all of the flight instructors to have initialed all the passports I had on file. Somehow, this is the way somebody thought all the flight schools were doing this."
Although her procedures differed from what the inspectors seemed to expect, she said they were very receptive to her methodology. "When I showed them what we were doing, they were very happy. They were mostly interested in the fact that I was checking citizenship, making copies of citizenship information, and checking the [TSA] Web site [to verify the status of] noncitizens.
"It seemed to open their eyes that there was another way to do this," she added.
Nevertheless, McMahon said the experience might have felt intimidating if she didn't already have a professional relationship with one of the inspectors.
And the inspection did turn up one problem with Aero-Tech's system--the school had been keeping copies of alien students' passports as a photo ID, but the regulations require that a copy of the photo sent to TSA be kept. "When we found this, we discussed it, and he said, 'Let's make this very clear that we're going to do this [going forward].' I agreed." That ended the discussion.
McMahon offers some advice for schools:
- Be proactive and assertive in explaining your procedures. Inspectors may arrive with a preconceived expectation, but they are receptive to sound procedures that achieve TSA's objectives.
- Keep copies of your correspondence, even if you never get a response to a question from TSA. "You need to be able to show that you've tried to do a good job," she explained.
"The inspection was nothing to be feared," McMahon said. "I think that if a flight school wasn't making an effort to do these things, the experience wouldn't be as good."
Gary Warden of Fort Stockton, Texas, an independent flight instructor who works part-time from Fort Stockton Aviation, was contacted twice by TSA. "They made one trip here and then they called me about a month later as a follow-up," he said.
During the initial visit, a TSA inspector talked with Warden and gave him some flyers. Warden explained that he administers some flight reviews and IPCs, but isn't accepting new students and considered himself inactive. (TSA considers instructors giving any type of instruction, including flight reviews, to be active for the purpose of requiring security awareness training.)
About a month later, he received a follow-up phone call to ensure he'd had no new student starts. He was reminded what he would have to do if his situation changes. "Of course I have to follow the procedure when I have a new student, and it's reasonable and understandable. We have a few alien student pilots down here because of our proximity to the Mexican border--maybe that's why we got some extra attention."
Unfortunately, after 37 years as a pilot and more than 28 years as an instructor, the additional regulation on the flight-training industry has him considering his future. "I have several students who want to start, but I've been putting them off--I don't know what I'm going to do," said Warden, who has owned two flight schools and served as a designated examiner. "It's just not fun any more."
He offered some simple advice to any instructor or flight school visited by the TSA. "My advice would be to be courteous, answer their questions, and don't offer them anything they don't ask about," he said. "Sometimes we talk ourselves into trouble."
AOPA appreciates any comments regarding your experiences with TSA inspections; please call AOPA's Pilot Information Center at 800/USA-AOPA.
Mike Collins is editor of AOPA Flight Training magazine.
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