TSA Issues Optional Recurrent FSSA Training
March 2, 2006 — Mitigating somewhat the discomfort of the nation's flight training industry, the Transportation Security Administration this week made public its guidance for required recurrent Flight School Security Awareness (FSSA) training of flight instructors and flight school employees. This guidance, expected since October 2005, provides a way for those required to comply with 49 C.F.R. § 1552.23(d).
The TSA encourages flight-training operations to develop their own recurrent FSSA training or to use a program designed by a third party based on the new guidelines. The National Association of Flight Instructors (NAFI) is preparing such a training program, and plans to have it available for its members at the upcoming Sun 'n Fun Fly-In April 4-10.
NAFI Executive Director Rusty Sachs and EAA Vice President of Government Affairs Doug Macnair discussed the program with TSA officials on January 31, 2006. "We were uncomfortable with TSA's mandating that instructors do recurrent training within a year of their initial training, yet failing to state the elements required," Sachs explained. "Flight instructors fear TSA officials arriving at the airport to fault them for dereliction of duty, but they couldn't determine what their duty was."
Recurrent FSSA training is required for active flight and ground instructors (including independent CFIs) and flight school employees with direct student contact. Originally, they were to complete recurrent training each year within twelve months of their initial training.
But when the absence of direction from TSA made it impossible for flight school employees to comply with the 12-month recurrency requirement, NAFI, EAA, and other organizations successfully lobbied TSA for an exemption in December 2005 that extended the deadline to 18 months. The extension is valid only for the first recurrent training; in subsequent years the recurrent training must take place within twelve months of the previous year's training.
TSA guidance outlines a four-part program of recurrent training, which must include review and documentation of the following:
- Any new security measures or procedures implemented.
- Any security incidents at the flight school or airport, and any lessons learned as a result of such incidents.
- Any new threats posed by, or incidents involving, general aviation aircraft contained on the TSA Web site.
- Any new TSA guidelines or recommendations concerning the security of general aviation aircraft, airports, or flight schools.