Part 135 Crew Training Records Software: What to Look For

14 CFR 135.293: the knowledge test and the competency check

No pilot serves in Part 135 operations unless, since the beginning of the 12th calendar month before that service, the pilot has passed a written or oral knowledge test (135.293(a)) and a competency check (135.293(b)). The competency check is given in the class of aircraft for a single-engine airplane other than a turbojet, and in the type for a helicopter, a multiengine airplane, a turbojet airplane or a powered-lift.

The FAA or an authorized check pilot certifies the competency of each pilot who passes in the certificate holder's pilot records (135.293(f)). An instrument proficiency check under 135.297 may be substituted for the competency check for the type of aircraft used in the check (135.293(d)); the substitution reaches the competency check only, and the knowledge test stands on its own.

What the software has to hold: two dates per pilot, the test and the check, with the check kept per aircraft type or class and the check pilot who certified each.

14 CFR 135.297: the instrument proficiency check

A pilot in command under IFR needs an instrument proficiency check passed since the beginning of the 6th calendar month before that service (135.297(a)), given by an authorized check pilot or the FAA (135.297(c)(2)).

A pilot assigned to more than one type takes the check in each type in rotation, but not more than one flight check in each period (135.297(e)). A pilot assigned to both single-engine and multiengine aircraft takes the first check in a multiengine aircraft and alternates after that (135.297(f)).

What the software has to hold: a six-month clock beside the twelve-month ones, and the type flown on each check, because the rotation is read from it.

14 CFR 135.299: the line check

A pilot in command needs a line check passed since the beginning of the 12th calendar month before that service, in one of the types the pilot is to fly (135.299(a)). An approved check pilot or the FAA gives it over at least one route segment, with takeoffs and landings at one or more representative airports; for a pilot authorized to conduct IFR operations, at least one flight is flown over a civil airway, an approved off-airway route or a portion of either.

The check pilot certifies the result in the pilot training record (135.299(b)).

14 CFR 135.343 and 135.351: recurrent training

A crewmember serves only after completing the appropriate initial or recurrent training phase since the beginning of the 12th calendar month before that service (135.343). The section does not apply to a certificate holder that uses only one pilot.

Recurrent ground training includes a quiz or other review of the aircraft and crewmember position, and instruction as needed in the initial ground training subjects, among them crew resource management and emergency training (135.351(b)). Recurrent flight training covers the maneuvers and procedures of the subpart, and a 135.293 check passed within the preceding 12 calendar months may be substituted for it (135.351(c)).

One substitution at a time: FAA Notice N 8900.685 says the FAA does not allow a double substitution, so one instrument proficiency check cannot satisfy both 135.293 and 135.351.

What the software has to hold: each event credited to the requirement it satisfies, so one check ride never quietly answers three rules.

14 CFR 135.301(a) and 135.323(b): base month and grace month

A test or flight check completed in the calendar month before or after the month in which it is required is considered completed in the month it is required (135.301(a)). Recurrent training completed in the month before or the month after counts the same way (135.323(b)).

The month a check or training falls due is its base month. A 2006 interpretation by the FAA's Office of the Chief Counsel calls the base month, the month before it and the month after it (the grace month) the eligibility period. Work completed anywhere in those three months counts as done in the base month, so the base month does not move; an operator may also reset the base month by giving the training earlier than it is due.

The same interpretation reads the grace month as service time: a crewmember who has not completed recurrent training or checking in the base month may continue to serve until the end of the grace month, and not after it.

What the software has to hold: the base month as a field of its own, beside the date passed. A system that adds twelve months to the date passed slides a month later every time a check lands in a grace month.

14 CFR 135.323(c) and 135.63(a)(4): the record and who certified it

Each instructor, supervisor or check pilot responsible for a ground training subject, a segment of flight training, a course of training, a flight check or a competence check certifies the crewmember's proficiency and knowledge on completion, and the certification becomes part of the crewmember's record. In a computerized recordkeeping system the certifier must be identified with the entry, and a signature is not required (135.323(c)).

The pilot record holds the date and result of each initial and recurrent competency test and proficiency and route check, with the type of aircraft flown (135.63(a)(4)(vi)), the check pilot authorization, if any (135.63(a)(4)(viii)), and the completion date of the initial phase and each recurrent phase of training (135.63(a)(4)(x)). Each pilot record is kept for at least 12 months (135.63(b)).

The check pilot has a record too: completion of the training and checks the role requires is entered in the check pilot's own training record (135.337(c)), and a check pilot serves only after conducting a proficiency or competency check under the observation of an FAA inspector or an aircrew designated examiner within the preceding 24 calendar months (135.339(a)(2)). Part 135 check pilot and flight instructor records covers that file.

What to ask any crew training records software

1. Does it count calendar months from the first day of the month, the way 135.293, 135.297, 135.299 and 135.343 count, or does it add days to a date?
2. Does it keep a base month for each check and each training cycle, and credit work done in the month before or after to that month?
3. When one check ride is both the instrument proficiency check and the competency check, does it credit each to its own base month, and decline to count the same ride as recurrent flight training?
4. Does each entry name the instructor or check pilot who certified it, and was that check pilot authorized for the type on the day of the check?
5. Does a date it cannot read show as unknown, or as a guess?
6. When the POI asks for a pilot's record, can it hand over the dates with the documents behind them?

How FileFlo answers them. The 135.293 competency check, the 135.297 instrument proficiency check, the 135.299 line check and 135.351 recurrent training are dated in calendar months with base-month crediting. A check in the grace month is never shown as cleared: FileFlo says it cannot establish readiness until a qualified reviewer settles the reading. A competency check is validated against your fleet types and your check pilot roster, and a self-signed or out-of-fleet check is refused as invalid. A check whose check pilot signature is not detected is held as a review item that names the fix. A date FileFlo cannot read is refused as unknown, not guessed. The POI gets an inspector link scoped to one crew, showing each pilot's standing and the standing of each document behind it.

For the wider field, Part 135 compliance software compared covers manuals, OpSpecs and recordkeeping beside the crew record, Part 135 operations and recordkeeping software the flight records, and CAMP and Veryon alternatives the maintenance side. An operator moving its training records off an airline suite can start with Comply365 alternatives for Part 135 operators.