> ![](media/image1.png){width="0.4625in" height="0.4625in"}
>
> U.S. Department
>
> of Transportation
>
> **Federal Aviation**
>
> **Administration**

Mr. Gregory S. Winton, Esq.

334 Oak Knoll Drive

Rockville, MD 20850

RE: Request for Interpretation of FAA Order 8400.10 and Title 14 C.F.R.
§§ 135. 293 and 135.297

Dear Mr. Winton,

This is in response to your letter of May 11, 2006 requesting an
interpretation of FAA Order 8400.10 and §§ 135. 293 and 135.297 of the
Federal Aviation Regulations.

Specifically, you asked if recurrent training is administered in
modules, must the operator: 1) record each element of the module as it
is completed, 2) record each module as it is completed, or 3) make one
record when all of the modules are complete. You provide the following
example: in February 2005 a crewmember completes an initial training
program and the airman competency check required by § 135.293. One month
later, the airman attends an FAA approved aviation training center[^1]
and completes the recurrent training required by §§ 135.293 and 135.297.
Based on that scenario, you asked if the operator could make a single
record of the entire curriculum in March 2005, or is the operator
required to note when each individual element or each individual module
is completed?

**[Modular Approach to Recurrent Training]{.underline}**

As you stated in your letter, operators may administer the required
recurrent training in modules. When an operator adopts a modular
approach for recurrent training, all recurrent training elements and
events must be grouped into specific modules to be administered and
recorded as a recurrent training curriculum. The modules for Part 135
are composed of two parts. One part consists of the written or oral test
elements, and the other part consists of the flight training and
checking events. Because the ground and flight training elements are
distinct and separate parts, they may be completed at different times.
Nevertheless, they comprise a single module. An operator may record when
each module is complete or may record when all of the modules are
complete, but is not required to record when each element of a module is
complete.

**[Recurrent Training and Eligibility Period]{.underline}**

To answer your question, it is helpful to first explain recurrent
training and eligibility period. Recurrent training is the training
conducted for flight crewmembers who have been previously trained and
qualified by the operator, who are continuing to serve in the same duty
position and aircraft type, and who must receive recurring training
and/or checking within a specific eligibility period to maintain
currency. The eligibility period is a three-month period comprised of
the month before the month in which training is due, the month in which
training is due ("base month"), and the month after the month in which
training is due ("grace month"). Recurrent training or checking that is
completed any time during the eligibility period is considered to have
been completed during the base month. A crewmember who has not completed
all recurrent training or checking requirements in the base month may be
scheduled and continue to serve in revenue service during the remainder
of the eligibility period (*i.e.* until the end of the grace month), but
may not serve after the end of the grace month. A flight crewmember who
fails to complete all required training and qualification modules before
the end of the eligibility period must complete requalification training
before serving in revenue operations.

Recurrent training may occur periodically throughout the year, and the
operator must record the actual date that the training is completed.
However, for purposes of calculating when recurrent training is due
next, the base month does not change as long as the training is
completed before the end of the eligibility period. In the example
above, the pilot completed initial training in February 2005. Therefore,
the pilot's base month is February, and the pilot must complete
recurrent training no later than March 31, 2006 (*i.e.* 12 months plus
the grace month). The pilot must also complete the instrument
proficiency check required by § 135.297 no later than September 30, 2005
(*i.e.* six months plus the grace month). If the pilot undergoes
recurrent training in March *2005* after completing initial training in
February 2005, the operator has two options. The operator could change
the base month from February to March, and the pilot would be required
to complete recurrent training again no later than April 30, 2006
(*i.e.* 12 months plus the grace month). The operator must record the
actual date that the training is completed, but should designate March
as the base month for recurrent training. Alternatively, the operator
could keep February as the pilot's base month since initial training was
completed in that month. In that case, the pilot would be required to
complete recurrent training no later than March 31, 2006. Again, the
operator must record the actual date that the training was completed,
but would designate February as the base month for recurrent training.

Your second question involves whether an operator may adjust a
crewmember's base month by administering recurrent training before it is
due. As explained above, the answer to that question is yes. Operators
may "reset" the recurrent training clock at any time by giving recurrent
training earlier than it is required. The operator must ensure, however,
that all required recurrent training is completed within the 12 calendar
months preceding service in part 135 operations as required by the
regulations. For example, if a pilot completes initial training in
February 2005, the pilot would be due for recurrent training no later
than March 2006. However, the pilot could undergo recurrent in June 2005
and change the base month from February to June. In that case, recurrent
training would not be due again until July 31, 2006.

The same rules apply for the instrument proficiency check, except that
there is a six month look-back period as opposed to the 12 month
look-back period applicable to recurrent training. Therefore, the
operator and pilot must ensure that the instrument proficiency check has
occurred within the six months preceding service in IFR operations under
part 135.

This interpretation was prepared by the Operations Law Branch of the
Office of the Chief Counsel and coordinated with the Air Transportation
and Aircraft Dispatch Divisions of Flight Standards Service. We trust
that this response adequately addresses your request. Please contact
Joe Conte of my staff at the address provided above, or by phone at
(202) 267-3073, if we can be of further assistance.

Sincerely,

Rebecca MacPherson

[^1]: Attendance at an FAA approved aviation training center is
    permitted if the person conducting the training is authorized by the
    FAA. *See* 14 C.F.R. § 135.321(a)(1) (2006).