Can an airport operator allow tenants to conduct some of the recurrent training now required under the revised Part 139, and if so, what type of audits, checks, or verification will be required?
Yes. An airport operator can train and authorize a tenant to conduct initial or recurrent training. Part 139.303(f) allows the airport operator to use a designee to comply with the requirements of Part 139 so long as this arrangement is FAA-approved and certain records are maintained. Such an arrangement has to be documented in the Airport Certification Manual (ACM), including procedures for keeping training records and the frequency such records will be submitted to the airport operator. For example, an airport operator could train several air carrier employees to be trainers for ground vehicle operation training and require the air carriers to submit monthly training records. While Part 139.303(f) does not require audits of training records in such arrangements, it does require the designee performing the training to prepare ‘records in sufficient detail as to assure the certificate holder and the FAA of adequate compliance with the ACM and Part 139.’ How this verification is accompl
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