Are airport operators responsible for training individuals that perform duties in movement or safety areas but are not airport employees, such as FAA employees or construction employees?
Yes. The type of training required depends on whether such employees are performing duties necessary to comply with the Airport Certification Manual (ACM) or Part 139. Part 139.303(c) training requirements do not apply to employees whose duties require that they be in movement or safety areas but are not required under Part 139. Most likely a FAA employee in the movement or safety area is performing maintenance on FAA-owned navigation equipment; and maintenance of FAA-owned equipment is typically not addressed in the ACM and not required under Part 139. Similarly, construction work in movement and safety areas is not required under Part 139 per se, but the rule does require the airport operator to develop and implement safety procedures for construction. Thus, workers performing construction duties would not require training under Part 139.303(c), but airport operations personnel would require training under this section if they are responsible under the ACM to ensure that construction
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