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13 Answers

Logging Instructor Time While Conducting Company Required Training

Asked by: 8686 views Flight Instructor

I hold an ATP, CFII, and an L-382 type rating. I work for a company that flies civilian C-130s (the L-382) under FAR Part 91 and 137.

Generally, new hire pilots come to us with military experience and a type rating, but don't have FAR 137 endorsements and often also need airdrop familiarization and training as well.

The company has training syllabi for these mission areas. When I'm flying with these pilots (who are already typed and current in the airplane) and executing the company's training syllabus, can I legally log instructor/dual given time?

13 Answers



  1. Sam Dawson on Jun 02, 2014

    Well, with your straight CFII (if that is what you really have), you can no longer act as an instructor under any circumstances using that instructor certificate, so you can’t log instructor time using that certificate.

    So the question becomes can you legally log instructor/dual using your ATP. I’m not sure you are legal to give the instruction you describe much less log it based upon the regulation and legal interpretations which state the instruction must be part of an approved air carrier program or part 121/135; no mention of 137. Definitely not under part 91.
    “61.3
    (3) A flight instructor certificate issued under this part is not necessary–
    …
    (ii) Under paragraph (d)(2) of this section, if the training is given by the holder of an airline transport pilot certificate with a rating appropriate to the aircraft in which the training is given, provided the training is given in accordance with the privileges of the certificate and conducted in accordance with an approved air carrier training program approved under part 121 or part 135 of this chapter;”

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/creech%20-%20(2010)%20legal%20interpretation.pdf

    Now having written all of this while I know what part 137 operations are, I am not really familiar with them. There may be exceptions that permit you to do this training, but I would want to see it in writing. Granted, the pilots you are training are typed in the airplane so maybe there is an out there… but I am not 100% sure.
    I would discuss this with your POI and make sure your duck are in a row. Don’t assume that since your company asked you to do this you are legal to do this.

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  2. Kris Kortokrax on Jun 02, 2014

    Interestingly enough, neither 61.51 nor 61.189 address the logging of time spent giving training. They only deal with training received. 61.51 does allow you to log PIC time while acting as an authorized instructor. I would say that since the regs don’t address training given, you could log it.

    Additionally, the endorsement must be given by the Certificate Holder or a person designated as the supervisor for the operation (or an FAA inspector). If the skills test is not conducted by an FAA inspector, then it is only good for the operator who conducted the test.

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  3. Sam Dawson on Jun 02, 2014

    But can he even give the training using his ATP under part 137? He can’t under part 91.

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  4. Kris Kortokrax on Jun 02, 2014

    Sam, I must have been typing at the same time as you.
    I think that even though he typed CFII, he has a CFI certificate with Airplane Multiengine and Instrument Airplane, if he received it on the basis of having been a military instructor. The C-130 is not a center-thrust only airplane.

    As far as needing a Flight Instructor certificate, I would say that in order to give any training required by the regulations (which would include a statement such as “given by an authorized instructor”), one would need a Flight Instructor certificate.

    If training is not required by the regulations, (such as aerobatics), one could give that training without a flight instructor certificate.

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  5. Sam Dawson on Jun 02, 2014

    You might be correct, but I did not read where he came as a military IP. Not sure if the training falls under non-required, or if under their 137 certificate it is required training. Again, I am not familiar enough with 137 to know what is required to give the training.

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  6. HAmmer01 on Jun 02, 2014

    Guys,

    Thanks for taking the time to help out. Haven’t been out of the military for long, and the learning curve in the civilian world is steep.

    Sam, sorry for the confusion my incorrect terminology caused. I was indeed a military IP, I took the equivalency test and now hold a “Flight instructor, airplane multiengine; instrument airplane” certificate, in addition to my ATP.

    I know I can’t instruct on the basis of my ATP, as we are not a 121 operation, nor do we have a formal training department or a formal training program.

    For FAR 137 operations, FAR 137.41© lays out some skills and knowledge that must be demonstrated to a company representative, and our CP is a DE who does this for us and issues the endorsement. I see no requirement that our CP must provide that training, or prohibition against any other CFI who holds the endorsement from doing it.

    For FAR 91.15 operations, I could find no skill/training requirements at all. Far as I can tell, one can just go out and drop anything from an airplane as long as all 91.15 rules are followed. Of course, military-style airdropping or personnel and equipment takes a lot more training, which someone has to provide.

    Kris, you highlight what I was finding, and what drove me to ask the question. FARs do talk about when to log dual received, but not instruction given. It almost seems that in order to log IP time, one must be providing training leading to a certificate of some sort, leading to recurrency, or leading to a type rating. And none of that is spelled out specifically. In the Air Force, there is no such thing as “Student time” or “dual received” after one has gotten their wings. And the AF regs are very detailed on when an IP can log instructor time.

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  7. Sam Dawson on Jun 02, 2014

    Got it. Then yes, you can log the instructor time. The FAA really gives you a bit of leeway on what constitutes “instruction”. The one caveat is that the instruction must be recorded and logged. In your case I’m sure your company uses training records and these suffice as the FAA again gives you leeway in this. In one legal case they even told the defendants they would have accepted paper napkins with proof of instruction.

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  8. Kris Kortokrax on Jun 02, 2014

    There are several circumstances where one could be providing training (not for a certificate or rating).

    Training for endorsements.
    Training in an aircraft that a pilot has not flown before (if no type rating required, think insurance requirements).
    Aerobatic training.
    Formation training.
    Training to tow gliders.
    Training to pilot a parachute jump plane.
    Training for commercial missions such as photo flights, pipeline/powerline patrol.
    Training for a 137 operation (No training program is required nor is any training required in the regulation).

    None of these would require a Flight Instructor certificate, although the Law of Primacy would still apply. If one is taught incorrectly in the beginning, it will take longer to correct things later.

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  9. Sam Dawson on Jun 02, 2014

    I’m not sure which endorsements you mean, but the ones covered by 61.31 specifically state “authorized instructor”.

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  10. Kris Kortokrax on Jun 02, 2014

    You’re right about endorsements for the most part. I was multi-tasking and thinking about his comments concerning training towards a certificate or rating and that endorsements would fit that definition.

    I could find a scenario in which one could provide endorsements without a CFI. If I were to be employed by a Part 142 training center, I could instruct towards the issuance of a certificate, rating or endorsement without a Flight Instructor certificate as long as I didn’t instruct in an aircraft and met the requirements of 142.47 (in which case I would be an authorized instructor).

    There are also persons who hold a certificate titled “Authorized Instructor”. These are issued primarily for those who instruct in Experimental Exhibition aircraft such as L-39, Corsair, etc. and do not hold a Flight Instructor certificate. It is the equivalent of the old LOOA. They are “authorized instructors” and may provide training for certification, ratings and endorsements.

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  11. Sam Dawson on Jun 02, 2014

    I understand and it makes sense.

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  12. HAmmer01 on Jun 02, 2014

    Thanks again guys for taking the time to help me understand.

    If I may summarize, based on all your inputs:

    Anytime I’m instructing/training someone in any company “mission area” (airdrop, airland, low-level ops, aerial spray ops, etc.) inflight, I can log instructor time–as long as that instruction is somehow documented. Documentation can consist of any written record, even outside of a logbook record.

    Does that sound about right?

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  13. Sam Dawson on Jun 02, 2014

    Yes.
    FAR 61.1 Applicability and Definitions
    “Flight training means that training, other than ground training, received from an authorized instructor in flight in an aircraft.
    …
    Training time means training received—

    (i) In flight from an authorized instructor;

    (ii) On the ground from an authorized instructor; or

    (iii) In a flight simulator or flight training device from an authorized instructor.”

    FAR 61.189 Flight Instructor Records

    “(a) A flight instructor must sign the logbook of each person to whom that instructor has given flight training or ground training.”

    The FAA has never really defined what a “logbook” and while most think of the traditional logbook really any means is pretty much acceptable including the company records.

    61.51 Pilot logbooks.
    “(a) Training time and aeronautical experience. Each person must document and record the following time in a manner acceptable to the Administrator:

    (1) Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.

    (2) The aeronautical experience required for meeting the recent flight experience requirements of this part.”

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