FAR 61.189 Flight Instructor Records

Erice

Erice

Pre-takeoff checklist
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Erice
I understand parts (a) and (b). But how should CFIs handle part (c) of this reg?

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.


(b) A flight instructor must maintain a record in a logbook or a separate document that contains the following:
(1) The name of each person whose logbook or student pilot certificate that instructor has endorsed for solo flight privileges, and the date of the endorsement; and
(2) The name of each person that instructor has endorsed for a knowledge test or practical test, and the record shall also indicate the kind of test, the date, and the results.


(c) Each flight instructor must retain the records required by this section for at least 3 years.
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Which records must be kept for 3 years: only the endorsements? Or a record of the normal training flights (and ground training)? Can these be kept in the CFI’s logbook? I have never asked to see my CFI’s logbook, but I am curious now as to what is recorded there.


Wouldn’t the FBO (or flight school) want to keep a record of these things too, since many CFIs don’t stay in one place for the three year term of this reg? If the CFI wrote it only in his/her logbook, would the flight school be on the hook if for some reason a FSDO wanted to look back for three years at the training records?


I see that ASA and Jeppesen make flight training folders to keep track of this sort of information (for example, http://www.aircraftspruce.com/catalog/pspages/asa_frprivate.php). Do any of you CFIs use these? Are they overkill? Or a good idea?
 
You need to keep a record of the endorsements you give in part (b) for three years according to part (c).

You are required to sign the trainee's logbook (or other record) if you give instruction.

What I've seen done at schools is that the instructor keeps a record of the endorsements (in his own logbook), and the flight school keeps a copy too in the student's folder.

So my logbook may have an entry that says:
5/31/2012. 1.5 hours total, 1.2 hours flight training given for Erice. Endorsed for solo flight in PA-28-161 aircraft this date.
And your folder will have a copy of the endorsed student pilot certificate and probably the other solo-related endorsements.
 
So flight schools DO keep a student folder? What all goes in the folder? Probably a copy of the medical? Pilot certificate? Proof of citizenship? Photo ID? Anything else?

Do free-lance CFIs need to keep the same stuff? I would think so.
 
Typical stuff in a student folder:
Rental agreement
Financial Stuff
TSA paperwork (or copy of passport/whatever showing TSA requirements met)
Checkout sheets for airplanes
pre-solo written (often the same as the rental checkout "quiz")
copies of endorsements.

Free-lance CFIs need to keep the records specified by the FAA and TSA, and it generally works out to the same stuff.
 
And that's just the beginning. TSA has additional requirements for instructors.
 
Erice said:
So flight schools DO keep a student folder? What all goes in the folder? Probably a copy of the medical? Pilot certificate? Proof of citizenship? Photo ID? Anything else?

Do free-lance CFIs need to keep the same stuff? I would think so.
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Some do and some don't. I take copies of everything.
 
I collect and retain what the law requires and nothing more. The last thing I want to be responsible for is a bunch of someone's personal information that I could lose.
 
Bear in mind that like lots of FARs, this one also deals with the bare minimum for record-keeping to meet FAA requirements. It does not deal with the requirements of other regulatory bodies (federal, state or local) nor establish the best business practices for CFIs.
 
After my checkride endorsement, my CFI asked for me to scan and email him last few pages of the logbook, and front page of my passport. Other than that, nothing.
 
I had my annual TSA audit about a month ago. The inspector said that they are going to widen their net in the near future, going after independent CFIs who have been flying under the radar for years. He said they had new access to FAA records that would allow them to find more CFIs.

So, be forewarned. Keep a photocopy of the driver's license and passport/birth certificate for every US citizen you train for a rating. (And you must get these BEFORE you begin their training.) You have to keep these records for a minimum of 5 years and they do check. Also, make sure to keep your own "security" training current.

Oh, one new thing we saw this year - the inspectors are now going through CFI logbooks looking at the training entries to ensure that no one is in there that doesn't match your records. Now the way around that is not to log the names of who you train, but endorsements will still give it away.
 
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write-stuff said:
I had my annual TSA audit about a month ago. The inspector said that they are going to widen their net in the near future, going after independent CFIs who have been flying under the radar for years. He said they had new access to FAA records that would allow them to find more CFIs.

So, be forewarned. Keep a photocopy of the driver's license and passport/birth certificate for every US citizen you train for a rating. (And you must get these BEFORE you begin their training.) You have to keep these records for a minimum of 5 years and they do check. Also, make sure to keep your own "security" training current.

Oh, one new thing we saw this year - the inspectors are now going through CFI logbooks looking at the training entries to ensure that no one is in there that doesn't match your records. Now the way around that is not to log the names of who you train, but endorsements will still give it away.
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First off absolutely nothing requires you photocopy their drivers license or passport/birth certificate. I refuse to do so for privacy concerns.

One can simply endorse in their logbook:
"I certify that [insert student's name] has presented me a [insert type of document presented, such as a U.S. birth certificate or U.S. passport, and the relevant control or sequential number on the document, if any] establishing that [he or she] is a U.S. citizen or national in accordance with 49 CFR 1552.3(h). [Insert date and instructor's signature and CFI number.]"
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I place that endorsement in both my flight instruction records (different logbook) and the students logbook.

Introductory or demo flight do not require the endorsement.

The endorsements are ONLY required if providing flight training which the TSA has defined as:
"for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less to only apply to training for a recreational pilot, sport pilot, or private pilot certificate; multiengine rating (at any certificate level — i.e., does not apply to MEI); or instrument rating (does not include recurrent training)"

So this means that citizenship validation IS NOT required for flight reviews, checkouts, or instrument proficiency checks.

When I get a new student that this applies to I:

  • Endorse their logbooks with above endorsements
  • Endorse my logbooks with above endorsements
  • Fill out student information sheet with contact info, emergency contact, etc that I keep for my own record which carries the endorsement as well
The whole program is insanely ridiculous with oodles of false information floating around. Such a waste of taxpayer money.
 
jesse said:
First off absolutely nothing requires you photocopy their drivers license or passport/birth certificate. I refuse to do so for privacy concerns.

One can simply endorse in their logbook:
I place that endorsement in both my flight instruction records (different logbook) and the students logbook.

Introductory or demo flight do not require the endorsement.

The endorsements are ONLY required if providing flight training which the TSA has defined as:
"for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less to only apply to training for a recreational pilot, sport pilot, or private pilot certificate; multiengine rating (at any certificate level — i.e., does not apply to MEI); or instrument rating (does not include recurrent training)"

So this means that citizenship validation IS NOT required for flight reviews, checkouts, or instrument proficiency checks.

When I get a new student that this applies to I:

  • Endorse their logbooks with above endorsements
  • Endorse my logbooks with above endorsements
  • Fill out student information sheet with contact info, emergency contact, etc that I keep for my own record which carries the endorsement as well
The whole program is insanely ridiculous with oodles of false information floating around. Such a waste of taxpayer money.
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Jesse,

Hate to break this, but I got raked over by two TSA agents last week, and trust me, you DO need to see a passport or birth cert. and photo ID if you so much as let the student take the controls on an introductory or demo flight according to the guys I had the great pleasure of working with. :dunno: They pointed to that "demonstration flight for marketing purposes" thing that most instructors point to and let me know in no uncertain terms that if you so much as let them take the controls and tell them how to hold the pitch and keep the wings level, that you have "provided" "flight training" instead of just a "demonstration" - and anyway, that demonstration flight is also defined as related to an aircraft purchase rather than training.
The other problem I see is, I guess any instructor just holding a 3rd class medical can't legally do a demo flight under TSA rules without a 2nd class medical since this effectively puts all demo flight people as passengers rather than students. I will not do a discovery flight without seeing a passport or birth cert. / photo id. They threatened an $11,000 fine if they checked and found a disc. flt that counted as "flight training" without proper docs.
The thing that really makes me mad about this as well is that I don't see how it really does a lick of good to prevent a serious terrorist from still doing something. I could have a nephew that doesn't have a birth cert. or passport, KNOW that he is an American Citizen, and be forced by this code to not allow him flight training. That to me is a violation of his rights. On the other hand, some enterprising terrorist could give me a 100% genuine looking birth cert, and I'd have NO way of proving otherwise.

Ryan
 
this reminder is just making me more and more happy that i basically exclusively do glider instruction now days.
 
RyanShort1 said:
Jesse,

Hate to break this, but I got raked over by two TSA agents last week, and trust me, you DO need to see a passport or birth cert. and photo ID if you so much as let the student take the controls on an introductory or demo flight according to the guys I had the great pleasure of working with. :dunno: They pointed to that "demonstration flight for marketing purposes" thing that most instructors point to and let me know in no uncertain terms that if you so much as let them take the controls and tell them how to hold the pitch and keep the wings level, that you have "provided" "flight training" instead of just a "demonstration" - and anyway, that demonstration flight is also defined as related to an aircraft purchase rather than training.
The other problem I see is, I guess any instructor just holding a 3rd class medical can't legally do a demo flight under TSA rules without a 2nd class medical since this effectively puts all demo flight people as passengers rather than students. I will not do a discovery flight without seeing a passport or birth cert. / photo id. They threatened an $11,000 fine if they checked and found a disc. flt that counted as "flight training" without proper docs.
The thing that really makes me mad about this as well is that I don't see how it really does a lick of good to prevent a serious terrorist from still doing something. I could have a nephew that doesn't have a birth cert. or passport, KNOW that he is an American Citizen, and be forced by this code to not allow him flight training. That to me is a violation of his rights. On the other hand, some enterprising terrorist could give me a 100% genuine looking birth cert, and I'd have NO way of proving otherwise.

Ryan
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That's interesting, and in direct opposition to what the TSA guys here in the metro DC area say. Suggest you forward this to AOPA, preferably with the names of the TSA folks who told you this. If they gave you their card, ask them the question in email and get the reply in writing.

Off the top of my head, TSA clearance and/or citizenship checking is required before a student begins a "course of instruction" that leads to significantly new privileges. That's why a private, or an instrument, or a multi-engine certificate require the check, but an commercial certificate does not (as I recall), nor does a flight review, a tailwheel endorsement, or other stuff.

Edit: got the instrument and commercial backwards. Commercial doesn't really add capabilities the way the instrument does.
 
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All I have to say is that a LOT of flight instructors are probably mis-informed, and need to read and re-read 14 CFR 1552 a LOT more carefully - and before they get a visit from their friendly local TSA agent. There were two of 'em, and they showed badges before getting down to business. I think I have all of my bases satisfactorily covered at this point, but I got a bit worried because they wanted to see stuff NOW and I had to go home and find everything, and I was at a very busy time in my life (still am) which made it extremely inconvenient.
Oh, it also so happens that I did do my annual "Security Awareness Training" - and had printed out the copies of it, but I didn't have them with me, and had to dig them up out of some boxes (I'm looking at a move in the near future). They wanted to see a copy of my initial and current SAT training certs. I am fairly confident that there are several CFI's that will be in huge trouble if and when the TSA catches up with them, which is sad, because on a personal level, they are great instructors and good people, and I doubt they've ever had contact with a "terrorist."
I still don't see how any of this stops one single terrorist.

Ryan
 
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RyanShort1 said:
Jesse,

Hate to break this, but I got raked over by two TSA agents last week, and trust me, you DO need to see a passport or birth cert. and photo ID if you so much as let the student take the controls on an introductory or demo flight according to the guys I had the great pleasure of working with. :dunno: They pointed to that "demonstration flight for marketing purposes" thing that most instructors point to and let me know in no uncertain terms that if you so much as let them take the controls and tell them how to hold the pitch and keep the wings level, that you have "provided" "flight training" instead of just a "demonstration" - and anyway, that demonstration flight is also defined as related to an aircraft purchase rather than training.
The other problem I see is, I guess any instructor just holding a 3rd class medical can't legally do a demo flight under TSA rules without a 2nd class medical since this effectively puts all demo flight people as passengers rather than students. I will not do a discovery flight without seeing a passport or birth cert. / photo id. They threatened an $11,000 fine if they checked and found a disc. flt that counted as "flight training" without proper docs.
The thing that really makes me mad about this as well is that I don't see how it really does a lick of good to prevent a serious terrorist from still doing something. I could have a nephew that doesn't have a birth cert. or passport, KNOW that he is an American Citizen, and be forced by this code to not allow him flight training. That to me is a violation of his rights. On the other hand, some enterprising terrorist could give me a 100% genuine looking birth cert, and I'd have NO way of proving otherwise.

Ryan
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You need to contact AOPA. They have a page that makes this all quite clear which includes guidance from the TSA. Individual line-level agents will always get confused and can always be corrected.
http://www.aopa.org/tsa_rule/alienfaq.html
 
RyanShort1 said:
All I have to say is that a LOT of flight instructors are probably mis-informed, and need to read and re-read 14 CFR 1552 a LOT more carefully - and before they get a visit from their friendly local TSA agent. There were two of 'em, and they showed badges before getting down to business.
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Just because they show a badge doesn't mean they get to make up their own interpretations of the rules.
 
I had my visit today. I had already emailed copies to her of the pertinent info for my one foreign student. She didn't give me trouble for the others. Must asked me how I handle the records. And when the other CFI wasn't going to be available said that shed just see him in august. Much nicer than the ones who saw you, Ryan.
 
All I can tell you is that I've been getting these TSA audits for years. I'm aware of the endorsement "option" but have never put it to the test. I get a new inspector every year and they are quite adament about seeing my student records proving US citizenship. And alien student training takes it to a completely new level of hassle.

So, if you aren't getting audited, do what you want. But odds are that you will get audited at some point. Maybe sooner than you wish. I've had several "discussions" with the TSA about the "value" of their CFI audits and have not held back on what I think of it (which isn't much). But these guys work with the FAA on this and I don't think you want to refuse their demands without a lawyer.
 
I'm with Jesse. You need to verify the documents. You need a record that you verified the documents. You do not need a copy of the documents you verified.

Copying the documents is a common practice, however.
 
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