FAA's New Training Requirements
The FAA issued a final rule for FAA 2003-15085 on October 7, 2005. This rule involves training requirements for various categories of employees for both "will carry" and "will not carry"
(Hazmats) air carriers and subcontractors. Part 121 & 135 and Part 145 Repair Stations are affected by this new regulation.
With comments, explanations and instructions it pretty much reads like an IRS Income Tax form in terms of complexity. In essence it agrees with the ICAO and IATA 2005 Editions regarding dangerous goods training required based upon the type of work performed by various types of employees.
The new regulations also place different degrees of training requirements based upon whether or not the air carrier chooses to carry dangerous goods, or, not carry dangerous goods. They are identified as "will carry" and "will not carry" operators and must notify their subcontractors in writing as to which category they fall under. The subcontractors, including repair stations, must then train their appropriate employees in the same manner and the same approved training program as their client (the carrier).
Both the carrier and the subcontractor training programs must be submitted to the carrier's FAA Principal Operations Inspector who will in turn submit the training program for approval by the Branch Manager of the FAA Regional Security and Hazardous Materials Office.
The following tables represent the training requirements for certificate holders (carriers) that "will carry" and "will not carry."
"Will not carry" certificate holders will not be permitted to "not carry" for shippers & passengers but then carry hazardous materials as comat.
This rule will impact maintenance and stores personnel for the air carriers. Aircraft parts that are also dangerous goods and have been removed from an aircraft for maintenance or overhaul will be prohibited from being placed on an aircraft unless those employees receive HAZMAT training. Stores personnel in particular will now have the same responsibilities for compliance as shippers.
Subsidiary companies of the airlines and subcontractors that handle passenger ticketing, loading cargo and baggage functions will now have their hazardous materials training requirements clarified.
The following tables will give you a snapshot of the new regulations.
However, we strongly urge carrier, subcontractor and repair station supervisors read the entire
final rule. You can download it at http://dmses.dot.gov/docimages/pdf93/348458_web.pdf