Last Thursday morning at 10:34 a.m., my effort to stay focused on my work task at hand was once again interrupted by a pop-up email alert. This one certainly broke my concentration as the subject line read “1200: Inquiry Regarding Flight Instruction.”
Two possibilities came to mind while I prepared to shift into email mode. Someone new was reaching out to me for some training or the FAA/NTSB was about to solicit information regarding an accident that recently happened to a former student who had an in-flight engine failure. If it was to be a new student, I’d get an opportunity to fly with someone new and help them achieve their goal. After all, I had earned my AGI, CFI, CFII, and MEI in the last two years with the intention of sharing nearly 40 years of flying experience with anyone who had the patience to listen to me prattle on about my adventures. On the other hand, if the FAA wanted to talk to me about my former student, it wouldn’t be nearly as exciting.
Opening up the unexpected email, I read that it was in fact from a Transportation Security Inspector (TSI) based out of Baltimore-Washington International airport. Interesting: I didn’t know that they even had that position. Reading the one-sentence question in the email revealed little about the purpose. “I am reaching out to see if you have conducted any flight instruction (initial, instrument or multi-engine) within the past five years that is separate from any flight school you may instruct at.”
Oh boy … the only metaphor that adequately describes the cold chill that washed over my body was when I’ve been driving along the highway minding my own business and then a flashing blue light illuminates my mirrors. The reaction was similar with a self-examination of all of my actions to see if I had triggered an alert with the TSA though my instruction. None of my CFI acquaintances had ever mentioned being contacted by the TSA about their instructing. What had I done?
After my heart calmed down, I went to check my logbook to see when I had received my TSA security awareness training required by 49 CFR 1552.13(d). My paper log was at home. Quickly, I went to Sporty’s online classroom to see if they had a record of my training. No joy there. On to King Schools and there I found my transcript showed that I had not completed the course! Queue the panic as now it all made sense. The TSI had discovered that I had not completed that required training and now must suffer the consequences.
I took a deep breath and replied to his email at 10:44 a.m. with a measured response. “Yes, I have done some instructing in all three areas of my CFI certification. I do not work for a flight school.” There, I’ve answered the question without confessing to not having proof of training that I was sure I had completed. Having sent the reply, it was time to go back to King Schools and take my training to completion. Although I couldn’t complete the earlier instance from nearly two years ago, a new training session was available. Dropping all pretense of returning to my previous work, I threw myself into completing the course and internalizing reminders of my responsibilities regarding training foreign students and diligently checking the citizenship of the students I accepted. With my new certificate of training in hand, I breathed a sigh of relief and calmed down enough to resume my regular duties.
At 2:19 p.m., the TSI replied to my email with “Has anyone with TSA ever met with you to review your compliance with 49 CFR part 1552 – Flight Training Security Program?”
Yikes! Another wave of adrenaline coursed through my body.
After a few more back-and-forth emails, he made an appointment with me to meet one week later at my regular airport to review my compliance documentation. Great! Now, I have time to make sure that I have met the requirements so recently refreshed in my mind. After arriving home, I flipped open my logbook to see that I did indeed finish the TSA awareness course and had the logbook entry virtually signed by John King himself. What a relief washed over me. Over the course of the next few days, I scrutinized my logbook entries and compared them to the electronic documents of my students’ passports, birth certificates, and government-issued IDs. All seemed to be in order, but I couldn’t figure out why I was being singled out for this audit.
I consulted with one of the local DPEs, who informed me that he had been audited regularly and that it was not a confrontational, gotcha encounter but rather an opportunity for learning how to operate better in the system.
Today, the appointed day for my rendezvous with destiny arrived. As I was finishing my lunch in the pilot briefing area of the FBO, a trim, smiling middle-aged man asked for me at the front desk. Putting down my last delicious slice of a Cara Cara orange, we greeted one another with a fist bump before I washed up preventing the saturation of my precious logbook pages with sticky fingers.
We exchanged some pleasantries and IDs. His badge was a very impressive gold and black enclosed in a handsome leather trifold wallet. He examined my U.S. passport and handed it back to me with an approving nod. Although I was anxious to present my logbook and show him my lovely King School endorsements, he pushed it back toward me and encouraged me to relax and let him do the driving with, “We’ll get to that later.”
He handed me a copy of 49 CFR 1552, which had a print date of May 5, 2026, and we started into a review of the purpose of the program as well as the importance of having everyone participate.
I couldn’t hold back my need to know any longer, so I asked, “But why me?”
The inspector informed me that all CFIs will be audited for compliance. Once we sign up for access to the FTSP Portal, we are visible to the TSA and they are required to audit us periodically for compliance. I offered to round up some of my friends at the airport who were known flight instructors so that he could make fast work of us all, but he demurred my suggestion. I was going to be in this audit alone. He or another TSI would make appointments with each of the CFIs in our area.
When we got to 1552.9 dealing with the requirement to designate a Security Coordinator, the inspector checked to be sure that I had designated myself as the coordinator in my one-person operation. Recordkeeping came next and I was finally able to present the inspector with my logbook and the cross-reference data for each of my students. Thankfully, all of their government-issued IDs were still in date.
An interesting point came up when we talked about interacting with the portal as well as foreign students. As CFIs and portal users, we must acknowledge notifications when we receive them. One option we have is to refuse the TSA’s training approval for a foreign candidate. The candidate is the one who selects our name as his instructor. Sometimes, the prospective student will choose the wrong result from his search and an unintended instructor or school gets issued the results of the application.
As we neared the end of our hour together, my TSI pointed out that the wording of the regulation is permissive, using phrases like “may initiate flight training,” and that this empowers the instructor or school to remain in control of the risk management side of the training decision. Our responsibility is to help keep everyone safe and we need the tools to politely refuse to train those people with whom we are uncomfortable. On the other hand, the regulations are prescriptive as to when we encounter a candidate who raises alarm signals with regard to any malevolent intentions for his flying skills.
Wrapping up, the inspector let me know that I’d be contacted by the TSA again at a future date to review my records since today’s inspection. I can honestly say that I’ll look forward to it if the next TSI has the positive, helpful attitude of the one I worked with today.
Key takeaways from this adventure:
- Familiarize yourself with the requirements of 1552 and review the particulars regularly.
- When the TSA contacts you, don’t get blue light syndrome. Relax. Breathe.
- Review your Security Awareness training dates and set a reminder for a month early. The training is only good for two years to the day. Be diligent in capturing the supporting documentation for your students who are training for a new certificate or rating. When dealing with the TSA for your audit, remember that they are people trying to do their job of ensuring that all of us are equipped to do our part.
Now I can return to my regularly scheduled work. After all, the TSI told me that I wouldn’t be audited until sometime in the future. Perhaps next time an email from the TSA startles me, my reaction will be more akin to seeing a traffic checkpoint ahead on the highway: just checking to be sure that I am operating in accordance to the rules. Perhaps other CFIs who have read my account can react with less startle and more confidence.
Walter,
Thank you so much for this article. I just completed my FIRC and forgot to print out the certificate for the TSA completion part. While no one likes more folks looking over our shoulders, perhaps if this stuff had been around 25 years ago, we might not have gone through 9/11. Well done article. Now, go back to work and use that A&P to fix what you’ve broken. 🙂
John
Ah yes. Another layer of bureaucracy and taxation to steal our time and money because the government keeps bringing terrorists into our country using our hard earned tax dollars. If Noah had had as much government red tape as we have today, the ark would never have been built and we would have all drowned in the flood.
Big reason why I let my CFI expire. With the little amount of instruction I did, did not make it worth while to go through all of the hoops of “security” training. Had enough of the time wasting TSA training when I was doing pt135 charters, time I will never get back. As far as 9/11 is concerned, it would have never happened if the FBI had been more worried about following up all the rumors and alerts that the aviation training industry was telling them than following government red tape. 9/11 would have never happened if the then INS agents had been allowed to enforce immigration regulations, something some in Congress again want to stop. Now aviation is stuck doing what other government agencies should have been doing. I have every right to complain about the end result of 9/11 because it nearly put the company I flew for out of business with then me out of a flying job. Where I used to go to the airport where I learned to fly and be able to talk to any CFI in the office, now is an empty office. I wonder how long it will take for a TSA inspector to cover every independent CFI out there with these worthless audits? I have been hearing there is a shortage of CFI’s along with a shortage of examiners giving check rides. If true I wonder if this TSA nonsense plays a role in that issue?