Former FAA Employees

FAR 141.34 — Former FAA Employees

FAR 141.34 restricts Part 141 pilot schools from hiring former FAA inspectors as agents before the FAA within 2 years. Key rules, exceptions, and oral prep.

In Plain English

FAR 141.34 limits how a Part 141 pilot school can use former FAA personnel when dealing with the agency. The rule prevents a revolving-door situation where a recently departed inspector could leverage insider relationships on behalf of a school they used to oversee.

A certificate holder (or provisional certificate holder) may not knowingly employ or contract with an individual to act as their agent or representative before the FAA if, within the preceding 2 years, that person:

Served as, or directly oversaw, a Flight Standards Service aviation safety inspector, and
Had direct responsibility to inspect (or oversee the inspection of) that certificate holder's operations.

"Acting as an agent" means making any written or oral communication to the FAA on the school's behalf about a particular matter — regardless of whether the person personally worked on that matter while at the FAA.

Exception: The rule does not apply to individuals who were already employed by the certificate holder before October 21, 2011.

Why it matters: schools must vet new hires carefully before letting them interact with the FAA, or risk a certificate action.

Regulation Text

14 CFR § 141.34

§ 141.34 Employment of former FAA employees. (a) Except as specified in paragraph (c) of this section, no holder of a pilot school certificate or a provisional pilot school certificate may knowingly employ or make a contractual arrangement which permits an individual to act as an agent or representative of the certificate holder in any matter before the Federal Aviation Administration if the individual, in the preceding 2 years— (1) Served as, or was directly responsible for the oversight of, a Flight Standards Service aviation safety inspector; and (2) Had direct responsibility to inspect, or oversee the inspection of, the operations of the certificate holder. (b) For the purpose of this section, an individual shall be considered to be acting as an agent or representative of a certificate holder in a matter before the agency if the individual makes any written or oral communication on behalf of the certificate holder to the agency (or any of its officers or employees) in connection with a particular matter, whether or not involving a specific party and without regard to whether the individual has participated in, or had responsibility for, the particular matter while serving as a Flight Standards Service aviation safety inspector. (c) The provisions of this section do not prohibit a holder of a pilot school certificate or a provisional pilot school certificate from knowingly employing or making a contractual arrangement which permits an individual to act as an agent or representative of the certificate holder in any matter before the Federal Aviation Administration if the individual was employed by the certificate holder before October 21, 2011. [Docket FAA-2008-1154, 76 FR 52236, Aug. 22, 2011]

Oral Exam Questions a DPE Might Ask

Q1Under Part 141, can a pilot school hire a former FAA aviation safety inspector to represent the school before the FAA?

Per FAR 141.34, not within 2 years of that person serving as (or supervising) a Flight Standards Service aviation safety inspector who had direct responsibility to inspect the school's operations.

Q2What does it mean to act as an 'agent or representative' of the certificate holder before the FAA?

FAR 141.34(b) defines it as making any written or oral communication to the FAA on the school's behalf about a particular matter, whether or not the individual previously worked on that matter as an inspector.

Q3Is there any exception to the former FAA employee restriction in Part 141?

Yes. FAR 141.34(c) exempts individuals who were already employed by the certificate holder before October 21, 2011, allowing them to continue acting as the school's agent before the FAA.

Practice this with our AI examiner

Examiner Reed adapts to your responses and probes deeper on weak spots — full ACS coverage, not a script.

Studying for a checkride?

All Checkride Prep

Every FAA pilot rating

FAR Library

All 741 sections in plain English

Related Sections in Part 141

§ 141.1

Part 141 Applicability

§ 141.101

Part 141 Training Records