It is common to know IS 141-007D by the items that come up during an inspection: the enrollment form, the transcript deadline, the signature on the certificate. That is a narrow reading. The document's official title is "Programas de Instrução e Manual de Instruções e Procedimentos" (training programs and instructions and procedures manual), and it runs to 503 pages. The chapter devoted to the student is one of fifteen.
This article summarizes what revision D is, what changed in it and what it asks of the CIAC (civil aviation training center) day to day, with the number of each item for anyone who wants to check the original.
What IS 141-007D is
Revision D was approved by Portaria No. 13.686/SPL of January 24, 2024, published in the Diário Oficial da União (DOU) on January 25, and in force from February 1, 2024. The same ordinance revoked the ordinances that had approved revisions C (Portaria No. 10.566/SPL, 02/16/2023) and B (Portaria No. 10.098/SPL, 12/20/2022), and article 1 of Portaria No. 1.529/SPO of 06/12/2020, which approved revision A. A correction was published in the DOU on February 1, 2024, shortening item 3.7 (video monitoring).
Like every Instrução Suplementar (IS), it clarifies and details how a regulation applies, in this case RBAC 141 (Brazil's regulation for civil aviation training centers). The text itself states the limits of that: the CIAC may adopt the means described in the IS or present a justified alternative, which depends on ANAC's express agreement, and the IS cannot create a new requirement or contradict the RBAC.
The structure is that of a manual. The first six chapters are general (general provisions, participants, instructional resources, use of FSTD, teaching staff and methodology). The others bring guidelines by category: airplane, helicopter, glider, balloon, tilt-rotor, airship, RPA, aircraft maintenance mechanic and flight attendant.
The central distinction is in item 1.2. The training program (PI) describes how a specific course is conducted. The MIP (instructions and procedures manual) describes how the CIAC conducts its activities. The IS includes an index of the items related to the content of the MIP, with the corresponding RBAC 141 section, and says it can be used as a checklist when writing the manual.
Who it applies to
CIACs certified under RBAC 141. Section 141.23(a) requires an ANAC-approved training program for each course taught that is provided for in RBAC 61, 63 or 65, and item 1.6 of the IS says the program may only be run after the approval FOP is received.
Courses that do not depend on approval may be offered freely (item 1.7), but the IS asks that it be made clear to prospective students that they are not approved by ANAC, and recommends that they follow the principles of the IS and go through the CIAC's SMS (SGSO) and quality system (SGQ). The correlation tables also note that the SMS is required for type 2 and 3 CIACs.
For whoever builds the PI, item 1.5 makes the course coordinator the main person responsible for writing it, with support from the quality manager and, in practical courses, the safety manager. The IS sets final competencies for each license, and the CIAC must, at a minimum, achieve them. The topic connects with what we discussed about CBTA and EBT in general aviation.
What changed in revision D
The IS's own revision history lists the changes in revision D:
- removal of references to RBHA 63, which was revoked;
- removal, from the summary of deadlines, of the deadlines related to flight video recording;
- adjustments to items 1.11, 5.1.1, 6.22.1, 7.1, 7.2.2, 7.2.3 and 7.3.1, removing references to the PQI (Programa de Qualidade na Instrução, the training quality program);
- in items 1.12 and 3.7, removal of the PQI details, which are now described in a separate guide;
- in item 4.7.4, updated instructions on FSTD abnormalities;
- change of the responsible area from GTOF to GFOP.
The February correction confirmed the direction: item 3.7 kept only the encouragement to use video as an instructional resource, and the item 3.7 rows were removed from the deadlines table. The PQI criteria are in the PQI Implementation Guide, cited in item 1.12.
What it asks of the CIAC in practice
Records: complete, intact and accessible
Item 1.4 gives the three characteristics of the records system: completeness (allowing the training history of each student or instructor to be reconstructed), integrity (records that are not removed or altered, with a backup) and accessibility (readily accessible).
Enrollment and the student file
Under item 2.1, enrollment requires, through an enrollment form or a computerized system: full name, ANAC code, CPF (including for foreigners), date of birth, photo ID, nationality, parents' names, education level, full address, student contact and emergency contact. Table 2-1 adds each course's requirements, such as age, education and CMA (aeronautical medical certificate) class.
Item 2.2 lists what goes into the student's individual file, physical or digital, from subitem a) to o). Among them: a copy of the ID document, proof of education and of residence, the guardian's statement for minors, the statement of awareness about the CMA, transcripts, transfer documents, attendance sheets, flight hour totals, tracking of the validity of ratings and the CMA, and the record of each course with the PI code, dates and result (passed, failed, transferred or canceled). Attendance in ground courses must be tracked by day and by subject, so that it is easy to check whether a student was present on a given day (2.2.1).
Instructors and coordinators
Instructors' initial and recurrent training is valid for 12 months, with a tolerance of one month before or after expiry. After that, the instructor may not teach until completing recurrent training; with more than 24 months since the last training, they go back to initial training (5.1). Item 5.2 asks for a detailed record for each instructor and daily tracking of flight instructors' working hours.
Under item 5.3, the course coordinator tracks the validity of instructors' training, ratings, CMA and recent experience, and the quality manager is responsible for ensuring that no one with an expired date gives instruction. For students, the instructor checks, before each session, whether the student meets the requirements.
Training forms
Each practical training activity needs a form (6.22.1), with minimum content from subitem a) to k): program and activity, name, ANAC code and signature of student and instructor, times, duration and landings, aircraft, aerodromes and routes, objectives, assessment and the instructor's opinion. The signature may be electronic, but may not be automatic. The forms are part of the approved program and must be used without modification. The CIAC must be able to locate them quickly by student, instructor, date, aircraft and PI (6.22.2).
Deadlines the IS consolidates
| Item | What | Deadline |
|---|---|---|
| 2.5.2 | Documents and withdrawal of a transferring student | up to 10 calendar days |
| 2.6 | Transcript for a student with no activity in the PI | after 30 calendar days |
| 6.5 | Certificate, transcript and CIV delivered to the student | up to 10 calendar days |
| 6.11.1 | Updating the pilot logbook (CIV) | every 7 days |
| 6.11.1 | Complete CIV after completion or withdrawal | up to 7 calendar days |
| 6.13.8 | Retention of assessment records | 5 years |
| 6.22.2 | Retention of training forms | 5 years |
The certificate (6.5) has seven minimum pieces of information, among them the control code, the student's name and CPF, the PI code and the signature of the course coordinator, at a minimum, or of a person in a higher position. The IS also requires a means of verifying the certificate's authenticity.
Common mistakes that the IS and RBAC 141 make it possible to identify
Changing the form or the PI without approval. Section 141.23(e) requires prior approval of any amendment to the program. Item 1.3 of the IS distinguishes: a change to the PI only applies after approval, while a change to the MIP takes effect ten days after filing. A training form "improved" on the school's own initiative is a change to an approved program.
A signature that applies itself. A system that stamps the student's or the instructor's signature when the form is saved does not meet 6.22.1, which allows electronic signatures, not automatic ones.
Recording the status and forgetting the result. "Enrollment closed" does not answer subitem l) of 2.2, which asks for the outcome: passed, failed, transferred or canceled.
A stalled student with no transcript. The 30-day deadline in item 2.6 applies to any student with no activity in the PI, not only to those who asked for a transfer.
An instructor with expired CIAC training. Revalidating the flight instructor rating does not replace the recurrent training set out in the MIP; the IS says one is independent of the other (5.1).
A certificate outside the deadline or the period. Besides the 10 days in item 6.5, section 141.81(b)(3) only allows the certificate to be issued if the student completed the course requirements in no more than twice the normal period set in the program.
Offering what is not approved. Under item 1.20.1, the CIAC may not enroll, advertise or put on a waiting list a program that is suspended, revoked or only filed.
Where Alis comes in
The Alis flight school module was built with IS 141-007D as the reference for the student file. In the enrollment record, besides name, ANAC code, CPF and contacts, there are the other fields of item 2.1: nationality, parents' names, education level with its status (in progress or completed) and a structured address. The student's documents are kept in private storage, sorted by category: identification, education, residence, guardian's statement, CMA statement, transfer and transcript.
Credentials (CMA with class, licenses, ratings and endorsements) have validity dates, and the student record flags what has expired or expires within 30 days. Each enrollment has its own result, separate from its status. Ground-course attendance is entered by student, day and subject, and the same screen lists students with no activity for more than 30 days so the office can issue the transcript; the system warns, and issuing it remains an act of the school.
Each course has a coordinator, whose name appears on the signature line of the completion certificate, and the certificate carries a verification footer with code, hash and link. On the FIP, the student signs through a link received when the instructor finalizes the form, and the signature is recorded with date, time and hash. For transfers, all of the student's FIPs come out in a single file. The enrollment also warns when it has gone past twice the expected period of 141.81(b)(3).
For quality assurance, which IS 141-007D cites in several items, see the article on IS 141-006A; for the routine of training forms, the piece on the FIP and the CIAC's paper folder. The module is described on the flight schools page.
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This article is informational. It is based on IS 141-007, Revision D, approved by Portaria No. 13.686/SPL of January 24, 2024 (in force on February 1, 2024), with the correction published in the DOU on February 1, 2024, and on RBAC 141, Amendment No. 03 (Resolution No. 706 of 02/28/2023). It does not replace consulting the regulations or the guidance of the course coordinator and the CIAC's technical and operational managers.