Notice2026-04297
Notice of Availability of FAA Notice N 8100.20 Regarding Organization Designation Authorization (ODA) Holder Ethics Training
Primary source
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Published
March 4, 2026
Issuing agencies
Transportation DepartmentFederal Aviation Administration
Abstract
FAA Notice N 8100.20, Organization Designation Authorization (ODA) Holder Ethics Training for Unit Members (UM) and Administrators, provides initial implementation of a requirement of the FAA Reauthorization Act of 2024, that FAA ensure that each ODA holder has in effect a recurrent training program for all ODA unit personnel.
Full Text
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<title>Federal Register, Volume 91 Issue 42 (Wednesday, March 4, 2026)</title>
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[Federal Register Volume 91, Number 42 (Wednesday, March 4, 2026)]
[Notices]
[Pages 10673-10674]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-04297]
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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
[Docket No. FAA-2025-0092]
Notice of Availability of FAA Notice N 8100.20 Regarding
Organization Designation Authorization (ODA) Holder Ethics Training
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Notice of availability.
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SUMMARY: FAA Notice N 8100.20, Organization Designation Authorization
(ODA) Holder Ethics Training for Unit Members (UM) and Administrators,
provides initial implementation of a requirement of the FAA
Reauthorization Act of 2024, that FAA ensure that each ODA holder has
in effect a recurrent training program for all ODA unit personnel.
FOR FURTHER INFORMATION CONTACT: Mr. Scott Geddie, Policy and Oversight
Integration Section, AVS-64, AVS ODA Office, Federal Aviation
Administration, by telephone at 405-954-6897 or by email at
<a href="/cdn-cgi/l/email-protection#e0b3838f9494cea78584848985a0868181ce878f96"><span class="__cf_email__" data-cfemail="6d3e0e021919432a08090904082d0b0c0c430a021b">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Background
The FAA Reauthorization Act of 2024, Public Law 118-63 (2024) (the
Act), amended Title 49 United States Code (U.S.C.) section 44736 by
imposing several requirements specific to the FAA's oversight of ODA
holders. Section 304 of the Act added one such requirement to 49 U.S.C.
44736; paragraph (g), Ethics Training Requirement for ODA Holders.
Paragraph (g) requires the FAA to ensure that each ODA holder has in
effect a recurrent training program, reviewed by the FAA, for all ODA
unit personnel. Paragraph (g) also requires all ODA unit personnel to
complete such ethics training within 60 days of appointment and
annually thereafter, and requires the FAA to establish the necessary
processes to ensure that this training occurs. Notice N 8100.20
provides initial implementation of the statutory requirement for ODA
holders to develop and provide, and for all ODA unit personnel to
complete, initial and recurrent ethics training. The FAA intends to
incorporate the policies established in this Notice into a future
revision of FAA Order 8100.15, Organization Designation Authorization
Procedures.
Comments
A proposed version of Notice N 8100.20 was published in the Federal
Register and made available for public comment from June 17, 2025,
through July 17, 2025 (90 FR 25530, June 17, 2025). The FAA received 62
public comments from a range of stakeholders, including industry
associations and 12 of the 75 current ODA holders. Organizations
submitting comments included AeroMech Inc., the Air Line Pilots
Association, Airlines for America, American Airlines Inc., Textron
Aviation Inc., The Boeing Company, Delta Airlines, Garmin International
Inc., General Aviation Manufacturers Association, Gulfstream Aerospace
Corporation, Heico Aerospace Corporation, Kilroy Aviation LLC, Lycoming
Engines, Mammoth Freighters LLC, and Rolls-Royce Corporation. Most
commenters suggested relatively minor changes to facilitate the
implementation of the statutory requirement of 49 U.S.C. 44736(g).
FAA Developed Training and UMs Employed by Multiple ODAs
Several commenters recommended that the FAA develop a standardized
ethics training program for ODA UMs and administrators. Some commenters
further suggested that completion of ethics training by a UM at one ODA
holder should satisfy the ethics training requirement for any other ODA
holder employing the same UM.
The FAA does not agree with the requests. The Act requires each ODA
holder to have a recurrent training program in effect that covers its
own processes and procedures as described in its approved procedures
manual. The FAA acknowledges there may be common elements among ODA
holders' ethics training programs. However, variations in ODA holders'
operations and organizational structures preclude the establishment of
a single, standardized ethics training program applicable to all ODA
holders. The FAA considers ethics training to be a holistic approach
intended to instill professionalism among ODA UMs and administrators
and to support the safety culture of each organization. The FAA does
not intend to develop a standardized ethics training program or to
permit the transferability of ethics training between ODA holders. Each
ODA holder remains responsible for (1) providing ethics training to its
UMs in accordance with its own procedures and (2) ensuring continued
compliance with statutory requirements.
Delay Implementation and Duplication of Training
Multiple commenters expressed concern that the timeline for
developing and delivering the required training is insufficient.
Commenters also recommended delaying implementation of Notice N 8100.20
to coincide with the next revision of FAA Order 8100.15. One commenter
stated that the Notice is unnecessary due to overlap with existing
training requirements.
The FAA does not agree with the requests. The Act established the
timeline to implement the required ethics training and the FAA
determined an extension of the training delivery period is not
warranted. Notice N 8100.20 authorizes Organizational Management Team
(OMT) managers to grant extensions to ODA holders, as necessary, for
the development of ethics training. If a UM does not complete the
required training within 60 business days after the OMT's approval of
the ethics training, that UM may not exercise the functions delegated
and responsibilities under the ODA until the training is completed. The
FAA recognizes that there may be some overlap with existing training
requirements. The training requirements outlined in paragraph 5.a.(4)
and (5) of the Notice were previously mandated to be completed once
every two years by FAA Order 8100.15B and Notice N 8100.19. Notice N
8100.20 changes the frequency of these requirements to an annual basis,
as required by the Act.
Required Language in ODA Procedures Manuals
One commenter questioned the necessity for ODA procedures manuals
to include the specific language found in paragraph 5.b.(1) of draft
Notice N 8100.20, which requires ODA procedures manuals to specify
``existing
[[Page 10674]]
ODA Unit Members (UMs) and administrators must complete the required
ethics training within 60 business days after the Organizational
Management Team (OMT) approves the ODA's revised Procedures Manual
incorporating ethics training, and annually thereafter, in order to
continue exercising the functions and responsibilities delegated under
the ODA.'' The FAA agrees to clarify this requirement. The FAA
restructured paragraphs 5.b.(1) through (3) to state that an ODA
holder's revised procedures manual must specify when existing ODA UMs
and administrators must complete initial ethics training, when newly
appointed ODA UMs and administrators must complete initial ethics
training, and that the ODA UM or administrator must have completed the
ethics training in the previous 12 months to meet the annual ethics
training requirements. The ODA holder's revised procedures manual must
also specify that the initial and annual ethics training requirements
must be completed prior to exercising authorized functions and
responsibilities under the ODA. This requirement is mandated to ensure
compliance with the accountability provisions set forth in the Act.
Terms To Identify Training Requirements
A commenter suggested that FAA use terms such as initial
qualification, recurrent qualification, requalification, or transition
training to designate ethics training.
The FAA does not agree with the request. Integrating new terms to
designate ODA holder training requirements is beyond the scope of
Notice N 8100.20.
Clarifications and Consistency
Multiple commenters requested that FAA clarify the meaning of
``annually'' as it relates to training intervals. The FAA agrees to
clarify the language. The FAA revised the relevant language to specify
``in the previous 12 months prior'' rather than ``annually thereafter''
to clarify the intended interval for recurring training requirements.
One commenter requested that FAA clarify the term ``code of
ethics.'' The FAA agrees and has revised the language to specify that
the code of ethics must specify that safety is of the highest priority.
Multiple commenters requested that FAA clarify the requirements for
training on professionalism and for promoting a clear understanding
among ODA UMs and administrators of the purpose and procedures
associated with Safety Management Systems (SMS). The commenters noted
that training on ``professionalism'' is duplicated in Notice N 8100.20.
Commenters also sought to distinguish the training requirements as they
relate to an ODA holder's SMS. The commenters requested that FAA
clarify whether training should address the requirements of Title 14,
Code of Federal Regulations (CFR) Part 5, for ODA holders required to
have an SMS, or the provisions of the International Civil Aviation
Organization (ICAO) Safety Management Manual (SMM) (Doc 9859), or any
successor edition, for ODA holders not required to have an SMS.
The FAA agrees to clarify. The FAA revised the Notice to remove the
duplicate reference to ``professionalism'' and to clarify the training
requirements. The revised language requires that training promotes a
clear understanding among ODA UMs and administrators regarding the
purpose and procedures associated with SMS. Additionally, the training
must also address the provisions of the third edition of the ICAO
Safety Management Manual (Doc 9859), or any successor edition.
Several commenters requested that FAA clarify training requirements
for reporting safety concerns. The FAA agrees to provide clarification
and, in response, has revised Notice N 8100.20 to reference the
applicable requirements of 14 CFR 183.63 and 14 CFR 183.65.
One commenter observed that the requirement for ODAs to report
training completion for existing ODA UMs and administrators is
redundant. The commenter reasoned that training completion is already
addressed through standard OMT surveillance in FAA Order 8100.15. The
FAA agrees and has revised Notice N 8100.20 to remove the seventh
bullet from paragraph 8 that would have required the completion date of
ODA holder training to be submitted to the ODA Office via the OMT Data
Portal.
SMS Resources
One commenter requested additional resources to assist in
developing the SMS components of the ethics training. Technical content
is available on <a href="http://www.faa.gov">www.faa.gov</a> to support ODA holders in the development
of their training programs.
Editorial Change
FAA corrected a clerical error relating to the implementation
timeline in paragraph 7.b of the Notice. The correction changes the
number of calendar days from 180 to 194.
This Notice is available to the public at <a href="http://www.faa.gov/regulations_policies/orders_notices">http://www.faa.gov/regulations_policies/orders_notices</a>, on the Dynamic Regulatory System
website at <a href="https://drs.faa.gov">https://drs.faa.gov</a>, and in the docket.
Scott A. Geddie,
Manager, AVS-64, Policy and Oversight Integration Section, AVS ODA
Office.
[FR Doc. 2026-04297 Filed 3-3-26; 8:45 am]
BILLING CODE 4910-13-P
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