Aviation · Regulation
Every US Part 121 air carrier is required by federal regulation to operate a formal pilot mentoring program, governed by a joint management-labor committee, with leadership-and-command and mentoring training that every captain must complete before flying the left seat. Here is the statute that requires it, the rule that implements it, who is covered, and how the carrier and the pilots' union split the work in practice.
1 · The statute
The mandate originates in Public Law 111-216, the Airline Safety and Federal Aviation Administration Extension Act of 2010, signed into law on August 1, 2010. The same act produced the well-known 1,500-hour ATP rule; the mentoring mandate is the act's other durable structural reform. Both pieces of the act were Congress's response to the February 12, 2009 crash of Colgan Air Flight 3407 near Buffalo, New York — an accident that killed 50 people and exposed systemic gaps in regional-airline pilot training, screening, and professional development.
Section 206 of the act is titled "Flight Crewmember Mentoring, Professional Development, and Leadership." It directed the FAA Administrator to convene an aviation rulemaking committee and then issue regulations requiring each Part 121 air carrier to:
The statute is a directive to the FAA, not a self-executing rule — the operative requirements on air carriers come from the implementing regulation that the FAA issued ten years later.
2 · The rule
The FAA published its implementing rule, titled "Pilot Professional Development", in the Federal Register on February 25, 2020 (85 Fed. Reg. 10896, RIN 2120-AJ87). The rule became effective on April 27, 2020, with full carrier compliance required by April 27, 2022. A small technical-amendments rule followed at 85 Fed. Reg. 39247 on June 30, 2020, cleaning up cross-references but not changing the substantive obligations.
The rule is codified at 14 CFR Part 121, Subpart N (Training Program), primarily across five sections:
§ 121.419
Pilots and flight engineers: Initial, transition, and upgrade ground training.
§ 121.420
Pilots: Differences training and re-establishment of recency of experience.
§ 121.424
Pilots: Initial, transition, and upgrade flight training.
§ 121.426
Recurrent training.
§ 121.429
Pilots in command: Leadership and command and mentoring training.
The centerpiece section — no carrier may use a pilot as PIC under Part 121 unless the pilot has completed leadership-and-command and mentoring training under the carrier's program.
The FAA also issued two implementing advisory circulars in March 2020 that explain how a carrier should design its program. Advisory circulars are not binding rules; they are the FAA's official statement of one acceptable means of compliance. The two relevant ACs:
AC 121-43 · Mentoring Training for Pilots in Command
Guidelines for developing and implementing the mentoring component — mentor selection, mentor preparation, structured mentor-protégé interactions, program oversight. Issued March 3, 2020.
AC 121-42 · Leadership and Command Training for Pilots in Command
The companion AC covering the leadership-and-command piece of the same rule — PIC duties, authority, decision-making under crew resource management.
3 · What the program must do
Putting the statute, the final rule, and the advisory circulars together, the obligation breaks into four pieces. A compliant program has all four, and the FAA's Flight Standards office expects to see each component documented and operational on inspection.
Before a newly hired pilot serves as a flightcrew member in revenue operations, the carrier must provide the pilot with an opportunity to observe flight operations and become familiar with the carrier's procedures. In practice this is a structured jumpseat / observation phase during indoctrination, documented as part of the new-hire training file.
Ground training for a pilot upgrading to captain must include facilitated instruction on leadership and command (including PIC duties under § 121.542) and on mentoring — specifically, techniques for instilling and reinforcing technical performance, airmanship, and professionalism in newly hired pilots.
Upgrade flight training must include scenario-based training that exercises crew-resource-management and leadership-and-command skills together — the rule explicitly rejects a checklist-only simulator pass as sufficient for the upgrade.
Under § 121.429, no certificate holder may use a pilot as pilot in command in an operation under Part 121 unless the pilot has completed the leadership-and-command and mentoring training the section describes. This is the rule's compliance hook — an FAA inspector pulling a captain's training file expects to find the documented completion of both. AC 121-43 lays out the FAA's preferred way to build that training: structured mentor selection criteria, mentor preparation curriculum, defined mentor-protégé interactions during the new-hire's first months, and oversight that feeds back into the carrier's safety-management system.
The carrier must stand up a Professional Development Committee (PDC) composed of both management and labor representatives. The PDC's job is governance, not delivery: it owns the program, reviews how it's working, and folds findings back into training.
For unionized carriers (which is every US mainline and every US regional), the labor side is the pilots' union — ALPA at most carriers, APA at American, SWAPA at Southwest, IPA at UPS. For non-union Part 121 carriers (rare; mostly small supplementals), the statute substitutes "professional association or other group representing the airmen," which in practice means an elected pilot-representative body inside the company.
4 · Who's covered
The rule applies to every US-certificated air carrier operating under 14 CFR Part 121 — domestic, flag, and supplemental operations. In plain terms, that is essentially every scheduled US passenger airline, every US regional / feeder carrier, every US all-cargo carrier flying under Part 121, and the supplemental side of charter operators that hold a Part 121 certificate. The category includes, but is not limited to:
Mainline passenger
American, Delta, United, Southwest, Alaska, JetBlue, Spirit, Frontier, Hawaiian, Allegiant, Sun Country, Breeze, Avelo.
Regionals / feeders
SkyWest, Republic, Envoy, PSA, Piedmont, Endeavor, Horizon, Mesa, GoJet, CommutAir, Cape Air.
All-cargo
FedEx Express, UPS Airlines, Atlas Air, Kalitta Air, ABX Air, Polar Air Cargo, Amazon Air's Part 121 operators.
Supplemental / charter
Omni Air International and the Part 121 supplemental sides of certain combination carriers.
The rule does not bind:
Every major US passenger airline has unionized pilots, so the joint management-labor PDC model is the universal pattern on the passenger side. The all-cargo carriers split: FedEx and Atlas Air are represented by ALPA; UPS is represented by IPA; the smaller all-cargo carriers are a mix of union and non-union.
5 · Airline vs. union obligations
The legal obligation sits squarely with the airline. The union cannot be sanctioned by the FAA, because the union does not hold a Part 121 operating certificate. The rule is written as "no certificate holder may use a pilot as PIC unless..." — the hook is on the carrier. If a Part 121 mentoring program fails an FAA audit, the consequence falls on the carrier's certificate, not on ALPA, APA, SWAPA, IPA, or any other pilot union.
But the way the statute was written makes it a joint operation in practice, and that is where the union role becomes load-bearing. Section 206 explicitly requires that each PDC be composed of both management and the labor union (or, where there is no union, an elected pilot-representative body). The carrier can't unilaterally constitute the PDC — it has to seat union reps as a statutory matter.
The carrier owns
The union typically owns
The union piece is voluntary as a matter of federal law — the union is not a regulated party — but it is the practical mechanism by which the carrier discharges the relationship-and-pairing piece of its obligation.
The PDC is where the two sides meet. It is the joint governance body, it owns the program's design and audits, and it is the artifact the FAA looks at to verify that labor is genuinely involved rather than rubber-stamped. PDC meeting minutes, member lists, and decision logs are typical FAA inspection material.
So the practical answer to "airline or union?" is: the airline as the regulated party, with the union as a statutorily required partner. A pilot considering whether to credit the airline or the union for a working mentoring program would credit both — the airline because it has to, the union because it usually wants to and is often better positioned to do the part it does.
6 · How carriers and unions operate the program
The FAA does not bless any specific product, and the rule does not require software. What it requires is the program, the committee, the training, and the records. In practice, carriers and unions assemble two software layers that map naturally to the two halves of the obligation, plus a layer of in-house build for the parts that don't fit either.
These satisfy §§ 121.419 / 121.420 / 121.424 / 121.426 / 121.429 by tracking who completed which training, when, and with what outcome. They are what an FAA inspector pulls records from. The major vendors:
These handle the mentor-protégé mechanics the FAA expects to see operating around AC 121-43: pairing new hires with mentor PICs, scheduling and logging interactions, surveys, and program analytics for the PDC to review. The vendors:
ALPA has paired Qooper with Real Magnet (now part of Higher Logic) for drip-style automated email and onboarding-cadence messaging to new hires. Independent pilot unions take a parallel approach: APA (American), SWAPA (Southwest), and IPA (UPS) use a mix of their member-engagement platform (NationBuilder, Salesforce Communities, Higher Logic Vanilla, or custom) for outreach plus a mentoring platform — most commonly Qooper or Chronus — for the matched program itself.
Many carriers run pieces of the program through their own LMS or homegrown SharePoint / Salesforce platforms. Delta's Propel career-pathway program uses a structured carrier-built mentor pairing where Propel pilots keep the same mentor throughout, and the carrier maintains the records side in its own training system. United's program runs on MentorSMART (named above) under its ALPA partnership. The mainlines tend to build more of the relationship layer internally or through a union-aligned custom tool; the regionals tend to rely on the union side (Qooper) and the off-the-shelf TMS (ATMS, CAE) for most of it.
The honest caveat
Neither vendor category alone satisfies the rule. Compliance evidence is: a documented program description, a standing PDC with joint management-labor representation, a published mentor selection and training process, training records showing every PIC has completed leadership-and-command and mentoring training, and observable mentor-protégé activity. The TMS layer carries the records; the mentoring-platform layer (or a homegrown equivalent) carries the activity; the PDC is the governance. Most carriers buy one of each, build the rest in-house, and document the whole stack to the FAA POI.
Sources
Everything on this page is sourced from federal primary records. The statute, the rule, the codified CFR text, and the advisory circulars are public-domain federal works. Union and vendor references are cited as factual identifications of who does what.
I keep this page narrowly bounded to the federal regulatory regime. I do not endorse any particular software vendor, union, or carrier-side program design. Vendor identifications are factual; the FAA does not bless any product, and the rule does not require software. Verify everything before acting on it — the primary sources above are authoritative; this page is a guide to them.