PART 382 COMPLIANCE AND “HANDS-ON” DISABILITY TRAINING
November 12, 2025
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Foreign air carriers that operate flights to and from the U.S. are required to train their staff to proficiency on the various requirements of Part 382. Staff includes, but is not limited to, pilots, flight attendants, reservation/sales (including GSAs), ticket counter personnel, gate agents, ramp and baggage handling personnel and passenger service officer personnel. Employees should be trained as appropriate to their specific employee duties. Carriers are also responsible for training and ensuring that contractors provide training to their employees who deal directly with the traveling public.
All employees who interact with the U.S. traveling public should receive initial training (recommended 8 hours). Refresher training for non-CRO employees must be given at least once every three years to maintain proficiency (recommended 8 hours). Complaints Resolution Officials (“CROs”), who are your “experts” on the regulation, must receive annual refresher training (recommended 4-6 hours) and new hires should receive training before their employment commences or shortly thereafter. We therefore recommend an 8-hour training each year to meet this requirement. Carriers are also required to maintain records for three years of individual employee training, demonstrating that all persons required to receive initial and refresher training have done so. Training records must be available for DOT review upon request.
DOT’s Ensuring Safe Accommodations for Air Travelers With Disabilities Using Wheelchairs rulemaking also imposed new “hands-on” training requirements such that carriers will be required to ensure employees and contractors providing physical assistance to passengers with disabilities or handling passenger wheelchairs or scooters receive in-depth “hands-on training” no later than June 17, 2026. Any employees or contractors who are hired after June 17, 2026, must complete the required hands-on training before assuming their duties.
We routinely conduct in-person and remote Part 382 training for clients across the globe. If your Part 382 training is not up to date, we would be happy to assist in conducting initial or refresher training for your CROs or other employees as needed to ensure compliance with DOT regulatory requirements.
This Aviation Blog Post is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions, please contact Evelyn Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew Derco at 202.659.6665 or dderco@eckertseamans.com; Samantha Walter at 412.566.1920 or swalter@eckertseamans.com, Tyler Myers at 202.659.6642 or trmyers@eckertseamans.com, or any other attorney at Eckert Seamans with whom you have been working.
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