Part 139 Compliance
How to Prepare for an FAA Part 139 Certification Inspection

To prepare for an FAA Part 139 certification inspection, start with your current approved Airport Certification Manual, connect applicable requirements to supporting records, and review unresolved findings with the people responsible for closing them. Build one indexed package so anyone can pull the ACM section, the dated record, and any open finding without calling the one person who knows the folder.
That sounds straightforward until someone asks for a specific training record or the corrective action behind an inspection finding. The work may be complete, but the record is in another office, an email attachment, or a folder only one person knows how to find.
For airport managers, operations supervisors, and certification leads, preparation means making those connections before inspection day. Here is a practical way to organize the work.
What does a Part 139 certification inspection cover?
The FAA conducts certification inspections to check whether airports holding Airport Operating Certificates meet applicable Part 139 requirements. According to the FAA, these inspections generally happen annually, and unannounced inspections are also possible. FAA inspection overview.
Use the FAA's inspection phases to plan access to people, facilities, and records:
- Pre-inspection review: Airport files and the ACM.
- Management in-brief: Schedule, personnel, and coordination.
- Administrative review: Records, NOTAMs, self-inspection forms, and Airport Master Record information, including FAA Form 5010.
- Movement-area inspection: Physical conditions and airfield operations.
- Aircraft rescue and firefighting review: Response demonstration, training, and equipment.
- Fueling facilities inspection: Facilities and associated records.
- Night inspection: Lighting, markings, and related features when applicable.
- Post-inspection briefing: Findings and correction dates; a Letter of Correction if violations or discrepancies are identified.
Coordinate the actual agenda with your inspector. The FAA identifies nighttime air carrier operations, expected nighttime operations, or an instrument approach as triggers for the night inspection. FAA inspection phases.
Start with the ACM, evidence, and corrective actions
These three parts of inspection readiness answer different questions. Keep them connected throughout preparation.
The ACM: What procedures apply here?
Your Airport Certification Manual describes the procedures, facilities, equipment, and responsibilities used to meet applicable requirements. Its contents depend on the airport's certificate class and applicable FAA authorizations. Start with the current approved version and identify amendments or operational changes that need attention. 14 CFR §139.203.
For manual development guidance, the FAA maintains AC 150/5210-22, Airport Certification Manual.
The evidence: Can we show the work happened?
Evidence connects a procedure to a dated activity. An inspection record, training entry, or maintenance closeout should help explain who did the work, when it happened, and what resulted.
For each applicable requirement, identify the relevant ACM section, the records supporting it, and the period those records cover. Check that records are complete and address the requirement being reviewed. Open the attachments and trace any related finding or corrective action. A document uploaded to a folder still needs that context. Keep missing or unreviewed evidence identified until someone resolves it.
The corrective action: What remains unresolved?
Track each gap with a responsible person, a next step, and a target date. Keep the original finding, current condition, actions taken, interim measures, and closure evidence together. Verify completed work before recording closure, and follow applicable reporting and correction requirements.
For example, an inspection identifies a damaged sign. A useful record connects that finding to the maintenance assignment, any necessary operational response, and the follow-up that verifies the repair. Someone reviewing the package should be able to follow the sequence without reconstructing it from separate conversations.
A practical Part 139 certification inspection prep checklist
Use the three-part framework above to assign the following work to named people. This is an operational preparation checklist. Tailor it to your airport's approved ACM, certificate class, applicable requirements, and inspection coordination.
1. Confirm the documents everyone is working from
- Locate the current approved ACM and its approval and amendment records.
- Confirm that responsible staff can access the applicable procedures.
- Review relevant exemptions, limitations, and approved modifications, including their scope and conditions.
- Identify changes in facilities, operations, or responsibilities that need to be reconciled with the manual.
- Locate related plans and program documents referenced by the ACM, as applicable to your airport.
Keep pending revisions clearly identified so the team can explain which procedures are approved and which changes are still being processed.
2. Review self-inspection and condition records
- Sample records across the review period, including different shifts and inspection types.
- Follow selected findings through their corrective actions.
- Check that condition reports and the relevant NOTAM history can be connected to the conditions they describe.
Section 139.327 requires inspections daily unless the ACM requires otherwise, when unusual conditions affect safe air carrier operations, and immediately after an accident or incident. It also requires inspection records showing conditions found and corrective actions taken. Use those obligations to guide your record review. 14 CFR §139.327.
3. Assemble program records with the people who own them
Have each program lead review the underlying work as well as the paperwork.
| Program | Preparation task | Suggested owner |
|---|---|---|
| Aircraft rescue and firefighting (ARFF) | Check personnel training, live-fire participation, applicable emergency medical training, and equipment readiness. | ARFF lead |
| Fuel safety | Gather tenant fueling-facility inspection records, training confirmations, and corrective-action records. | Fuel compliance lead |
| Personnel qualifications | Match staff responsibilities to the training and qualification records supporting those duties. | Training lead and supervisors |
| Other applicable programs | Identify the plans, reviews, and records tied to your ACM, including emergency planning and wildlife management where applicable. | Certification lead and program owners |
ARFF response, equipment, and personnel requirements are addressed in §139.319. Fueling oversight, inspection records, and training confirmations are addressed in §139.321. Check the requirements relevant to each record instead of applying one training interval or retention period to every program.
4. Inspect the airfield and reconcile open discrepancies
Review pavement, markings, signs, lighting, safety areas, wildlife conditions, vehicle activity, public protection, and wind indicators through your ongoing self-inspection program. The FAA's Airport Safety Self-Inspection guidance provides program guidance and a sample checklist.
Compare what you find with the discrepancy list.
A repaired item needs a clear closeout record.
An unresolved item needs an accurate status, an owner, and the operational response appropriate to the condition.
Address safety issues when identified. Inspection preparation should help the team see outstanding work early enough to act.
5. Build an index and test the handoff
Build the index around the ACM, evidence, and corrective-action connections described above. Name the person responsible for explaining each program.
Then ask someone who did not assemble the package to retrieve several records. If they cannot follow a link, identify the right version, or explain a status, fix that part of the handoff.
Keep a dated, readable copy of the package for the inspection discussion. Record when it was generated so later changes are easy to distinguish.
If the inspection is three weeks away
Three weeks is a planning example, not a standard FAA notice period. Use the time available to establish the current state, resolve priority issues, and make the supporting records accessible.
| Timing | Focus | Concrete output |
|---|---|---|
| Week 1 | Confirm the approved ACM, assign program owners, and inventory evidence and open findings. | One shared index and a prioritized gap list. |
| Week 2 | Resolve gaps that can be closed, retrieve supporting records, and verify completed field work. | Reviewed program records and documented action status. |
| Week 3 | Test record retrieval, coordinate personnel and access, and prepare the management briefing. | A dated inspection package and a clear account of remaining work. |
The airport manager should own the overall preparation effort. The certification lead can maintain the ACM and package index. Operations supervisors, maintenance, ARFF, fueling, and training leads should own their supporting records and actions. At smaller airports, one person may hold several of these responsibilities.
Use the management briefing to explain work that remains open. Handle required reporting and coordination through the applicable procedures. A target date alone does not resolve a finding.
Keep readiness current between FAA inspections
Routine self-inspections keep attention on operating conditions throughout the year. An internal certification-readiness review tests the three-part framework across programs.
Schedule that broader review early enough to work through what it finds. Return to it when responsibilities change, an ACM revision is approved, or a program review reveals a gap.
For records, keep both the working view and a reliable way to produce readable copies. Choose export periods deliberately and check the files before handing them over. Follow the retention rules that apply to each record type. For example, §139.327 specifies at least 12 consecutive calendar months for self-inspection records and 24 consecutive calendar months after completion for training records required by that section. Self-inspection record requirements.
Frequently asked questions
How often does the FAA conduct a Part 139 certification inspection?
The FAA says certification inspections generally occur annually. It may also conduct unannounced inspections. Keep the records and programs current between scheduled visits. FAA overview.
Is the FAA certification inspection the same as a daily self-inspection?
They are separate activities. The FAA evaluates the certificate holder's compliance. The airport conducts its ongoing self-inspection program under §139.327, supported by its approved procedures and applicable guidance. Daylight and nighttime self-inspections belong to that operational program.
Does a completed readiness checklist mean FAA approval?
No. A checklist or software readiness indicator reflects the airport's recorded review state. It does not establish FAA approval or guarantee compliance. The certificate holder remains responsible for its operations, and FAA determinations remain with the FAA.
How Glidepath supports inspection preparation
Glidepath's Certification & ACM inspector package includes the selected period's records and explicit gaps. These workspaces support the preparation:
- Certification & ACM organizes the manual and requirement-based review.
- Certification Self-Inspection supports the airport's internal readiness audit and records its findings and follow-up. The FAA conducts the certification inspection.
- Part 139 Self-Inspections tracks routine findings and maintenance follow-up.
- Records Export provides broader operational archives for retention, turnover, and offline review.
If your team is preparing for a certification inspection, request a Glidepath demo to walk through how your ACM, program records, and open actions can come together in one inspection package.
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