Q: Does an AMTS need to keep every test issued to every student of every class offered for the two year record limit?
A: No. As provided for in § 147.33(a)(1), each AMTS "shall keep a current record of each student enrolled, showing attendance, tests, and grades..." On its face, the language does not require filing each and every test for every student, only that it is recorded. Filing every test would require lots of physical or data storage space. Plus, now in our technological world many schools provide computerized knowledge testing, just like the FAA through commercial testing centers where only the "grade earned" is the record. Of course, if an FAA Inspector doing surveillance over a particular grade issued to a student for a specific test given, the AMTS should be able to provide a sample of that test.
This position is supported in the language of AC 147-3B, paragraph 3-4 entitled Records, Transcripts, and Graduation Certificates, which states that "records must clearly show attendance, tests, quizzes,http://fsims.faa.gov/PICDetail.aspx?docId=8900.1,Vol.6,Ch10,Sec1 and practical projects grades received on subjects required" (emphasis added) and in 8900.1, Vol. 6, Ch. 10, Sec. 1, paragraph (c), which also speaks to the recording of grades, not filing or storing individual student's tests.
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