A former senior FAA official is asking the FAA to revise Parts 121 and 135 to require human trafficking recognition and response training for certain airline and charter employees — training he says Congress already directed but that has not been built into the regulatory and oversight structure operators typically follow.
David Downey, who previously led the FAA’s Rotorcraft Directorate in Fort Worth, said his interest sharpened during the COVID-19 era as he tried to understand how trafficking could occur through aviation without obvious border-crossing markers.
“This was during COVID, when the whole Jeffrey Epstein thing popped, and I wondered, ‘How does somebody fly people extraterritorially? There’s no passports and there’s no customs,’” he said. “So I started looking into it, and the answer was he never left the United States. He flew international airspace, but he flew from the U.S. to the U.S. Virgin Islands.”
Downey submitted a petition for rulemaking Jan. 2. The FAA acknowledged receipt Jan. 7 and assigned it Docket No. FAA-2026-0038, telling Downey the agency expects the decision to take longer than 120 days.
His argument is less about new training content around human trafficking and more about making existing requirements visible and verifiable within the FAA regulatory environment.
What Downey Says Is Missing
Downey points to federal statutes that call for human trafficking awareness training for flight attendants and certain customer-facing airline personnel. The FAA issued an Information for Operators bulletin, InFO 19002, to alert operators to those statutory requirements and to point them to existing training resources. But Downey said the practical result has been uneven awareness and little, if any, structured FAA follow-through.
He said an aviation attorney pushed him to focus on what the law actually says about the human trafficking training and who it’s written to.
“She sent me back a note and said, ‘Dave, you have to read the law,’” Downey said. “The law says it’s written to carriers, not to the FAA. I showed it to a former FAA air carrier inspector who used to be in Washington, and he read it and he goes, ‘I didn’t discern that it wasn’t to the FAA, even if it says carriers.’ So what’s happened is the FAA’s done nothing.”
In his view, that has allowed the issue to sit in a gray space.
“There is no rule. There’s no op spec. It’s not in the 8900,” he said, referring to an FAA policy handbook. “So it’s just a gaping hole and everybody thinks because this InFO is out there that something’s being done.”
He said he has pressed the point directly with operators.
“When I’m at Verticon or HAI or other things, I’ll talk to DOs or chief pilots and go, ‘Hey, do you guys know about this?’” Downey said. “And they rarely do.”
A Measurable Impact
Downey said DHS estimates aviation accounts for a measurable share of human trafficking activity.
“The presentation that was done by Sean Burnett from DHS … they estimate that it’s probably about 7% to 8% of all human trafficking is done through aviation,” he said, adding, “If you stop 7%, you stop 7%. That’s still huge.”
From there, he said, he gravitated toward the practical question of who in the aviation system is most likely to notice something that does not look right; not just in a cabin, but on the ground.
“At smaller airports … it’s the ramp rats. It’s the people putting gas in there, servicing the lavs, catering, mechanics at the FBO — they see everything that goes on there,” Downey said.
He described his view as adding awareness where people already have eyes on the operation.
“If you’re sitting in the FBO and you’re aware that you need to be paying attention to this and you see something that looks a little unforward, you can just pick up the phone and make a call.”
What Training Looks Like in Practice
Downey said he is not proposing an elaborate curriculum. He repeatedly returned to the idea that the content already exists and can be delivered without major disruption.
“It’s all in how the FAA writes the op spec,” he said. “And again, it’s a 15-minute video. I mean, it’s not like you’ve got to go away for eight days on a type rating.”
He also emphasized that reporting, in his telling, is designed to be simple for aviation employees who may not know what to do in the moment when they think they see signs of human trafficking.
“The two program managers I’ve talked to at DOT and DHS have said if somebody suspects something on an airplane, all they need to do is report the carrier, the flight number and the seat number,” Downey said. “They’ll take it from there. You don’t have to do anything. They have a whole bevy of people that can go research that.”
Downey said he has heard variations of the same concern from frontline airline workers.
“Just talking to flight attendants, they’re like, ‘I think I’ve seen it, but I didn’t know what to do.’”
What Comes Next
Downey said he expects the next meaningful step would be the FAA opening the door to public comment if it decides to move forward.
“I’m hopeful that they would give us at least a 60-day comment period so that it could get through the news cycle two or three times,” he said, while also acknowledging how timing can vary. “But having been at the agency, if you don’t want a lot of work, you make it a very short comment period.”
He framed the goal as human trafficking awareness paired with a clear, standardized place in FAA oversight rather than a niche effort that only a limited set of operators encounter.
“We’re supposed to have done this. The training material already exists,” Downey said. “We need the rule changed.”
I’m so glad we’ve solved the FAA’s backlog of all the trivial things like signing off already completed checks like check airmen, aircraft conformance, approved Ops specs, etc, etc. so we can hound them about operators watching a 15 min video. So glad they had the time to pore thru FSIMS/8900-- how about someone take a look at WebOps and post the dwell times of the existing things the FAA can’t seem to get done in a reasonable amount of time.