A trainee who spent two weeks attending flight attendant training required by an airline employer who subsequently hired her is not entitled to be paid for that training time under the Fair Labor Standards Act, a federal district court in Seattle rules.

The court applies a six-factor test developed by the Dept. of Labor Wage-Hour Administrator to determine whether the trainees in the program fall under the FLSA’s definition of “employee:” 1) the training, even though it includes actual operation of the facilities of the employer, is similar to that which would be given in a vocational school; 2) the training is for the benefit of the trainees; 3) the trainees do not displace regular employees, but work under close observation; 4) the employer that provides the training derives no immediate advantage from the activities of the trainees; and on occasions his operations may actually be impeded; 5) the trainees are not necessarily entitled to a job at the completion of the training period; and 6) the employer and the trainees understand that the trainees are not entitled to wages for the time spent training. The court finds that all six factors were met when the airline conducted its training, thus the trainee was not an employee and thus was not entitled to be paid for her time. Ulrich v. Alaska Airlines, Inc.