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ICAO Language Proficiency Implementation – Sometimes a great challenge for NAA`s

An example how National Aviation Authorities can adopt and implement ICAO Standards

ICAO St Petersburg 24-26.05.2011

Joachim Wirths – NAA Austria

© WIJ / LSAjoachim.wirths@austrocontrol.atwww.austrocontrol.at

How we did it…

Implementation ofLPT requirementsTraining and assessment procedures

Legal Requirements ?Legal Requirements ?

• ICAO Annex 1 (Personnel Licensing)• ICAO Annex 6 (Operation of Aircraft)• ICAO Annex 11 ( Air Traffic Services)• ICAO Doc 9835 • EC Directive 2006/23 – English Language Requirements for ATCO• JAR-FCL 1 – 1.010 / App 1 + AMC / 1.200 IR

And in Addition…ICAO Resulution A 36-11 / 36 ICAO Assembly 2007 urged those states that could not

comply with language requirements by 05th March 2008 deadline to publish „language proficiency implementation plans“

Transition period should not exceed 05th March 2011 ICAO Circular 318 – Language Testing Criteria for Global Harmonization 2009 ICAO Circular 323 – Guidelines for English Training Programme (EN-L4) EU FCL 055 / AMC 055

Observed facts:

a) About 9377 Pilot licenses....

b) About 315 ATCO licenses

c) About 712 Examiner (FE, TRE, CRE ..)

Challenge:

All pilots minimum L 4 certified…and we have to re- evaluate them until

2012...

Further Facts• Only limited resources available

• No language proficiency experts employed

• Observation made 2008:

Observed harmonization problems between Observed harmonization problems between NAA`sNAA`s

Observed problems of implementation and Observed problems of implementation and Interpretation Interpretation

• Observation made 2009:

ICAO launched Circ 318 /323

Observed adjustment problems because of Observed adjustment problems because of national lawnational law

Increase of harmonization problems Increase of harmonization problems • Due Date 05.03.2011Due Date 05.03.2011

InitialInitialSolutioSolution 2008n 2008PracticaPracticallApproaApproachch

Review Philosophy

• A basic command of plain language is necessary to meet the needs of communication beyond standard phraseology: – in emergencies or unusual situations

– to clarify or elaborate on instructions

– for normal and non-urgent, yet non-standard situations

Iplementation phases 2008 -2011

• Phase 1:

Release of published information 2008/2009 and establishment of implementing procedures including FAQ list via a dynamic approach

• Phase 2: Commitment to use a semi-direct and a direct testing system (interview)

with interactive components included ( ICAO Doc 9835 Ch 6 / Cric 318-3.6)

• Phase 3:

Examiner (LPE) selection, training, testing, authorization (Circ 318/323)• Phase 4:

Soft implementation regulation with credits and practicable timeframe

settings 2009 / 2010• Phase 5:

Establishment of LAB`s for training and testing 2011 (Circ 318 / 323)

PILOTSPILOTS

• 2008 Initial compliance via radio certificate• 2009 Developing and investigation for LP – test implementing

scenarios. • Challenge: „Find a way to implement ICAO requirements with

limited resources!“ (Doc 9835 / Circ 318 / Circ 323)• 2009 Establishment of initial procedures and regulations• 2009 Selection and training for Language Proficiency Examiner• 2010 Language Proficiency Testing is in force• 2011 Language Assessment Bodies established (JAR-FCL 1.010 App 1)

ATCO 2008 - 2011ATCO 2008 - 2011

• LP Training via Austro Control Academy ( Circ 323 )

LP – Test ( Circ 318 )

a) ELPAC (ac. 2006/23/EG)

b) RELTA (ac. 2006/23/EG)

Initial Approach:Different kind of test for ATCO and Pilots

Different procedures established to excecute LP – test

Transition procedure established between ATCO and pilot LP-Test

via an special interview

Established requirements for our Established requirements for our acceptance ofacceptance ofANYANY digital LP – test program on the digital LP – test program on the market:market:Concept:

No commitment for any test provider – performance based acceptance..

• Must be compliant with established legal framework (Circ 318 Ch 4)• Must have realistic contents and scenarios –• Must be easy to use, focus on web based CBT program • Program must include data protection and test result storage system• Program must have an access option for quality control reasons• Examiner must be able to use program and rate matrix to establish a

documented test result by himself• Fast and easy to evaluate the test results in a serious, documented way• Must contain aeroplane and helicopter topics• Must contain an advanced module / EN L 5 + 6• Must have access posibility for second examiner (Q- Reasons)• Must be listed on our NAA / or ICAO acceptance list ( starting 2011 )

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Examiner Assessment - LPE

Examiner

Examiner must receive an initial assessment with a SEN. This shall be done via the recurrent examiner assessment, followed by a special LPE training course,Involving a LP examination via digital, interactive test to confirm the personalLPE Skill and at least requested additional LPE authorization!

Qualify pre assessed examiners…Qualify pre assessed examiners…

LPE Selection ,Training, LPE Selection ,Training, AuthorizationAuthorization

• Active and experienced Flight Examiner

• Pre-selection passed

• LP Examiner training

• LP test passed

• Initial LPE authorization

• Rater Training passed

[ Reference Cricular 318]

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LPT

Pilots

The authorized LPE will perform the LP Test with the candidate -digital test and interview- [semi – direct and direct testing Circ. 318 3.6)

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Failed

FailedL4

Should perform a LPT with the same examiner / LPE OR has to approach a language assessment body / AMC No 2 FCL 1.010!

AMC No 2 JAR FCL 1.010 (4) AMC No 2 JAR FCL 1.010 (4) LABLAB

CRITERIA FOR THE ACCEPTABILITY OF LANGUAGE ASSESSMENT BODIES

A language assessment body offering services on behalf of the Authority (see Appendix 1 to JARFCL 1.010 paragraph 5) should meet the specifications at paragraphs 14 to 18.

In order to ensure an impartial assessment process, the language assessment should be independent of the language training.

In order to be accepted, the language assessment bodies should demonstrate:

• a) appropriate management and staffing, and

• b) quality system established and maintained to ensure compliance with, and adequacy of assessment requirements, standards and procedures.

In addition:• Must employ minimum one linguistic expert and one operative expert / Examiner Level 6

[ Circular. 318 / 323]

Language Assessment Language Assessment BodyBody

• FTO`s

• TRTO`s

• Aviation companies

and

• Other organizations…

Audit criteria: ICAO Circ 323 and 318

ACG will audit and observe!

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Just NO

I don’t want..

Must perform an interview test with an examiner / LPE GERMAN Level 4,5,6 will be endorsed in JAR-FCL license..[ICAO Annex 1 ]

Action Action taken by taken by EU EU CommissioCommissionn

SAFA

SAFA - CAT Findings SAFA - CAT Findings – Related to ICAO Member States noted on F-– Related to ICAO Member States noted on F-

SIX Web SiteSIX Web Site

• CAT 2 no compliance but Action Plan• CAT 3 no compliance and no Action Plan established• CAT G proper endorsement in license and observed no

proficiency to speak and understand English

in accordance with the ICAO Scale / LEVEL 4

This may lead us to a training for SAFA Inspectors in This may lead us to a training for SAFA Inspectors in the future…the future…

Consequence AIP 05/11

SAFA inspector`s duty

• Checking FSIX Web Site• Checking country status of aircraft and crew inspected• Checking compliance with entry and SAFA requirements• Raise findings• Take action accordingly….

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INTOLERABLE

Aircraft will leave with a CREW probably not able to speak or understand Aviation English at the proficiency level required by state (AIP- ICAO EN L 4)

Consequence high risk of a serious on GND or in FLT incident or accident. Further high cost and reclaim by operator, if blocking the aircraft for longer period of time. Probably legal action by the operator

Probability of incident / accident 80-90 %Probability of legal action by operator 100 %

Accept the Risk

Hazard Identification

Risk Assessment Severity / Criticality

Risk Assessment Probability

Risk Assessment Acceptability

Take Action Risk Mitigation

not acceptableacceptable

Process of SAFA LP / G- Finding Risk Management

Clarify situation with an accepted LP Competence check to keep delay at a minimum or have proven evidence in case of legal action later on.

SAFA EN L 4 Competence CheckSAFA EN L 4 Competence Check(RMK: This is not an LPT!)

Trigger:Trigger: SAFA Inspector is unable to communicate with the pilot /

crew during inspection or an ATC incident was evident during arrival of aircraft

Finding:Finding:SAFA „G“ finding is considerd as initially

„NOT ACCEPTABLE RISK“ in regard to SSP and AIP!

Consequence:Consequence:Crew must be changed, or must demonstrate EN L 4

competence prior release of aircraft

SAFA „G“ Finding - RISK SAFA „G“ Finding - RISK MANAGEMENTMANAGEMENT

Objective:Objective: Changing risk to the tolerable / acceptable level Documented decision process

- Adressing the finding to the crew

- Offering solution to clarify the situation

by using a digital

SAFA - LP L 4 Competence Check Procedure

to avoid any further delay in excess of 1 hour

- If pilot / crew agrees, SAFA Inspector will launch a digital test as trained interlocutor,

and will select one authorized LPE from the official LPE list

- Inspector will release the LPC access code to the LPE

- LPE will rate the competence of pilot / crew as an expert

Result:Result: Clear basis for GO / NOGO decision

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The ALARP Principle

Intolerable Region

ALARP or Tolerable

Region

Acceptable Region

• Risk is unacceptable at this level• Risk cannot be justified

• Risk is undertaken only if a benefit is desired• Tolerable only if further risk reduction is impracticable

or if its cost is grossly disproportionate to the improvement gained cost / benefit analysis

• Maintain safety assurance that risk remains at this level

ALARP = As low as reasonably practicable

Negligible risk

Risk

Source: ICAO Safety Management Manual / Doc 9859 / § 4.2

Related Links onAustro Control Web Site• ICAO FSIX Web Site http://www.icao.int/fsix/lp.cfm

• List of LPEs in Austriahttp://www.austrocontrol.at/en/Images/DC_LFA_PEL_051_tcm586-75855.pdf

• Examination formhttp://www.austrocontrol.at/Images/FO_LFA_PEL_194_tcm586-75663.pdf

• Official Announcement / Austro Controlhttp://www.austrocontrol.at/Images/DC_LFA_PEL_056_tcm586-77845.pdf

– available in German Language only

• FAQ`s http://www.austrocontrol.at/content/lfa/FAQ/faq_lpe/faq_lpe.shtml

• Flight Examiners Handbook – containing national information in addition to those provided by the FEM (v.18, JAA) including LPEhttp://www.austrocontrol.at/Images/HB_LSA_PEL_002_IN_tcm586-77995.pdf

• List of accepted Language Proficiency Test – Testproviders http://www.austrocontrol.at/Images/DC_LFA_PEL_065_tcm586-78362.pdf

Outlook• We will continue to develop the system together!

(..with test providers / LPE`s, PILOTS, ATCO´s, ATO´s, AOC holder ect...)

• We would like to harmonize and to develop our system with other NAA`s (sharing exp)

What should we discuss?What should we discuss?

• A mutual recognition for LPT results between all member states compliant noted on the ICAO FSIX web site……

• ICAO Doc 9835 and Circular 318 / 323 should be free of charge• LPT test provider - Quality Good List established on ICAO

homepage• Test standards (p.e. no LPT during LPC/OPC Sim Session)

• Test for maintenance personnel (reading, writing?)

• Test for dispatch, meterological –AIS- personnel • Test for cabin crews – (EASA License req. 2012)• Test recomondation for national licenses (ML/UL ect)

30LSA Jour Fix, 4 März 2011, Ing. Franz Graser

Thank you for your attentionThank you for your attention

Joachim Wirths - Manager PELjoachim.wirths@austrocontrol.at