Training Implementation Policy - EASA · Working Methods ... Failure of the crew to follow the...

Page | 1

Training Implementation Policy

EASp Action SYS 5.5

October 2013

Implementation Pilot Training Group (IPTG)

Sub-Group of the

EASA Internal Group on Personnel Training (IGPT)

EASp Action SYS 5.5 “Training Implementation Policy”. Action performed by a sub-group of the EASA Internal Group on Pilot Training. Action leader: Georges Rebender, EASA Approvals and Standardisation Directorate. [email protected].

of 21

Page intentionally left blank

mailto:[email protected]


of 21

Contents Objectives ....................................................................................................................................................... 5

EASp.......................................................................................................................................................................... 5

IGPT .......................................................................................................................................................................... 5

IPTG .......................................................................................................................................................................... 5

Working Methods .................................................................................................................................................... 6

Overview of the nine Training Implementation Issues ............................................................................................ 9

Top nine analysis: priorities, actions across the 3 EASp pillars ..........................................................................10

Issue 1:.................................................................................................................................................................... 10

<< Lack of common European Inspectors’ Training Standards. The inspector initial training varies from 1 week

classroom delivery to a 5 week training course followed by OJT and testing.>> .................................................. 10

Issue 2:.................................................................................................................................................................... 11

<<Significant differences in the NAA oversight practices for LIFUS “line flying supervisors” & “line checkers” are

leading to a wide variation in the individual skill sets within this group of pilots .>> ........................................... 11

Issue 3:.................................................................................................................................................................... 12

<< Although holding an instructor (SFI/TRI) qualification, many SFEs/TREs lack appropriate basic instructional

experience. As a result, they do not always possess sufficient skills on detecting the root cause of poor

performance (e.g. lack of basic airmanship) by the airline pilot under check. As a consequence, although they

are capable of assessing correctly a failed item in a check/test they are not always well placed to give

appropriate guidance for effective remedial training .>> ...................................................................................... 12

Issue 4:.................................................................................................................................................................... 14

<< Lack of robustness of the pilot training, testing/checking processes: .............................................................. 14

1. Training/checking is often not optimally integrated into an airline’s risk management system. Several

accidents point towards this direction. >> ......................................................................................................... 14

2. When training is combined with the checking programme, there is an imbalance of time spent on

checking to the detriment of the time available for training. >> ....................................................................... 14

Issue 5:.................................................................................................................................................................... 15

<< Lack of adequate SOPs and non-adherence to them ........................................................................................ 15

1. Inadequate /lack of robust SOPS for the type of operation.>> ................................................................. 15

2. Failure of the crew to follow the company SOPs. >> ................................................................................. 16

Issue 6:.................................................................................................................................................................... 17

<< TRI/TRE/SFI/SFE that does not belong to the airline of the pilot under training/checking is not familiar with

company SOPs; this situation is exacerbated amongst business aircraft type operators as some ATOs outside

Europe will not dry lease their simulators. >> ....................................................................................................... 17



of 21

Issue 7:.................................................................................................................................................................... 18

<< There is no standard guidance to operate single pilot certified aeroplanes in CAT multi crew environment

(SOPs, task sharing versus cockpit configuration). >> ............................................................................................ 18

Issue 8:.................................................................................................................................................................... 19

<< ‘‘Gross error’’ check: erosion of the ability to discriminate the essential data inputs (e.g. V speeds, take-off

weight, fuel usage, thrust/speed ratio vs. aircraft configuration, flight parameters, etc.) on the flight deck into

an overall assessment of whether or not the various parameters have the appropriate magnitude. This is in

particular to avoid overreliance on automated systems. >> ................................................................................. 19

Issue 9:.................................................................................................................................................................... 20

<< Lack of effective consideration of the pilot’s previous experience during conversion courses. One size does

not fit all!>> ............................................................................................................................................................ 20

Conclusion .....................................................................................................................................................20

Work facilitated by Michel Masson, Executive Directorate, IGPT Coordinator.



of 21

Objectives

EASp

In 2011, EASA published the first edition of the European Aviation Safety Plan

(EASp) for the period 2011-2014. EASp was based on the top 5 safety concerns provided

by the Member States in early 2010. All responses were placed into one of the following

areas:

1. Operational issues (runway excursions, CFIT, Loss of Control, etc.);

2. Systemic issues (implementation of SSP, SMS, development of Performance

Indicators, etc.);

3. Emerging issues: covering safety issues derived from operations or

regulations that have not been fully deployed and where data are not always

available;

4. Human Factors and Performance, which affect all of the above areas.

For each area there is an action list with the activities that are proposed to address the

subject safety issues. The Systemic issues part of EASp includes the Development of a

Training Implementation Policy (EASp 2013-2016: SYS5.5).

IGPT

The Agency’s Internal Group on Personnel Training (IGPT) has been established to

follow on from the work of the EASA International Conference on Pilot Training, which

took place on 29th November 2009. The IGPT’s first meeting took place on 27th January

2010. Building on proven internal expertise and competencies, the IGPT bridges Design,

Certification, Training and Operations by creating a forum to address training within the

Agency and delivering the Agency’s official position on the subject. The IGPT is composed

of experts from all operational Directorates and adopts a total system approach in

training based on the three pillars: Rulemaking, Oversight and Safety Promotion.

IPTG

The IGPT set up a sub group, the Implementation Pilot Training Group (IPTG). The

IPTG focussed on the development of a Training Implementation Policy, referenced in the

EASp as Action SYS5.5:



of 21

<< To reduce differences in training implementation in Europe, there is a need to

improve oversight at Member States’ and EASA levels, and the Agency should reinforce

standardisation with regard to Flight Crew Licensing and training related aspects of

Operations. Appropriate training implementation measures are needed so that training is

enhanced and does not result in lowering training and safety standards. The resulting

Training Implementation Policy will address the implementation of rules regarding

training, testing and checking. It will also provide recommendations for improving the

implementation of rules or the rules themselves >>.

In June 2012 the IPTG organised a workshop to address the 9 most significant

training implementation issues.

Some topics have already been covered by other EASp components or initiatives

and are not included in this report (e.g. LOCART).

The workshop was an interactive forum that intended to capture best practices

and current issues regarding NAA oversight. It addressed all flight crew

training/checking/testing issues, both FCL and Ops related.

Working Methods

As a first step, the IPTG analysed the lessons learnt from both Air Operations and FCL

standardisation visits. A list of top 9 issues was compiled, by the Standardisation

Directorate with input from the NAAs. It was then decided to cross fertilise those

emerging items with the help of NAA Ops and FCL experts.

As a second step, the draft top issue list was send to all FCL and Ops national

coordinators for comments. No additional items were suggested.

The third step was to run an interactive workshop with all available NAA Ops and FCL

experts. The participants were requested to discuss all issues and suggest for each of

them priorities and solutions. These encompassed Best Practise/Safety Promotion,

Oversight and Rulemaking (EASp pillars).

For each of the items:

The experts were introduced to the matter through a short EASA presentation

focusing on the key factors.



of 21

Participants were proactive in contributing ideas (level of priority, actions

suggested along the 3 EASp dimensions: Best practices/Safety promotion,

Oversight and Rulemaking).

Extensive use was also made of a web-based feedback form (shown on the next

page).

The fourth step was the creation of this document: providing IPTG’s in-depth analysis and

recommendations regarding proportionate and consistent use of the 3 EASp dimensions.



of 21

EASA Workshop on Training Implementation Issues: Cologne, 27th June 2012



of 21

Overview of the nine Training Implementation Issues

Issue #1

Lack of common European Inspectors’ Training Standards. The inspector initial training varies from 1 week classroom delivery to a 5 week training course followed by OJT and testing.

Issue #2

Significant differences in the acceptance criteria for LIFUS “line flying supervisors” & “line checkers” leading to a wide variation in the individual skill sets within this group of pilots.

Issue #3

Although holding an instructor (SFI/TRI) qualification, many SFEs/TREs lack appropriate basic instructional experience. As a result, they do not always possess sufficient skills on detecting the root cause of poor performance (e.g. lack of basic airmanship) by the airline pilot under check. As a consequence, although they are capable of assessing correctly a failed item in a check/test they are not always well placed to give appropriate guidance for effective remedial training.

Issue #4

Lack of robustness of the pilot training, testing/checking processes: 1. Training/checking is often not optimally integrated into an airline’s risk management system. Several accidents point towards this direction. 2. When training is combined with the checking programme, there is an imbalance of time spent on checking to the detriment of the time available for training.

Issue #5

Lack of adequate SOPs and non-adherence to them : 1. Inadequate /lack of robust SOPS for the type of operation. 2. Failure of the crew to follow the company SOPs.

Issue #6

TRI/TRE/SFI/SFE that does not belong to the airline of the pilot under training/checking is not familiar with company SOPs; this situation is exacerbated amongst business aircraft type operators as some ATOs outside Europe will not dry lease their simulators.

Issue#7 There is no standard guidance to operate single pilot certified aeroplanes in CAT multi-crew environment (SOPs, task sharing versus cockpit configuration).

Issue #8

‘‘Gross error’’ check: erosion of the ability to discriminate the essential data inputs (e.g. V speeds, take-off weight, fuel usage, thrust/speed ratio vs. aircraft configuration, flight parameters, etc.) on the flight deck into an overall assessment of whether or not the various parameters have the appropriate magnitude. This is in particular to avoid over-reliance on automated systems.

Issue #9

Lack of effective consideration of the pilot’s previous experience during conversion courses. One size does not fit all!



of 21

Top nine analysis: priorities, actions across the 3 EASp pillars

Issue 1:

<< Lack of common European Inspectors’ Training Standards. The inspector initial

training varies from 1 week classroom delivery to a 5 week training course followed by

OJT and testing.>>

In Europe, unlike the US for example, there is no uniform OPS/FCL inspectors’ training

standard. Instead, there is considerable variation of OPS/FCL inspectors training. Some

States offer programmes ranging from 1 week classroom with no OJT and no testing,

while other States require a 5 week training course, including OJT and testing.

Although the Implementing Rules describe a comprehensive training programme for

ramp inspectors (ARO.RAMP), the rules do not provide equivalent, detailed training

programmes for OPS or FCL inspectors.

There was unanimous consensus for:

Minimum entry requirements (as per Doc 8335) + effective training and testing =

inspector competence.

Developing standardised minimum entry criteria for applicants seeking to become

an Ops or FCL inspector. In addition, for standardised pan-European integrated

inspector training syllabi (theoretical, on-the-job and testing) leading to a European

inspector licence/qualification that could be recognised and valid across Europe.

Summary:

The range of actions and directions for future work that are identified are strongly

supported by the Member State experts that attended the workshop:

establishing minimum entry requirements for applicants to become inspectors

(OPS and FCL), set at the pan-European level

setting out standard European syllabi for training and testing of inspectors.

A central training body, equivalent to the US inspectors’ system is an option, which was

supported by some participants.

Possible directions for future developments include:

Develop for OPS and FCL inspectors standardised minimum entry criteria.



of 21

Develop pan-European integrated inspector training syllabi (theoretical, on-the-job

and testing).

Decide what should be the qualification level (e.g. license, qualification) which

could be pooled across Europe.

Consider establishing a central training body.

Issue 2:

<<Significant differences in the NAA oversight practices for LIFUS “line flying

supervisors” & “line checkers” are leading to a wide variation in the individual skill sets

within this group of pilots .>>

Note:

“Line flying supervisors” are pilots supervising new entrant type rated pilots to

carry into practice the Operator’s procedures and techniques with which they

have been made familiar during the conversion course

“Line checkers” assess of a pilot’s competence to perform a safe and efficient flight

in order to be released for unsupervised duties at the end of the conversion

course.

The workshop participants agreed that the quality of LIFUS and the line checks performed

by an airline are key risk mitigation issues and should have high priority.

Related to this, during Standardisation visits, the majority of the OPS Manuals sampled

indicate that this is a weak area. The CRM assessment methodology was not described

and so adequate training to the task could not be found. The Line checker must be

trained in the process of observing, recording, interpreting crew member’s performance ,

knowledge and behaviour (observable, repetitive behaviours that contribute to a

technical failure).

During the workshop the case of pilots contracted for a limited period to act as Line

supervisors/checkers without an adequate framework has been highlighted as potential

issue.



of 21

There is no European requirement for a competent authority to directly monitor Line

checking activities, even though there is an ICAO SARP (Doc 8335) requirement regarding

the oversight of all checking personnel.

Summary:

The workshop identified the need to introduce more guidance for operators on training

of line supervisors/checkers including pilots contracted for a limited period and more

guidance for NAAs consistent with ICAO Doc 8335’s conceptual approach.


NAA oversight of Line Checkers in line with the provisions in ICAO Doc 8335 (as line

checks are considered to be checking personnel by ICAO)

GM to ensure uniform interpretation of the methodology for assessing CRM skills

Investigate in more detail how to better address the case of free-lance pilots.

Issue 3:

<< Although holding an instructor (SFI/TRI) qualification, many SFEs/TREs lack

appropriate basic instructional experience. As a result, they do not always possess

sufficient skills on detecting the root cause of poor performance (e.g. lack of basic

airmanship) by the airline pilot under check. As a consequence, although they are

capable of assessing correctly a failed item in a check/test they are not always well

placed to give appropriate guidance for effective remedial training .>>

The workshop audience agreed on the importance of this issue. A pilot’s ability to revert

to basic skills is a safety factor of utmost importance when facing suddenly degraded

operational situations.

Type rating courses are intended to introduce a licence holder (competent pilot) to the

specific systems and possible unique handling qualities of a new aircraft.

Type rating courses were never intended to provide trainees with basic handling skills

and decision-making skills. These should have been put in place during earlier training

programmes. However, this is often found not to be the case.



of 21

As a result SFI/TRI/SFE/TREs are being asked to remedy deficiencies in basic aircraft

handling and decision making skills of trainee pilots. However this is a task for which they

have not been trained.

This issue might be solved with complementary solutions.

The first is to review initial training programmes (ab-initio) so that trainees attending a

first type rating course cover basic handling and decision-making skills in more detail than

is currently the case.

The second is the establishment of a task force to:

• Analyse in depth the abilities and skills that all varieties of instructors/examiners

should have;

• Redefine the prerequisites (qualification/experience) and

• Review the training courses for instructors/examiners.

The above should not be considered in isolation from each other but as a holistic

solution.

Summary:

Although holding an instructor (SFI/TRI) qualification, many SFE/TREs lack appropriate

basic instructional experience. As a result, the root causes of poor performance and

guidance for remedial training may not be adequately addressed. A change of instructor

training paradigm is therefore proposed.


Review initial training programmes (ab-initio) for a first type rating course,

devoting more attention on basic handling and decision-making skills

Establish an expert task force to:

Analyse in depth the abilities and skills that all varieties of

instructors/examiners should have;

Redefine the prerequisites (qualification/experience) and

Review the training courses for instructors/examiners



of 21

Issue 4:

<< Lack of robustness of the pilot training, testing/checking processes:

1. Training/checking is often not optimally integrated into an airline’s risk

management system. Several accidents point towards this direction. >>

An Operator’s crew training/checking records should be part of a confidential crew

performance enhancement process. There should be feedback into the airline’s training

programme and the process should be integrated within the SMS.

The NAA’s certification and oversight of the Operator should ensure that the SMS is

effective in addressing the adequacy of the initial type rating, conversion and recurrent

training programmes.

2. When training is combined with the checking programme, there is an imbalance

of time spent on checking to the detriment of the time available for training. >>

The existing annual CAT flight crew recurrent checking programme includes one Licence

Proficiency Check (LPC) and two Operator Proficiency Checks (OPC). The LPC may be

combined with the OPC. The minimum required time for an LPC is 2 hours per applicant

(total 4 hours for a two man crew).

In addition the annual recurrent training programme includes aircraft/FSTD training,

which shall be established such that all major failures of aircraft systems and associated

procedures will have been covered in a 3 year cycle. This training may be combined with

the OPC. There is also a need for additional training for specialised operations such as All

Weather Operations, steep approaches etc.

It should be noted that flying training should be structured and sufficiently

comprehensive to familiarise the flight crew member thoroughly with all aspects of

limitations, normal, abnormal and emergency procedures associated with the AFM.

The combination of these mandatory requirements (LPC, OPC, training for specialised

operations, systems failures etc.) are extremely difficult to achieve effectively within the

absolute minimum allowed time. The time needed to complete these items does not

allow the flexibility to include the ‘value added’ training covering issues such as

unexpected events, mitigation against risks identified via the SMS etc.

Workshop participants proposed to increase the minimum time available for recurrent

training and to separate the training from the checking.



of 21

The establishment of a task force to review the flight crew’s aircraft/FSTD recurrent

training and checking requirements/contents is recommended.

Summary:

The minimum time required for mandatory training elements is too short to effectively

cover these elements. There is no flexibility to include ‘value-added’ items on e.g.

unexpected events, risk mitigation established via the SMS. When training is combined

with the checking programme, too little time is available for training.

Effective integration of training/checking into an airline’s risk management system is an

issue, as indicated in the investigation of several accidents.


Establishing a confidential crew performance enhancement process, including

trainee feedback forms and feedback to the airline training programme.

The NAA certification and oversight of the Operator should ensure that the SMS is

effective in addressing the adequacy of the initial type rating, conversion and

recurrent training programmes.

Establishing a task force to review the flight crew aircraft/FSTD recurrent training

and checking requirements/contents is recommended.

Issue 5:

<< Lack of adequate SOPs and non-adherence to them

1. Inadequate /lack of robust SOPS for the type of operation.>>

The NAA should ensure that the contents of each CAT operator’s SOPs are adequate for

the type of operation and respect human factors principles.

Operators should consider all relevant feedback in order to continuously enhance their

SOPs.

The role of manufacturers in regard to SOPs, in conjunction with the OEB, should be

further clarified.



of 21

A task force should be established to prepare guidelines for typical items to be

considered when preparing SOPs (crew departures / approach / specialised ops briefings,

use of automation, fuel monitoring, etc.).

2. Failure of the crew to follow the company SOPs. >>

In a significant number of serious incidents and accidents, non-adherence to SOPs has

been mentioned as a contributing factor. The importance of following SOPs is not always

fully understood by crew.

Best practice suggested: Airlines should recognise this subject as important. Internal

safety promotion campaigns should be used to increase the awareness of pilots, TRE and

line checkers. Testing on SOPs should systematically take place during OPCs and Line

Checks.

Oversight performed by NAAs: enhance the oversight of designated examiners

(CRE/TRE/Line checkers) by conducting enough audits/inspections of those persons. This

should include unannounced checks as per Parts ARA/ARO.

Summary:

The proper adherence to SOPs can be improved by airlines running a variety of

promotion campaigns, thereby increasing the awareness of pilots, TRE and line checkers.

Sufficient testing, audits and inspection of the SOP contents and awareness should be

ensured and required by the NAA.

The robustness of SOPs in regard of the type of operation is an area for improvement and

would need to be discussed with stakeholders


Increase awareness of pilots, CRE/TREs and Line Checkers on the importance of

following SOPs.

Reinforced NAA oversight of designated examiners (CRE/TRE/Line Checkers), to

ensure sufficient audits/inspections of those persons, including unannounced

checks as per Parts ARA/ARO.

NAAs to ensure that the contents of a CAT operator’s SOPs are adequate for the

type of operation and respect human factors principles.



of 21

Issue 6:

<< TRI/TRE/SFI/SFE that does not belong to the airline of the pilot under

training/checking is not familiar with company SOPs; this situation is exacerbated

amongst business aircraft type operators as some ATOs outside Europe will not dry

lease their simulators. >>

The workshop identified this issue as very important. Some business jet type CAT

operators are at the edge of negative training (training in procedures not in use by the

Operator). Due to unbearable and unjustified wet lease costs by some ATOs the

Operators revert simply to training on the aircraft rather than on an FSTD. This therefore

reduces the effectiveness of training and adversely affects safety standards (e.g. inability

to simulate emergency scenarios in a real aircraft).

In all cases ATO instructors/examiners should be adequately familiarised with airline

procedures so that trainees can be trained effectively.

Non-EU ATOs should make sure that the ATO training manual and SMS risk assessment

properly reflect these safety principles.

Summary:

It should be ensured that CAT operators, especially those of business jet types, are not at

risk of conducting negative training (training in procedures not in use by the Operator).

In all cases ATO instructors/examiners should be adequately familiarised with airline

procedures so that trainees can be trained effectively.

The EU system has to be made aware of this potential safety case and the distortion of

the market.

When EASA is approving 3rd country ATOs, EASA should make sure that the 3rd country

ATO’s training manual and SMS risk assessment ensure no negative training.


The NAA certifying and overseeing the Operator should ensure that the training is

provided (either within or beyond Europe) according to the Operator’s manuals



of 21

Issue 7:

<< There is no standard guidance to operate single pilot certified aeroplanes in CAT

multi crew environment (SOPs, task sharing versus cockpit configuration). >>

There is a lack of:

SOPs for multi pilot operation in single pilot certificated aeroplanes.

Guidance on such procedures for either the operator or its NAA.

OEB recommendations encompassing multi pilot activity in a single pilot

certificated aircraft, in particular the Single Pilot High Performance Complex

aircraft types.

The workshop identified this issue as important; such CAT operations are not uncommon

and regulatory guidance is currently lacking.

Both rules and guidance material for Aircrew and Ops should be reviewed together to

better cover all aspects of single pilot aeroplanes operated by a 2 man crew (AMC/GM on

SOPs and training policy).

Guidance should also be drafted to assist the activities of the OSD teams when assessing

new aircraft classes/types, in particular for single pilot high performance aeroplanes.


Establish a task force to review rules and guidance material for Aircrew and Ops, to

better cover all aspects of single pilot aeroplanes operated by a 2 man crew

(AMC/GM on SOPs and training policy. Accountability of the OSD/OEB in the

process.

As a follow-up, issue GM for NAAs and operators.



of 21

Issue 8:

<< ‘‘Gross error’’ check: erosion of the ability to discriminate the essential data inputs

(e.g. V speeds, take-off weight, fuel usage, thrust/speed ratio vs. aircraft configuration,

flight parameters, etc.) on the flight deck into an overall assessment of whether or not

the various parameters have the appropriate magnitude. This is in particular to avoid

overreliance on automated systems. >>

Recent accident reports show that there is an erosion of the crew’s ability to critically

evaluate essential data, in particular for data processed electronically (e.g. V speeds,

take-off weight, fuel usage, thrust/speed ratio vs. aircraft configuration, flight

parameters, etc.). In addition, the crew’s ability to assess whether or not these essential

parameters have an appropriate magnitude is diminishing.

This is of particular importance in a highly automated cockpit environment. Most pilots

would understand this ability in the context of “basic airmanship”. However the basic

airmanship skills are not automatically acquired but must be taught from the beginning

of a pilot’s education and continuously reinforced during his/her piloting career. This can

best be supported by scenario-based training in the initial and recurrent training

procedures.

In addition, when developing SOPs, attention should be given to ensure that they address

all relevant aspects of airmanship.

Summary:

This issue shall be addressed in all phases of pilot education and supported by scenario-

based training. The NAAs propose to oversee the operators’ procedures on gross error

checking. Human factors orientation is essential.

SOPs shall be carefully tailored and consider all aspects of airmanship.


Introduce into the training cycle risk mitigation against gross errors.

Establish a multi-disciplinary task force on OPS / Aircrew, looking at human factors.



of 21

Issue 9:

<< Lack of effective consideration of the pilot’s previous experience during conversion

courses. One size does not fit all!>>

The workshop identified that conversion and type courses should consider all aspects of

the pilot’s previous experience. It is recommended that this take the form of a “Gap

analysis” between his/her previous experience and the competencies required to

operate the new type in the particular airline environment.

Typical considerations would be:

change from “fly by wire” to aircraft with conventional controls (trimming!)

EFIS to analogue instrument displays (acquire/reacquire selective radial scan)

analogue to EFIS instrument displays (increased opportunities to select incorrect

settings)

turbo-prop to jet conversion (engine handling, compressibility issues etc.)

jet to turbo-prop conversion (e.g. icing vulnerability is much greater)

The above list is not considered exhaustive or complete but merely serves to show some

of the possibilities that need to be considered.

Summary:

The workshop identified that conversion courses should better consider a pilot’s

experience and offer tailored solutions.


Focused standardisation workshop

Conclusion

Since the workshop, recent events have confirmed the validity and robustness of the Top

9 issues. Most of the events can be associated with one of these issues. They therefore

deserve further attention. The actions proposed here will improve pilot training and

should radically reduce the risk of certain pilot training-related events. This document is

an important basis for further developments. It is particularly pertinent given the recently



of 21

published and forthcoming European rules on other types of air operations: non-

commercial and specialised operations.


Training Implementation Policy - EASA · Working Methods ... Failure of the crew to follow the...

Documents

Transcript of Training Implementation Policy - EASA · Working Methods ... Failure of the crew to follow the...