The rule that rose out of the 2008 Colgan Air accident was finally published last week when the the Federal Aviation Administration issued a supplemental Notice of Proposed Rule Making (SNPRM) which incorporates the provisions imposed by passage of the Airline Safety and Federal Aviation Administration Extension Act of 2010.
The supplemental rule also addresses key issues raised during the comment period that were not a part of the original rule. It comes 16 years after the National Transportation Safety Board first called for improved training to deal with unusual upsets.
The new rule is expected to put additional pressure on regional airlines. The original NPRM was criticised for low-balling the actual cost the industry is expected to incur upon implementation. The agency argued that since many operators already provided simulator training similar to that in the proposed rule, the cost would be minimal. The agency revised its expectations estimating the 10-year cost of the rule to USD391.9 million. It also estimated potential benefits over the decade to be USD445.1 million.
The SNPRM is designed to better equip pilots to handle the unusual circumstances encountered by the crew that were killed in the Colgan accident, according to US Department of Transportation Secretary Ray LaHood. It also covers other crew members, he noted, including flight attendants and dispatchers.
The Congressional mandate imposed last July reflected a significant shift in training methods, from one that seeks to avoid the stall the crew found themselves in, to a more robust training that teaches them how to deal with a stall or other unusual upsets once they do happen. The agency called this the most significant crew training update in 20 years.
Crew would have to demonstrate their ability to handle “real-world” emergencies, not just learn what to do. It mandates more realistic simulator training. In addition, crew would be required to train as a complete flight crew, coordinating their actions through Crew Resource Management, and fly scenarios based on actual events. The proposed rule also seeks to ensure the pilot in command and the second in command have equivalent levels of training. Dispatchers would have enhanced training and would be required to apply that knowledge in today’s complex operating environment.
While mandating training to enable recovery from unusual upsets has been a key safety recommendation since 1994, the SNPRM is the first to mandate it after addressing the issue by issuing guidance documents for roll upsets such as the rudder issue that caused several 737 accidents and the icing accident that felled an ATR 72.
The proposal also requires remedial training for pilots with performance deficiencies such as failing a proficiency test or check, or unsatisfactory performance during flight training or a simulator course. Thus, the agency was silent on one of the major problems found by the National Transportation Safety Board in the post-accident investigation. During hearings, the board emphasised the seven failures of the captain of the Q400 both in his early days learning to become a pilot and as a line pilot at a regional airline. Safety experts said this clearly indicated the need for a cap on such failures suggesting that there are some who just shouldn’t be allowed to fly commercially.
The proposal details how carriers can modify training programs for aircraft with similar flight handling characteristics. It also reorganises and revises the qualification, training, and evaluation requirements for all crew members and dispatchers.
As with the original proposal, the supplemental notice would require the use of pilot flight simulation training devices. Pilots also would have to complete special hazard training in addition to practicing the use of crew resource management skills.
The supplemental proposal also contains requirements derived from voluntary FAA-approved alternative training regimens such as Advanced Qualification Programmes (AQP) including crew oriented, scenario-based training and satisfactory skill demonstration for each task. It also includes a continuous analysis process that would allow the certificate holder to validate the effectiveness of the qualification and training program.
Comparison of Current and Proposed Recurrent Job Performance Training
Hours for PICs and SICs Over a 36-Month Training Cycle
Flight attendants would be required to complete hands-on emergency drills every 12 months, and the proposal would standardise the training and experience requirements for certain dispatchers and instructors.
Comments are due 19-July-2011.
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