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Old 01-22-2012, 11:20 AM   #1  
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Joined APC: Nov 2011
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Question What Training/Checking Standard Should Exist

Today, the FAA is wrapped up in a couple of rulemaking efforts. Included in these efforts are:
1) A revision to the training and evaluation requirements; and
2) The issue of crew rest.
Both of these issues seemingly arose from the controversies that developed after the Colgan accident in Buffalo in 2009. Of course, there are other examples where at least one of these issues played a prominent role ... but this one seems to have been the catalyst for all the current flurry of activity from the Feds.

I’m going to stay away from the “crew rest” issue simply because I believe it is almost impossible to develop a meaningful set of regulations to “ensure” that pilots are well rested before the beginning of each sequence. Outside of being able to identify those who are cavalier about closing the bar at 2AM with a lobby show time of 08:00, or flaunting ski-lift tickets for the last run of the night with a similar show time, I can see virtually no way for anyone to determine if a crew member is or is not “well-rested” before flight. So, I’ll stick to the first issue – that of training regulations.

Today there seems to be more than one way that an airline may approach training program development, approval, and application. First, there is very little chance of applying any training program without the Feds granting approval ... but that approval can be achieved in one of essentially 2 ways. First, there is the existing regulations that lay out what has to be trained and tested initially and then revisited during recurrent checks. I can rather easily find what I’m going to be checked on ... but, other than my instructor’s outline, where can I look to find out what I’m going to be trained on? When I asked the last Fed who graced our jump seat, he said to “…check 121 appendix E.” That does answer some of my question … but the material in that appendix seems to be terribly high level and completely avoids almost all specificity for anything described. How does any company know for sure that what they are proposing for training is going to be in compliance with regulations that are so vague?

Second, if my company chooses to do things differently, they may find it beneficial to seek approval under the AQP. For some time now, I’ve never really looked to see what that meant – but I’ve recently taken the time to research it a bit more. According to the material I’ve read, almost anything will be considered as long as the Feds are given something on which to hang their regulatory “hat;” and from what I’m told, that means essentially hiring a staff of behavioral psychologists to provide all the necessary “buzz” words. The almost immediate result is an increase in the training intervals for some crew members and a rather significant departure from what the rules have been requiring for some time. For example, under this approach, the airline is apparently allowed to set their own objectives for the individual functions that are included in the “approved” training program – although the caveat here continues to be that these staff psychologists can convince the Feds that what they describe really does what they say it does. Under this approach, the content of what is actually “checked” can be reduced to only “sample” the functions that have been trained - again, depending on those psychologists' ability to achieve agreement with the Feds. Additionally, the number of functions required during each recurrent training session can be reduced by having the FAA agree that some of the normally required functions are “routine” and can be observed during the regularly scheduled "line check." Of course, with each reduction in what the crew members are exposed to during recurrent training, there is at least some savings in time (read that as “expenses”) that benefits the corporate structure. The justification for this is that these reductions are described as "adjusting the training program to conform to the individuality of the specific airline’s operation." I’m aware that any two companies are very likely to do some things a bit differently, but I am not at all sure that our operation of a B-737NG is decidedly different from any other company operating the same airplane type.

My question then becomes … what happened to the concept of everyone having to meet the same standards? A standard set of regulatory requirements not only should ensure that the minimum knowledge and proficiency has been achieved by everyone involved, it should prevent anyone from being granted a “more streamlined path” to achieve what they have described as "proficiency." And, if we re-define that “end point” for everyone, we effectively allow everyone to follow a different "path," allow everyone to achieve their own individual goals, and effectively eliminate any "regulatory standard." Is this a good thing?

I’m not trying to be “picky” and I’m certainly not trying to get any airline management into some kind of trouble … but I AM curious as to what is so good about doing things differently from everyone else. So ... I ask ... what should be trained and checked that will help ensure a safe operation?
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