Until February 2015 I was working for EASA. One of my projects was to implement and update the requirements for upset prevention and recovery training (UPRT) for commercial pilots. Although I left before the work was finished EASA published ED Decision 2015/012/R on 4 May 2015 . This decision introduced the new regulatory requirements for UPRT. The decision comprises 20 pages of new requirements and another 13 pages of explanation. In case you don’t have time to read the whole thing right now here’s a condensed overview aimed at training managers and instructors:
Why are new requirements being published?
A number of recent aircraft accidents could have been prevented if the pilots had avoided entering an ‘aircraft upset’, or had recovered from the upset once it occurred. In particular the accidents to Air France 447 on 1 June 2009 and Air Asia 8501 on 28 December 2014 both resulted in the loss of all passengers and crew on board. In the case of Air France 447 the aircraft would have been controllable if the pilots’ actions had been different. Initial indications are that the same is true for the Air Asia event.
Responsible aircraft operators will have already reviewed these accidents and ensured that their training programmes address the associated risks; nevertheless the European regulator (EASA) has decided to introduce new requirements to ensure that all operators have suitable training programmes. This is in line with international standards.
Who is affected by the new requirements?
The new requirements apply to commercial air transport operators of complex motor powered aeroplanes. There are no changes to licensing requirements so training organisations are not affected (yet). Operators who have an approved ‘alternative training and qualification programme’ (ATQP) are not affected.
What changes will operators have to make?
Operators need to update their flight crew training programmes, in particular recurrent training and operator conversion training (i.e. the training programmes for flight crew joining an operator or changing fleet within an operator). In each case there are additional requirements for ground and simulator training. There are no changes to the requirements for type-rating courses.
There are two new types of training to be assimilated, upset prevention training and upset recovery training. Prevention training helps pilots to avoid getting into an ‘aeroplane upset’ and recovery training teaches them to recover from an upset that has already happened. The new requirements include a list of training elements for each type of training (41 elements for prevention and 5 for recovery). Once the new requirements come into effect operator conversion training must include some of the ‘prevention’ elements. Recurrent training must include all of the ‘prevention’ and ‘recovery’ elements within a 3-year period, including some elements of prevention training every 12 months. The content of the training programmes should be based on an operator’s specific risks as identified through the management system (SMS).
Instructors will need specific training and standardisation before delivering UPRT. This requirement is not addressed in the TRI/SFI course. The focus of this training will be to ensure that the instructors teach the correct techniques and understand the limitations of using a simulator for this type of training.
What’s the deadline?
The new requirements come into effect on 4 May 2016. There is no requirement to have re-trained crews before that date, but all training after that date must comply with the new requirements. Operators will need to amend their training programmes (OM part D) and have the revised programmes approved before 4 May 2016. They will also need to ensure that instructors have had the required training and standardisation before they deliver the new training programme.
Is this mandatory?
The requirements have been published as ‘acceptable means of compliance’ (AMC). The underlying rules (ORO.FC.220 and ORO.FC.230) have not changed. This means it is possible to propose an ‘alternative means of compliance’ (AltMoC) if some aspect of the new AMC does not suit your operation. You would need to demonstrate that the intent of the rule is met and that your proposed AltMoC would achieve an equivalent level of safety to the new AMC.
What does the Training Manager need to do?
The first step will be to study and understand the new requirements. As well as the 38 pages of the decision EASA has provided references to several other documents. After this a ‘gap analysis’ should be conducted to compare your existing training programmes with the new requirements. Once you know the differences you can amend your training programme to meet the new requirements. The revised programme (operations manual part D) will then need to be approved by the competent authority. You will probably need to run special training sessions for simulator instructors. The content of these sessions should also be detailed in the part D.
Is there an easier way?
McKechnie Aviation will be running a series of half-day seminars to explain the new requirements in detail. To book a place or to arrange for us to deliver the seminar at your venue please get in touch.
If you prefer flying to desk work then I can help you to adapt your training programmes. In particular I’ll conduct a gap analysis of your existing part D with the new requirements and present you with a report detailing the differences and suggesting changes. I can then work with you to develop a revised training programme based on your specific risks and in compliance with the new requirements.
I will also be offering a one-day training programme for simulator instructors to prepare them to deliver UPRT. This programme will cover all the theoretical training elements required by GM5 ORO.FC.220 & 230; in particular it will provide an overview of the qualification and approval requirements of different types of flight simulation training devices (FSTDs) and help instructors to understand the capabilities and limitations of flight simulators for UPRT. This theoretical training can be complemented by practical (simulator) training sessions based on your aircraft type and your operating procedures.
If the new requirements pose a difficulty for your operation then I can help you find a solution or prepare an alternative means of compliance (AltMoC) for approval.