State of the industry
A situation where the training is focussed on the 'test', be it a License Skill Test of a Licence Proficiency Test, inevitably leads to a gap between 'competence' and 'compliance'.
This gap is there because to be 'compliant' you have 'passed the test' but to be 'competent' you need to have received comprehensive training that focusses on the job you do.
There are no 'compliance' requirements, beyond the IR, that focus on a particular job save those that are in the Company Operations and/or Training Manuals. With so many skill-sets required in our industry this is probably not surprising. In the Fixed Wing world if you can take off and land on a runway then there is not a huge difference in technique between a puddle-jumper and an Airbus but if you are a commercial chopper pilot then just imagine the range of skills you may need to go to work: Offshore, Sling Load, HEMS, Law Enforcement, Long Line, Fire Fighting, VIP, Search and Rescue, Offshore Windfarm Support, Power Line Repair, Power Line Inspection, Survey. There are others I'm sure.
The point is that doing an autorotation and a spot turn makes you compliant, doing a single engine IFR approach makes you compliant but to be competent you would need to demonstrate that you can do a night deck approach in the pouring rain at minimas, manage a 'max weight' load on the end of a hook, pick up a survivor at night from a boat, drop a Bambi Load on the spot nine times out of ten.
Those that respond that 'their company does just that' are fortunate. Many, dare I say most, do not have the benefit of such comprehensive training and checking.
Perhaps it's not surprising that there is a gap between 'compliance' and 'competence' when we contemplate when the rules were drafted - was it 30 years ago? Arguably two generations of helicopter ago.
IMHO a better way is needed if we are to keep the industry safe.
G.