safetypee, you make some really good points … i.e., “more training?” … “Ok, how much and what for?” as well as … “understanding the widest range of issues in major accidents; learn; and then, make small but effective changes to correct the recognized errors…” Of course, I can’t speak for the kinds of rules, regulations, authorizations, “do's and don'ts,” traditional and non-traditional aspects, etc. etc. for aviation systems other than those in the US – But, for the US, I DO know and HAVE experienced the full gamut of most of those characteristics. However, that doesn’t change the validity of what you’ve pointed out … I merely want to add the following:
Even as good as the NTSB is at determining the “probable cause” of accidents and investigated incidents, the training recommendations they make either as a result or seemingly to prevent a similar situation in the future – while quite logical, at least most of the time, if an FAA regulation was created for each of the safety recommendations made – the increase in requirements and all the resulting time and cost concerns would be much more than theoretical. Over the recent 20 – 30 years, or so, I have seen a good effort on the parts of all the major players – and by that, I mean individuals representing each … the FAA, the NTSB, several individual airlines, a couple of pilot unions, appropriate airplane manufacturers, several training organizations, etc., who have, on multiple occasions, got together, laid all of the issues on the table, and mutually agreed to work to find logical, realistic, and workable recommendations. Profit margins, ticket sales, advertisement schemes, etc. were all set aside for these discussions.
Within these “working groups” there was, initially surprising, but later quite expected, quite logical, sensible, workable, realistic recommendations that were distilled out of all of the conversations and professional “give ‘n take” that was provided from ALL of the participants. Sounds pretty good … eh? Well, not so fast. As good and as logical as these recommendations were, it was still necessary to get those recommendations through each of the participants’ management structure at home. Even when some potentially productive efforts were put into operation – even if it was only to gather information which was to be later used to refine the rules and regulations, while at the same time provide instructive recommendations, there was the inevitable “head-shed” decision that either blew apart the effort or changed its direction so dramatically that all of the original intent was no only lost but provided substantial logic to go in a completely skewed direction.
I think almost everyone who participated in more than one or two of these efforts eventually came to understand that to see any of the recommendations become an industry wide practice – it would have to be 1) simple to adopt, easy to administer, provide superlative aviators, and add “depth” to the corporate coffers, be they airline or manufacturer, training organization or individual pilot pocket; or it would have to be 2) required by regulation. You may have, but I’ve never seen (and probably will never see) anything that might be even close to having the features of number 1 … and that leaves only number 2.
Also, I think that, while everyone here recognizes that a government entity does not have an exclusive capability to generate “bureaucracies,” virtually all corporations that have more than 2 employees have their own version of such a “head-hurting” processes … but NONE of those corporations have that process down to the level of “science” that the government manages to provide 25 hours a day, 9 days a week, and 15 months out of every year! The effort it takes to outline the necessities for having to modify an existing rule is quite major … but it doesn’t hold a candle to what happens to construct, write, review, modify, re-review, and then defend either a “major” overhaul of an existing rule, or, heaven forbid, the initiation of a brand new requirement!
The very notable exception to this point – as would be jumped on by the regulatory managers and some of the management officials of those airlines currently participating in one such “major” effort … in the US it is known – either affectionately or not-so-much (depending on your position) as the “Advanced Qualification Program,” or AQP. This was a working group-developed concept that was originally designed to provide data that did not exist at that time. It was proposed to provide that data, get a “hands-on” working familiarity with some of the then-understood philosophies, and help determine the logic of maintaining those philosophies or of changing them … which would be accomplished in accordance with the data gathered from this effort. It was initially planned to have something like 3 to 4 or 5 airlines entered into this program, and was predicated on a rather sophisticated data gathering process and a really well-laid-out record keeping process. The initial queries were to focus on the logic of continuing to have airline Captains return to the simulator every 6 months for a recurrent proficiency check, while requiring First Officers to return every 12 months for the same kind of check … particularly when there were some local FAA offices that thought that it would be appropriate to allow one recurrent training period each year to substitute for that visit’s proficiency check. That meant that Captains would get 1 course of training and 1 recurrent proficiency check each 12 months – equally spaced.
Unfortunately – that thought process didn’t quite make it through to frontal lobes of some … who, apparently blindly, allowed First Officers to get the same one recurrent course of training each 12 months. If one were to stop talking (and thinking) at that point, it would be fine. But, First Officers were only coming in once each 12 months – now that visit was going to be a training session … not a proficiency check. Of course, some operators and a few regulatory offices recognized this and allowed every other proficiency check for First Officers be satisfied with the course of training in the simulator. But, even then, that allowed F/Os to be checked only once every 2 years. During the first 18 – 24 months of this “data gathering effort” there were several management changes in the FAA – both locally and at the HQ level. At the same time, there was an influx of accidents and incidents that kept aviation – with the emphasis on the airline portion thereof – firmly on the front pages of most of the newspapers and all the local media outlets in the Washington, DC area. Naturally, no one in the FAA – particularly the senior managers – were very happy about having to be questioned by the Department of Transportation officials and the occasional Congressman or Senator – or the local TV, radio, and/or newspaper reporters, and the kind of questioning was quite pointed. Lucky for them the FAA had two on-going programs that were very highly thought of by members of the airline community.
These programs were the National Simulator Evaluation Team (NSET) and the Advanced Qualification Program (AQP). The airlines liked the efforts to clearly define both the technical requirements for simulators and the authorized uses for each such device (as it standardized the quality of the devices, making them more reasonably priced through competition of the manufacturers of simulators) and clearly set out the capabilities such that no one airline was getting more authorized in a simulator, requiring them to use the airplane more frequently – now it was more of a “level playing field.” At the same time, the idea of using the AQP to gather data, was discarded. The authorized training frequency was converted to a permanent factor, and any airline could petition to have its training program approved under the AQP … and doing so for one airplane fleet for a given airline, came with an authorization for all the other airplanes operated by that airline to move to a “single-visit training” function for all their crewmembers – Captains and First Officers.
This meant that, for larger airlines, this authorization immediately reduced their training budget by the cost of one simulator recurrent check or training for each captain they employed every year. If the airline had, say, 8000 crewmembers – 4000 captains and 4000 first officers – what used to be 8000 pilot training sessions for captains (2 per year) and 4000 pilot training sessions for first officers (one per year), for a total of 12,000 training sessions per year – instantly became a total of 8000 training sessions per year (one for each captain and one for each first officer) – which, using the appropriate number of calculators, means that 4000 pilot training sessions could be saved each and every year. THAT could mean a substantial cost savings – authorized by your friendly neighborhood regulator. And there were airlines in the US that had well over 10,000 pilots on their seniority lists … meaning a substantial savings … presto.
Yes, there were some requirements that the training program would have to meet some “high-power sounding” metrics, requiring some PhDs to be added to the payroll – at least for the development of the program – but if one were to carefully review just exactly what was required, the “high-power sounds” were … well … over-stated. Next, there was the offer from the regulator that the airline could establish their own standards of performance – regardless of what was indicated in the rules. Additionally, not all tasks contained in the regulations would necessarily have to be conducted during training. The “official sounding” justification for this said …
AQP was established to permit a greater degree of regulatory flexibility in the approval of innovative pilot training programs. Based on a documented analysis of operational requirements, a certificate-holder under AQP may propose to depart from traditional practices with respect to what, how, when, and where training and testing is conducted. This is subject to FAA approval of the specific content of each proposed program. All departures from traditional regulatory requirements are to be documented and based upon an approved continuing data collection process sufficient to establish at least an equivalent level of safety. Because AQP provides a systematic basis for matching technology to training requirements and for approving a training program with content based on relevance to operational performance, an applicant may propose to replace certain requirements of the regulations with an AQP curriculum, subject to FAA approval.
An AQP may also employ substitutes for the practical test requirements. The application to the specific issue of two alternative approaches to any single issue shows how risk based techniques may be used to demonstrate that an alternative methodology achieves a level of safety equivalent to traditional methodology. In order for an airline to “depart from traditional practices with respect to what, how, when, and where training and testing is conducted” that airline must provide “a documented analysis of operational requirements. Once the authorization to “depart” from the “traditional practices” has been issued, the continuation of that authorization will be dependent on “an approved continuing data collection process sufficient to establish at least an equivalent level of safety.” This is further explained by stating that this process must also include a “systematic basis for matching technology to training requirements” as well as the process of “approving a training program with content based on relevance to operational performance.”
A real-world example of substitution of one task for another task – with supposedly an equivalent level of safety - was the authorization for the conduct of recovery from a windshear encounter would replace the necessity for a pilot having to demonstrate satisfactory recovery from either an approach to stall or an aerodynamic stall. Take a moment and re-read that … this says that airline pilots training under AQP would not have to be exposed to recovery from either an approach to stall or an aerodynamic stall. There were other such “authorizations” … but because each training program approval was deemed to be “proprietary,” no one outside of the AQP office that constructed the “approval” and the specific FAA Operations Inspector assigned to that specific airline, would be able to read and understand what that airline was authorized and on what tasks they had to actually be trained and demonstrate proficiency.
After the terrible accident in Buffalo, NY, when this specific authorization was made known to other, more senior managers in FAA Headquarters, the AQP office was notified to “ensure that all AQP-authorized airlines would contain a requirement for training and evaluation in approach-to-stall/stall recognition and recovery.” It might be interesting to find out what other tasks have been “substituted.”
The point for all delving into all of the above is to point out that even when the regulator takes up the task of modifying the rules, someone, someplace, should be held to some level of accountability that the resulting implementation of said-regulation, will have the intended results – and not be left to the potentials that are clearly possible. In this particular case, the cost savings recognized by the airlines involved in AQP tend to make the management officials feel quite positive about complimenting the regulatory officials that allowed such a “modernized” approach to airline training. Those regulatory officials, after finding themselves being complimented for their foresight and courage for allowing a modernized and advanced training program, particularly one yielding the kind of well-trained pilots claimed by those airline management officials, also find themselves being seriously considered for further advancement within the regulatory structure – increasing their income and, at least as importantly, their stature among their superiors, their peers and their subordinates. The epitome of the mutual admiration process … achieved without any direct communication or agreement.
Of course, as all of my posts certainly are, this is simply another of my own, individual opinions. ....right?