Mandatory Sim Training??

[Geoffersincornwall]

CASA are considering making sim training mandatory for high-risk manoeuvres. I also understand that the Nigerians make sim training compulsory for the larger helicopter types (?).

Is this subject being considered elsewhere does anybody know?

G. :ok:

[SASless]

What is the definition of "High Risk Maneuver"?

Sounds like a load of rubbish to me!

it has gotten to the point one only talks about way too many maneuvers as it is.

Anything that will work to enhance safety....expose Pilots to extreme situations....but do so with some real resemblance of how the actual aircraft reacts...would be good. Making it mandatory sounds more like the Sim folks are trying to work a ticket, the H&S folks are enlarging their stroke, and the Authority is looking to generate some revenue and post retirement employment perhaps.

[170']

You hit the nail on the head SAS...

[topendtorque]

the H&S folks are enlarging their stroke, and the Authority is looking to generate some revenue and post retirement employment perhaps.

Especially the H&S mob. See message below a major victory

Two I can think of, a) The approach downwind into a deliberate vortex ring state. That would blow a few big headed assumptions I hope.

b) Sit in a hover and wind off RPM into overpitch, learn now, can I go or nogo.

was most interested to read Whirlygigs little F1 course booklet recently and didn't see that overpitching problems mentioned, but thought for the main her instructors course delivered a much more complete instructor than what I have seen of our instructors


The same should apply to some of the ridiculous SMS garbage. learn and be good at the basics, the whole ab initio syllabus and every other syllabus that you use, IR, NVG etc with no f'n excuses and the rest takes care of itself is my motto.

This was quite recent

Prosecution of Air Operator under State work safety legislation held to be invalid

New South Wales is known to have one of the most onerous workplace safety legal regimes in the world. Employers have strict obligations to workers with substantial penalties if there is a breach. Prosecutions of employers are incredibly difficult to defend.

In addition, the NSW Occupational Health and Safety Act 2000 (OH &S Act), somewhat unusually, gives unions and other industrial organisations representing employees the right to prosecute breaches of the OH&S Act. The union is also entitled to half of any penalty imposed on an employer.
Landmark decision on the right to prosecute Aircraft Operators for Civil Air Accidents
Heli-Aust Pty Limited v Cahill1

On 11 May 2011, the Full Court of the Federal Court of Australia held that Commonwealth legislation regulated civil aviation in flight to the exclusion of the NSW OH&S Act. The effect of this decision is that airlines and aircraft operators, although still required to meet the safety standards imposed by Commonwealth legislation, cannot be prosecuted under State work safety legislation in connection with civil aviation accidents during flight.

The Facts

On 22 November 2004, a helicopter struck a wire and crashed whilst performing locust spotting operations. Last year, charges were brought against the operator of the helicopter for breaches of the OH&S Act.

In summary, the charges laid under the OH&S Act alleged a failure to ensure that the work premises (in this case, the helicopter) were safe and without risk to health and also that people entering the premises were not exposed to risks to their health or safety. The charges were particularised to allege failures to conduct sufficient planning and failures to provide particular safety equipment for the helicopter and its occupants.

The Full Court Decision

The Full Court unanimously held that the Commonwealth civil aviation legislation covered the field with respect to the safety of civil aviation in flight. Moore and Stone JJ delivered a joint judgment, and found:
The Commonwealth regime for the regulation and the safety of civil aviation in flight in Australia is comprehensive and exclusive, it is not supplementary or cumulative on State law or Commonwealth law. There is a direct conflict between the State and Commonwealth legislative schemes. A State law, to the extent of the inconsistency, is invalid.


Flick J, in a separate judgment, essentially reached the same conclusion.

Impact Of Decision

The decision of the Full Court means that the OH&S Act, and by extension corresponding legislation in other States and Territories, insofar as they purport to apply to matters concerning the safety of civil aviation in flight, are invalid. Occupational health and safety laws continue to apply to matters occurring in or around aircraft that are not strictly related to the operation of the aircraft.

Despite this limitation, the judgment represents a significant victory for airlines and aircraft operators insofar as it permits certainty about the standards to which they are required to operate and eliminates exposure to the significant penalties under State work safety legislation in the event of civil air accidents.

It is not known at this point whether there will be an application for special leave to appeal to the High Court.

[HeliComparator]

SAS, are you Old and Bold?

The point is that modern helicopters are fairly reliable (I am glad to say) so there comes a point where you can destroy more helicopters and kill more people by training in higher risk manoeuvres (all flying carries risk, it can be higher or lower depending on the nature of the manoeuvres) than would ever be destroyed/killed by an actual case of the emergency.

Like when I first learnt to fly fixed wing (RAF University Air Squadron) we had to wear parachutes. When I asked if we would get any practical training in their use, the answer was no, because we would kill more people in the training than would be killed attempting a real bailout. And that was 1970s safety thinking.

Heli Simulators are still a fair way away from the real thing, but there is a lot of benefit in training the manoeuvres, maybe 90% as good as doing it in the real thing but with zero risk (a bit of vomit excepted!).

We had a double fatality in Bristow Aberdeen in the late 70s(?) during OEI training, so mandatory Sim would have saved them.

With the gradual spread of modern (relatively) low cost Sims, it is becoming much harder to justify not to use them for training. I would have thought CASA should take it in stages though - require training in the Sim for those excercises best done in a Sim, which as far as I am aware they either don't do, or only require it quite infrequently. Then the next step would be to ban aircraft training in high risk manoeuvres if there is a clear safety case for it.

To answer the original question, I am not aware of such a move in EASA land so far...

HC

[SASless]

HC....both Old and Bold....but fortunately I was less bold than old.,,,that is why the ratio is getting better daily too!

One of the reasons I sound so reactionary.....I have seen these Pipe Dreams before.....where without adequate vision, control, and study....have resulted in less than stellar results. A simple example.....the US Army in its infinite wisdom issued one Parachute to every helicopter unit for use during Maintenance Test Flights. I discovered this when I had to sign for the thing in my Unit as part of my assigned Collateral Duty as the Technical Supply Officer. The fact a Chinook had a minimum crew of three had escaped the Army's brightest Aviation Safety folks. Since then....I have not had a lot of faith in edicts handed down by Government based upon Father Knows Best thinking.

My questions remain....who defines "Hazardous Maneuver", the training curriculum to be taught, the standards to which they shall be taught, how to certify the standards and establish certification standards, determine what level Sim is appropriate for which maneuver, which maneuvers are generic and which are type and model specify, the configuration of the training devices to ensure replication of the controls and equipment the Sim is to reproduce.....oh the list goes on!

Just how complicated, complex, bureaucratically, burdensome, and costly does CASA want to make this exercise?

Can I use a JetRanger Sim for McD-500 engine offs.....or must it be a 206BIII and not a 206L4.....for tail rotor failures....do we have to have a Sim that acts l ike a wrong way turning French Product or can we use an old Bell UH-1H SFTS?

If CASA is going to "require" (insist, demand, enact, force, extort) this practice they better get their Ducks in a row or it shall be a real Dog's Breakfast for those in the Industry who have to pay for it!

I am not against Sim training....quite the opposite having done instruction at two Factory schools.....but I do want it to be realistic, efficient, and designed to improve/enhance Pilot training, proficiency, and understanding of the aircraft they are operating.

If the end result is more cost, more bureaucracy, and false input that actually degrades safety.....then I am all against it!

[HeliComparator]

Since we can't even agree on how to spell "manoeuvre", it is highly unlikely that we could agree its meaning!

But I take your points, change should only be made if it is definitely for the better. However I think there is a pretty clear cut case for maximising training in the Sim for at least 90% of the syllabus, and some operators need a nudge in the right direction.

[SASless]

HC...so right!

Like a certain helicopter company we both know that decided to use its own instructors in a Sim Company's machines...then took pilots from Nigeria and had them do Aberdeen approaches, within hours of arriving on site following a two day commute across a half dozen time zones, in the wee hours of the Morning as it was the cheapest time slots , and all the while ignoring the great amount of expertise and knowledge surrounding them. Calling the single four hour session good and pissing off back home for the balance of their Leave.

The only reason they did even that was because the Customer required it to hold the contract.

"Nudge".....I would suggest having their "kicking" their ass into reality!

[Snarlie]

The UK CAA have made it a prerequisite that pilots intending to use the Cat A vertical profiles for the S76 shall have undergone training in those profiles in the sim prior to practising them in the aircraft. Even then the profiles may not be practised in the aircraft to OEI touchdown. Only the continued take off may be practised OEI. This came about after a number of incidents/accidents whilst carrying out training on these profiles which resulted in airframe damage. The risk assessment indicated that sim training was required. Most people I have spoken to who have undergone the sim experience prior to using the profiles for real agree that, in spite of some anomalies, much can be gleaned from the exercise.

As for SASLess`s ill informed rant - a number of operators prefer to use their own instructors because it allows them to carry out the training in accordance with their own Ops Manuals and also to conduct valid licensing checks on the trainees. The staff sim instructors cannot be expected to be current on all operators` individual OPs Manuals. Incidentally, the Nigerians I have met at the sim I visit on an occasional basis have always done their approaches at Lagos or home operating base and the offshore section on one of their own rigs but then why let the actuality spoil a good rant, especially when it`s about Bristow.

[SASless]

Snarlie.....I guess being there doesn't count for you?

What value was gained in the situation I described? I was not the only one that held similar views about that. Watching guys fall asleep in the middle of a Sim Ride due to exhaustion just adds so much realism to the ride doesn't it? If it was such a grand scheme....are they still doing that?

Using Own Company Examiners to conduct Checks makes good sense....finding Sim Company Instructors that are qualified or can be made qualified to give Checks makes more sense yet. Having a "Third Party" involved in crew competency checks ensures the reliability of the product does it not?



Also....I have some concern with your statement.....

The risk assessment indicated that sim training was required.

Do you mean "suggested", "preferred", "advised" when you say "required"?

If a Rejected Take-off is so prone to result in damage to the aircraft....perhaps the technique/profile/procedure is at fault and needs looking at.

[212man]

SAS, the manouevre is considered demanding and is acknowledged as such in the RFM. The particular issue for the corporate operators is that their aircraft empty masses tend to be very high and therefore - even with minimal fuel - the aircraft may be at or very close to the MCTOM for the procedure. This reduces the margins for error considerably. The risk assessment then becomes "what is the real risk of damage to the aircraft during training vs the actual risk of an engine failure during normal operations." For this specific activity, the simulator wins. I'm not sure the CAA mandate this though - CAP789 has some guidelines on it that arose from the AAIB safety recommendations in 2004, but maybe individual FOIs require it for their AOC holders.

For the EC-155 the corporate aircraft empty masses are above the Cat A Vertical procedure training weight, so a simulator is the only way to practice the profiles. We also risk assessed the training policy for the recently introduced S-92 Cat A Vertical procedures and have decided not to carry out rejected take offs in the aircraft.

Regarding your BHL sim experiences, I fully endorse your comments about the travel and rest arrangements (in that era) being pretty crap! But, like Snarlie, I believe Operator conducted training is the ideal when conducting operator specific recurrent training rather than just license revalidation checks. As for not using local airports, again my sympathies are with the trainer. Many pilots become parochial in their outlook, and they forget that as instrument rating holders they should be able to pick up their Jeppesen plates and fly any approach in the world. Taking them out of their comfort zone gets them working a little harder. Of course, if the operator provides a sensible number of simulator training hours, then you can do LOFT exercises in a home environment and IF exercises in a less familiar environment - sensible being the key phrase:ok:

[SASless]

Simulators are excellent training devices....and well planned and executed programs of training in Sim's is far safer, cheaper, and more dependable than using real aircraft....no doubt! I am an advocate of Simulator Training....and have always been.

My criticism of what went on in those days is based upon having been a Sim Instructor before returning to Operational Flying. When forced to utilize Sim Training the usual attitude of doing the minimum on the cheap attitude presented by the Operator was such a sad thing. What could have been a golden opportunity to lead the industry became an exercise in searching for the bottom of compliance.

LOFT scenario's for Nigera based crews would have been interesting.....lots of ILS, VOR, GPS approaches......to what end.....considering the state of Nigerian NavAids in those days!

I would like to see Helicopter Sim's reach a point such that the first flight in the actual aircraft would be an Operational Revenue flight. Where all training is done in a Sim.

The question is why are we not there yet?

With the expense of operation of large aircraft such as the 225, 92, 412, 76, and 155.....it would seem there would be a move to that capability.

When I did a marketing study for American Airlines Training Corporation that was then the 76 Sim Operation at the Sikorsky Facility in West Palm Beach....loacation of the Sim's was the major problem. To make it reasonable in costs for the customer we would have to locate Sim near their major bases.

That for AATC killed the deal.....as their concept was to have one central facility (remembering their airline connection to American Airlines).

Fleet size also entered into the equation....sheer lack of numbers of 155's for instance would make customer support for a Sim difficult.

But back to the point of the thread.....rather than make Sim training "Mandatory" as an edict of CASA or any other Authority....I would rather see a concerted effort by the Helicopter Industry as a whole to voluntarily improve the Sim Standards and move as an Industry to as much Sim training as possible.

[Geoffersincornwall]

The use of 'own instructors' has several advantages as '212' suggests and one of the most important is that the candidates are known quantities and the instructor has a vested interested in ensuring a quality product at the end of the day.

However, the 'I'll check you if you check me' syndrome is endemic and the occasional use of external auditors to validate your instructors and the training they deliver is to be recommended. Trouble is I don't know anyone who does it........yet!!!

SAS and his lessons of yesteryear inform us and warn us - don't just tick boxes. Do the job properly and real value for money will follow.

I agree with 212 that once you have mastered home territory the use of any airport for IR training is valid but some caution is necessary. Whilst charter pilots take every day as it comes the airlines generally run through a route-training programme in the sim prior to 'live' line flights. There is no training value in a flight that ends in a chaotic mess because of a glitch in the sim-automatics because nobody has ever flown that location before. We know they are supposed to work but keeping the sim nav database, the sim positional database, the sim avionics positional database and the sim visual database in line is occasionally a step too far. Shame to find out mid-lesson and waste all that time.

G.

[Geoffersincornwall]

Just caught your latest post and you will be pleased to learn that the hot news on the sim front is that ICAO have just published ICAO 9625 Document Volume 2 - FSTD Qualification Data.

This for the first time provides for specialist sims designed for helicopters and creates the opportunity for sims that are affordable and easy to maintain which will in turn lead to them being located in more convenient places in larger numbers.

There is a conference on this very subject in London at the end of May. Check-out the Royal Aeronautical Society's webside for details. I will be there.

G.

[212man]

Me too:ok:

[SASless]

The "Buddy Check" system is like Incest....no one admits to it, talks about it, or exposes it! I firmly believe in Third Party evaluation of an Operator....but even that is fraught with peril as Consultants want to keep the Contract, Old Mates might still be able to cover up short comings.

The Third Party should be there to pose the questions and the Operator should have to provide the answers and in the process actually do a good self review.

Technology and experience change with Time and what was once considered "Right and Good" are overtaken by Events.


Geoffers/212....

Part of the goal of the ICAO Standard you mentioned is to "Standardize" the Standards for such devices.

As we consider what should be very simple issues like "Air Crew Licensing"....just what hope do we have that "all" of the NAA's will be able to agree on a common standard for Sim's?

Is there anything in Aviation that "All" NAA's actually maintain a "common standard" and do not alter for their own reasons?

Why should we hold out any hope for the CAA/FAA/CASA/JAA/EASA and all the other major players to give up their own unique paths to Salvation?

[Shawn Coyle]

If I can wade into what is a very interesting thread…
The computer sees all and could be made to mark everything to an agreed objective standard - if only that standard could be agreed upon.


And if we don't aim for the 'zero flight time' for licensing, like the FW folks do now, we'll never get there.

[HeliComparator]

As I mentioned above, I did two typeratings in a level D sim. Both typeratings were on my license before I flew the actual aircraft

Presumably not in JAR-land for heavy twins then, since JAA / EASA requires at least 2 hrs aircraft time before the type rating course is complete. So whilst you can do the LST with only the Sim time, you can't actually complete the course and hence get it on your licence without the real aircraft time.

HC

[212man]

So whilst you can do the LST with only the Sim time, you can't actually complete the course and hence get it on your licence without the real aircraft time.

Slight thread drift, but this raises an interesting discussion point. Actually, it's a big rock that when lifted has lots of worms beneath it!

Who does the aircraft training - when the TRTP was conducted by an organisation other than the operator - and under what authority?

[Geoffersincornwall]

As I understand it the idea is to facilitate the creation of a new generation of FSTDs that can be built to an affordable standard for role training. I think the NAAs have the license thing covered. A typical affordable sim could be optimised for a particular role or roles and shorten the time it takes to become a competent crew-member (front seat and back seat). With easy access and cheap running costs they could be located at YOUR base and allow you to practice/rehearse SAR, HEMS, Fire Fighting, Sling Load, Police, Transmission Line Repair, Wind Turbine Servicing. IF training a breeze and recurrent training as you wish, night currency without flying at night, night DLs at your local platforms, Command Courses, LOFT Training.

The world is your lobster !!!

G. :ok: