Part 135 Operator Proficiency Checks - Emergencies?
 

Can anyone point to the regulation or somewhere in the MOS that says an operator proficiency check must include actual simulation of emergencies?

This is in the AC119 on the matter however it just says assess competency, but cannot find where it is backed up by the legislation


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135.435(3)(b/c) and (4)(b/c) point to the need to have a proficiency check and that the prof check is in the MOS.

MOS 12.01 definitions defines the FCM proficiency check as covering the items in 12.05 that are listed as conversion training and FCM proficiency check.

SpecificallyEven through that MOS ref refers just to training, the Definitions link same to the Proficiency Check.

Simples
/s

Yep, it gets caught up in a lot of circular links in my reading! 'training in normal, non-normal and emergencies' but does not specify that it must involve actual simulated emergencies (I am really referring to in-flight, most of us in the small aeroplane air transport world do not have appropriate sims available)

Wondering if one developed an alternative acceptable means of accomplishing the training that did not pose as much risk for some of the benefit of recurrent training it would be beneficial, specifically in the small aeroplane multi IFR world - you'd have an IPC every 12 months checking simulated emergencies with a flight examiner and an OPC every 6 months checking everything else and perhaps doing touch-drills and scenario-based discussions in cockpit.

The vagueness of many of the new regs is extremely frustrating. If you ask for clarification via the CASA guidance centre, don't hold your breath for a straight answer. It's a f***ing minefield because the reg writers will not come out and say in plain English exactly what they mean.

Does the person conducting the training and checking have to have an instructor rating with the appropriate training endorsements for the type? I can't see where the reg or MOS specifies that, so it falls back on the requirements from the operator's exposition as to what the checker needs in terms of competency and qualifications. Possible scenarios:
- Trainer/checker isn't an instructor, pulls some emergencies, something goes wrong. Insurance won't pay up.
- As above, but CASA gets upset because the operator hasn't ensured the operation could be conducted safely. Will they insist that the trainer/checker had to be an instructor? Maybe, because it's not clear in the reg. That's not their problem, though, because they're not the ones in the hot seat in court.
- Operator is concerned about inflight emergencies, and relies on the AFR to cover those, while using the OPC to cover operation-specific matters with discussion and perhaps touch drills to tick the 'emergencies' box. CASA gets upset because, depending on who's auditing, it's considered that that's not sufficient.

CAR 217 had its own internal structure with respect to who could do what to whom and how, and for the smaller end of town, flight reviews, PICUS and CP-designated training did the trick. Now we are in the brave new world of Part 135 etc, operators are rightly asking - what exactly do I need to do, who can do it, how often and so on. If the regs are truly outcomes-based and you make your exposition say whatever you think it should, that would be good, but a critical reading of most of the new air transport parts reveal a plethora of traps as far as I can see.