Is EU Operational Suitability Data (OSD) Fit for Purpose?
Thread Starter
Is EU Operational Suitability Data (OSD) Fit for Purpose?
Greetings all
Having previously got all stressed out by the training guidelines of the draft EC145 OEB reports that our Authority insisted we follow, I've just been looking at the EC175 OSD report for which the training (section 4) I believe is now mandatory. A few questions spring to mind:
1. Why have we gone from a list of OEB reports easily available on the EASA website to contacting the airframe manufacturer and asking if you can please have a copy.
2. The EC175 has a very complex autopilot and display system and the OSD report requires 16 hours of classroom training for this - can't complain too much at that but - what about a pilot that I'm converting from EC145T2 to EC175 - he knows the helionix system inside out and I suspect the EC175 system is near as damn it identical - it's not going to take me 16 hours to explain he's got one more screen than he used to have!
The minimum format/timescale of a type rating course should be agreed between the ATO and the Authority - not set by deciding a timescale based upon a worst case scenario for the most incompetent pilot ever seen.
3. OEB reports were supposed to be created by a team which included launch customer input (although I never saw this happen). Presumably, this was to get some 'real world' perspective into the OEB report. The list of contributors to the OSD reads like a who's who of management and test pilots - where does the customer get to feed into the process?
4. It appears that Category 'A' (class 1) operations are considered an add on in European manufacturer's eyes. So, if Mr. Rich Bloke employs a factory trained pilot as his personal aircrew and Mr. Bloke looks at the fresh licence, how does he know the pilot has the first idea about how to come out of a congested hostile environment at his factory? The idea that a type rating course doesn't include class 1 profiles is mad (and a way of charging a little extra at the factory school!?)
5. And so we come to the IR! This is contentious but where in part FCL is there mention of a 'multi-pilot IR' and if there is such a thing, how would you convert it to a single-pilot IR on that type or vice versa?
6. I'm confused by the table giving flight training times for MET MP IR but if I'm reading it correctly, it's suggesting if you do all the training in the aircraft, it'll take 20:30 but if you have the benefit of a FFS it'll take you 33 hours - What!!
7. Lastly, and perhaps I'm being picky, but section 4.2 b states:
Sorry but a Skill test is required for the type rating, both single pilot and multi-pilot and an initial instrument rating, not to extend the instrument rating to another multi-engine type - that requires a proficiency check on type!
I've picked on the EC175 because that was the only one I could find on the internet - it's here if you want a look; however, the OEB for the EC135, EC145 and AW139 seemed to follow a similar path of inflexibly maximising the length of a course. Strangely, if you check the similar documentation for the Bell 429, I think you will find a much more lenient/flexible (dare I say sensible) minimum training requirement.
I just find it annoying that instead of adjusting the course content to the experience, background and ability of the student, we have now developed a system where everyone has to do a course directed at the lowest common denominator.
Rant over, sorry.
TeeS
Having previously got all stressed out by the training guidelines of the draft EC145 OEB reports that our Authority insisted we follow, I've just been looking at the EC175 OSD report for which the training (section 4) I believe is now mandatory. A few questions spring to mind:
1. Why have we gone from a list of OEB reports easily available on the EASA website to contacting the airframe manufacturer and asking if you can please have a copy.
2. The EC175 has a very complex autopilot and display system and the OSD report requires 16 hours of classroom training for this - can't complain too much at that but - what about a pilot that I'm converting from EC145T2 to EC175 - he knows the helionix system inside out and I suspect the EC175 system is near as damn it identical - it's not going to take me 16 hours to explain he's got one more screen than he used to have!
The minimum format/timescale of a type rating course should be agreed between the ATO and the Authority - not set by deciding a timescale based upon a worst case scenario for the most incompetent pilot ever seen.
3. OEB reports were supposed to be created by a team which included launch customer input (although I never saw this happen). Presumably, this was to get some 'real world' perspective into the OEB report. The list of contributors to the OSD reads like a who's who of management and test pilots - where does the customer get to feed into the process?
4. It appears that Category 'A' (class 1) operations are considered an add on in European manufacturer's eyes. So, if Mr. Rich Bloke employs a factory trained pilot as his personal aircrew and Mr. Bloke looks at the fresh licence, how does he know the pilot has the first idea about how to come out of a congested hostile environment at his factory? The idea that a type rating course doesn't include class 1 profiles is mad (and a way of charging a little extra at the factory school!?)
5. And so we come to the IR! This is contentious but where in part FCL is there mention of a 'multi-pilot IR' and if there is such a thing, how would you convert it to a single-pilot IR on that type or vice versa?
6. I'm confused by the table giving flight training times for MET MP IR but if I'm reading it correctly, it's suggesting if you do all the training in the aircraft, it'll take 20:30 but if you have the benefit of a FFS it'll take you 33 hours - What!!
7. Lastly, and perhaps I'm being picky, but section 4.2 b states:
As per EASA Part-FCL, skill test is required for Initial Type Rating, Additional and IR extension.
I've picked on the EC175 because that was the only one I could find on the internet - it's here if you want a look; however, the OEB for the EC135, EC145 and AW139 seemed to follow a similar path of inflexibly maximising the length of a course. Strangely, if you check the similar documentation for the Bell 429, I think you will find a much more lenient/flexible (dare I say sensible) minimum training requirement.
I just find it annoying that instead of adjusting the course content to the experience, background and ability of the student, we have now developed a system where everyone has to do a course directed at the lowest common denominator.
Rant over, sorry.
TeeS
Last edited by TeeS; 7th Jun 2016 at 05:16. Reason: Edited out a bit of financial ranting :-)
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You can continue down that list...
Why does a pilot need 4 type ratings now to fly the same type on Single Pilot and Multi Pilot VFR resp. Single Pilot and Multi Pilot IFR?
Every pilot should come out of his basic pilot training as Single Pilot...
Give him ONE good Multi-Pilot course regarding workload sharing etc., and leave him with that...
Same to the IR:
Biggest difference is only between Single and Multi Engine IR (in the emergency part).
Once you hold one Single Engine and one Multi Engine IR, you should be allowed to fly any helicopter under IR....THAT would produce safety..
Sometimes, there is a bigger difference between two helicopters of the same type (e.g. analogue gauges vs. glass cockpit) than between two different types..
EASA has destroyed the helicopter industry-yet nobody realizes this, as the big offshore business kept pumping money into the game....now all of a sudden, that breaks away....and now everybody is in shock?
Surprise, surprise....
Why does a pilot need 4 type ratings now to fly the same type on Single Pilot and Multi Pilot VFR resp. Single Pilot and Multi Pilot IFR?
Every pilot should come out of his basic pilot training as Single Pilot...
Give him ONE good Multi-Pilot course regarding workload sharing etc., and leave him with that...
Same to the IR:
Biggest difference is only between Single and Multi Engine IR (in the emergency part).
Once you hold one Single Engine and one Multi Engine IR, you should be allowed to fly any helicopter under IR....THAT would produce safety..
Sometimes, there is a bigger difference between two helicopters of the same type (e.g. analogue gauges vs. glass cockpit) than between two different types..
EASA has destroyed the helicopter industry-yet nobody realizes this, as the big offshore business kept pumping money into the game....now all of a sudden, that breaks away....and now everybody is in shock?
Surprise, surprise....
It has become unaccountable - even our CAA can't get a timely answer from the EASA 'author'.
Classic example was the 'differences' grid between a Dauphin N3, N3+ and EC155B1.
If a pilot is rated on a late generation N3 and the EC155B1 then they have covered any differences with operating the N3+ (AP).........but the grid says you must have a 'differences' course as it does not account for the pilot having flown both types. Then you have to find someone who can give you such a course........world has gone crazy.
Classic example was the 'differences' grid between a Dauphin N3, N3+ and EC155B1.
If a pilot is rated on a late generation N3 and the EC155B1 then they have covered any differences with operating the N3+ (AP).........but the grid says you must have a 'differences' course as it does not account for the pilot having flown both types. Then you have to find someone who can give you such a course........world has gone crazy.
Thread Starter
......and also, what is the system for distributing any OSD amendments to an ATO that has based its training program on the previous OSD amendment!!
TeeS
OK - I've kind of answered my own question now - the manufacturer is required to notify any changes in the OSD to every known operator of the type - That'll be fun for them, I can't help thinking this information should be on the EASA website!!
TeeS
OK - I've kind of answered my own question now - the manufacturer is required to notify any changes in the OSD to every known operator of the type - That'll be fun for them, I can't help thinking this information should be on the EASA website!!
Last edited by TeeS; 10th Jun 2016 at 01:31. Reason: I know more than I did a few hours ago!
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OSD's and TR's
It is worth contemplating that OSD's and TR syllabuses have to be in place PRIOR to their entanglement with the real world. It is inevitable that this experience further informs the ATO's and the Authority about the suitability of these training elements in the REAL world.
IMHO these elements need to be subjected to compulsory review after a threshold number of courses have been delivered. The feedback can then help to 'tune' the requirements and the syllabus. This will help the focus of the training and improve the cost effectiveness of the courses. The review should involve the Authority, the ATO AND the operators.
G.
IMHO these elements need to be subjected to compulsory review after a threshold number of courses have been delivered. The feedback can then help to 'tune' the requirements and the syllabus. This will help the focus of the training and improve the cost effectiveness of the courses. The review should involve the Authority, the ATO AND the operators.
G.
Thread Starter
I thought I would stir this subject up again as I'm falling foul of the problems highlighted by EESDL on both types I fly,instruct and test on.
EC135 - I'm current on T1 (CDS and CPDS/FCDS), T2, T2i and T3(H) [the helionix version] and one of my customers would quite like me to work on their T3 (CPDS) - I'm fairly sure there isn't a difference on the T3 (CPDS/FCDS) that I haven't covered on the other variants; however, Airbus feel I need another 3 hours groundschool and 1 hour of flight training to cover what?
EC145 - Again, I'm current on EC145T2 and need a differences course for the EC145 (BK117C2) - the OSD requires differences training consisting of 12 hours ground school (I think I can get away without the 17 hours of FCDS, Helionix [on a 117C2??], AFCS and FMS/NMS) and 4.5 hours of flight training - to learn that the cockpit looks like an EC135, it has manual throttles and no fenestron; no reduction at all for thousands of hours flying the same cockpit and autopilot around!
Please EASA - let the National Authorities know that they can allow reductions from the OSD where experience on similarly equipped types can show an equivalent level of safety.
Rant over. TeeS
EC135 - I'm current on T1 (CDS and CPDS/FCDS), T2, T2i and T3(H) [the helionix version] and one of my customers would quite like me to work on their T3 (CPDS) - I'm fairly sure there isn't a difference on the T3 (CPDS/FCDS) that I haven't covered on the other variants; however, Airbus feel I need another 3 hours groundschool and 1 hour of flight training to cover what?
EC145 - Again, I'm current on EC145T2 and need a differences course for the EC145 (BK117C2) - the OSD requires differences training consisting of 12 hours ground school (I think I can get away without the 17 hours of FCDS, Helionix [on a 117C2??], AFCS and FMS/NMS) and 4.5 hours of flight training - to learn that the cockpit looks like an EC135, it has manual throttles and no fenestron; no reduction at all for thousands of hours flying the same cockpit and autopilot around!
Please EASA - let the National Authorities know that they can allow reductions from the OSD where experience on similarly equipped types can show an equivalent level of safety.
Rant over. TeeS
Last edited by TeeS; 21st Dec 2017 at 12:59. Reason: Corrected 'types' to 'variants'
TeeS,
To narrow it down I was doing some recurrent at DON a few years back when the now H145 was being introduced.
My instructor was going through the pain of OEB/OSD with EASA.
His thoughts were in line with yours. EASA wanted to make the H145 a separate type!
I thought this was all part of the design philosophy - commonality. Especially with the Helionix.
Somewhere there is a "choke point" - pun intended.
To narrow it down I was doing some recurrent at DON a few years back when the now H145 was being introduced.
My instructor was going through the pain of OEB/OSD with EASA.
His thoughts were in line with yours. EASA wanted to make the H145 a separate type!
I thought this was all part of the design philosophy - commonality. Especially with the Helionix.
Somewhere there is a "choke point" - pun intended.
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EASA wanted to make the H145 a separate type!
It was the manufacturer who insisted in making the 145 a seperate type rating...
I had seen the email of the testpilot back in the days-one of the guys shared it on the internet....
The OEB allows manufacturers to "dictate" what training should be required...
Its like asking Mercedes what training is required for a driving license owner before he could be allowed to drive the mercedes he just bought.....
Its not just OSD but almost every regulation EASA owns is being re-scribed to try and cover every scenario perceived by EASA lawyers. It seems this particular regulatory monster is growing incredibly fast on a feast of risk assessments.
hueyracer
I was stood in the office of the manufacturer and there was apparently not even a consensus amongst the manufacturer.
The test pilots and the customer training department even had different views.
It was not manufacturer versus authority.
Nobody was "lying" as you seem to claim from some comment on the internet just as this is.
I had seen the email of the testpilot back in the days-one of the guys shared it on the internet....
The test pilots and the customer training department even had different views.
It was not manufacturer versus authority.
Nobody was "lying" as you seem to claim from some comment on the internet just as this is.
Well, the 145 is still produced as BK117.
Thats why i.e. the CWP (Central Warning Panel) was put above the monitors of the Helionix System.
You don‘t need it, cause every caution will appear on the master list but without, Airbus wouldn‘t be able to produce the 145 on the 117 papers...
Still, there are quite remarkable differences between the B2, C1 and the 145 which I all flew/fly.
Things which won‘t bother you on the daily Job but are important in case of system failures.
Differences in Overspeed handling, differences in hydraulics just for example.
The amount of training needed? Well difficult to decide. I guess, if in doubt, play it save which is a pain for some but might give deeper understanding for others...
Thats why i.e. the CWP (Central Warning Panel) was put above the monitors of the Helionix System.
You don‘t need it, cause every caution will appear on the master list but without, Airbus wouldn‘t be able to produce the 145 on the 117 papers...
Still, there are quite remarkable differences between the B2, C1 and the 145 which I all flew/fly.
Things which won‘t bother you on the daily Job but are important in case of system failures.
Differences in Overspeed handling, differences in hydraulics just for example.
The amount of training needed? Well difficult to decide. I guess, if in doubt, play it save which is a pain for some but might give deeper understanding for others...
