Inadequate training of line pilots

Thank you for the opportunity to comment on this REPCON. In response to comments offered by the reporter, [Operator] would like to offer the following comments:

The reporter states that the [Operator] does not supply bi-annual training to line pilots, which is in contravention to Civil Aviation Order 82.10. The reporter states that [operator] provides bi-annual checks to pilots, and it is only if those checks are found to be unsatisfactory, that further training may be supplied. The reporter further states that new pilots are being endorsed on [aircraft type] using the simulator; however, are not completing all the mandatory items as per the endorsement form. The reporter has advised that the reason given to pilots for the lack of annual training was due to budget and/or rostering constraints. The reporter acknowledges that in previous years, pilots have been provided with very comprehensive and beneficial training that was outsourced to [external organisation]; however, those opportunities have not been made available for several years.

[Operator] undergoes annual compliance reviews performed by CASA. A key component of these annual reviews is to assess the Training and Checking Organisation (CASR 217) for compliance against CAO 82.1. [Operator] has found to be compliant in the last three reviews. Both the [aircraft type] and [aircraft type2] are operated with nine installed passenger seats with a single pilot. If more than nine passengers are required to be carried Refer AFM, Limitations Section 2. Notwithstanding our current level of compliance, [Operator] is currently implementing a comprehensive training program that includes training in excess of what is required in CAO82.10 and has a Fixed Training Device of its own on order that has a flight data model that includes upset recovery. The [aircraft type] type ratings are provided by [Operator] Operations CASR Part 141 approval. This entity is wholly owned subsidiary of the [Operator].

The reporter correctly identified that in previous years (prior to the [Operator] Operations being granted Part 141/142 approval) the [Operator] sent our [aircraft type] pilots at considerable expense to [external provider] in [Location. It was never the intention of [Operator] to continue this arrangement once the [Operator] had established adequate capacity to insource this function including the procurement of its own flight simulation capability.

The [Operator] is subject to annual internal quality and external CASA audits to ensure the training and checking program is delivered to a standard expected by [Operator] and the regulator. Recent results from the surveillance activities have established that [Operator] is compliant with these requirements.

The reporter referenced ATSB investigation [number] in which the ATSB noted that “the omission of basic handling training on a new aircraft type could result in a pilot not developing the required skilled behaviour to handle the aircraft either near to or in a loss of control situation” as a factor that increased risk in that accident. As a result of that investigation, [Operator] advised amongst other things that “all new pilots will complete the company’s full induction training, including aircraft endorsement training.” The reporter queries, if mandatory items such as emergency gear extensions and flapless landings are not being completed due to time constraints, if [Operator] training is motivated by enhancing safety or to meet regulatory requirements.

All new pilots joining the [Operator] undertake full aircraft specific training (defined by the Chief Pilot), regardless of previous experience. To support this assertion, the [Operator] recently had a pilot start with us who has been flying [aircraft type] aircraft in [Location 2], and yet they were put through exactly the same training course as their fellow trainee who had no previous experience.

All trainees undertake training on flapless approaches either in the simulator or in their line training. Refer the [aircraft types] line training guides (attached) where a minimum of two flapless approaches are required during their training. Both the training and the abnormal procedure itself for ‘Landing Gear Manual Extension’ is identical for both the [aircraft type 1 & 2]. This is discussed at length during the initial [aircraft type] type rating training, including that for [Operator] pilots transition from the [aircraft type] onto the [aircraft type] is as much a ‘type differences’ course for experienced [aircraft type] pilots as it is a [aircraft type] type rating course.

The [aircraft type] rating course currently delivered to [Operator] pilots has a deliberately designed footprint; one predicated on candidates completing the full [Operator] initial employment induction process and present for [aircraft type] training being experienced in [Operator’s aircraft type] operations. Put another way, the [Operator’s aircraft type] rating course for our [aircraft type] pilots is six hours (3 sim sessions per pilot) shorter than an ‘off the street’ applicant due to recognition of prior learning (RPL). RPL is particularly relevant to subsequent points.

The ‘Flaps Up Landing’ abnormal checklist procedures for the [aircraft type] and [aircraft type] are near identical, with only one minor difference being in the sequence of the same abnormal checklist items. The only difference in a flapless landing technique between the [aircraft types] is the actual airspeed flown during the flapless approach, which is provided within applicable aircraft QRH dependant on landing weight. Manual landing gear extension and flapless landings are further discussed at length during CAR 217-line training and tested regularly during CAR 217 compliance base checks/IPC’s.

Please see attached a previous version of the CASA Form 61-1498 Type Rating – Multi Engine Aeroplane. This form version is the one that has been submitted to CASA for all past [Operator] pilot [aircraft type] rating flight tests. Whilst this has very recently been updated by CASA, the newer version is not relevant to this report. As you will see from the attached type rating flight test form, nowhere does CASA mandate a requirement for testing of either manual landing gear extension or a flapless landing. Assessment and confirmation of manual landing gear extension and flaps up landing proficiency is conducted during CAR 217-line training and compliance simulator training & checking.

The reporter states that the current lack of training provided to pilots raises obvious and serious safety concerns. Civil Aviation Advisory Publication 5.23-1(2) recognises that a number of accidents are caused by mismanagement of aircraft systems and loss of control by pilots, and that pilots need to be shown all the flight characteristics of the aircraft and be given adequate time and practice to consolidate their skills.

All staff, including our Flight Operations team, have numerous mechanisms to provide feedback on the quality of the training and safety related concerns. The [Operator] has a positive reporting culture where we feel appropriate responses are provided to reporters when the appropriate mechanisms are used to provide quality feedback. At no time, post [aircraft type] rating training have any of the pilots whom have received type rating training on the [aircraft type] expressed formally or informally dissatisfaction with the training provided.

The [Operator] prides itself on going above and beyond in regard to quality and safety. Results from our recent internal and external surveillance activities and the documented financial commitment to Flight Safety are for all to see (refer to ATSB Investigation report [number]).

The [Operator] and subsidiaries will continue to refine training footprints as required, as well as incorporating recently highlighted quality measures to improve and evolve our training and checking product.