Climatic Change in the Regulatory Environment

A regulation is a legal norm intended to shape conduct that is a byproduct of imperfection. At least, that’s how Wikipedia defines it. In any case, it is an authoritative rule on how an act shall be carried out. Sunjoo Advani, PhD., reports.

Simulators are not perfect. They never will be, and they don’t need to be. Instructors and evaluators are not perfect. However, they do have the responsibility to ensure that the candidates using simulators are developing the right skills and knowledge, and not inappropriate behaviour. Training pilots in developing and maintaining proficiencies, resilience, understanding and mitigation of threats, and operating aircraft in a professional, safe manner under all circumstances is the real key.

In this article, we will look at the range of regulations that govern this industry - how they evolved, where they are headed, and where the ultimate focus of our training and simulation industry lies: maintaining high standards for instructors and evaluators.

Training is a highly critical component of aviation safety. Regulations are developed to ensure that the training system meets a high standard, so that both the systems we use, and the pilots who go through that training, are capable of operating with efficiency and proficiency. However, are today’s regulations adequately ensuring that the instruction provided, tools we use, and inspections yield resilient, reliable and competent pilots? Are the standards of today the wind in our sails that lead us to a robust training for the future pilot? Or are they the anchor dragging behind our boat, impeding us whichever way we choose to sail? Are standards giving us the ability to define training devices and their use based on competency, or are we still in a never-ending cyclone of regulations that in futility are trying to catch up with technology? Most importantly, how can future regulation and training standards provide industry with the greatest service in establishing a minimum yet significant training objective in light of current safety initiatives?

Core Issues

Simulation regulations continue to evolve and transform from technology-centric capability specifications to training-driven functionality-based guidelines. As flight simulation became a valuable asset for pilot training, it was also clear that there were differences between technologies. In order to define an acceptable norm, industry and aviation regulatory authorities developed minimum criteria for simulator qualification. By looking at what was technologically possible, standards were established. For example, only after cross-cockpit collimating visuals were introduced by Rediffusion Simulation in 1982 did the regulations start to reflect the tests associated with these, in order to ensure the technology was meeting a minimal standard.

However, different regions around the world began to develop their own standards (their airline and simulation providers came with improvements, and there were other priorities). By 2005, we had 26 device standards around the globe. Many devices were required to undergo multiple regulatory checks in order to satisfy different authorities. This is still the case, and the QTG’s and related testing have become a burdensome challenge, particularly when they need to be repeated out of formality. Strangely enough, the pilots, the training, and even the instructors in many cases are the same.

In 2005, Mr. Ed Cook, then the Manager of the National Simulator Program of the FAA, signaled to the Royal Aeronautical Society (RAeS) the urgency in developing a common standard - not simply by amalgamating the current standards, but by taking a top-down approach to defining the training needs. The RAeS summoned the world’s experts in training and in simulation, to work in parallel to what became ICAO 9625 Manual of Criteria for the Qualification of Flight Simulation Training Devices, Edition 3.

According to Mr. Cook, “It’s all about checking the competency of the final product: the trained pilot. While the regulator’s responsibilities include setting minimum standards, it is also true that if the regulator has done the job correctly and completely, anyone meeting those ‘minimum’ standards should be plainly seen to meet any/all appropriate safety requirement”. Standards must be written such that anyone meeting the standards described will have the knowledge and the skills to apply that experience so as to satisfactorily accomplish any task in a complete and competent manner that results in the expected outcome. IF something were to occur that is unanticipated, the level of knowledge and skill application will be immediately brought to bear so as to, again, satisfactorily resolve whatever circumstance was presented.

So where has this led us? Why then do we still have so many standards for the same device? Why are there differences between operators?

There are many answers to these questions, some of them legitimate, but all worthy of consideration. Let’s examine the underlying process.

Today’s Realities

If you think airlines are the low-cost leaders in industry, think again: National aviation authorities operate on even tighter budgets, relying on volunteer work forces of external experts and straining their staff with high and often inefficient load factors. Yet these regulators are tasked with knowing all about the current trends, and defining the rules that will influence the industry for years to come. Furthermore, while it is expected that regulators apply identical standards between regions, the truth leaves much to be desired. The interpretation of a specific test by one regulator may differ completely with another’s, and even with the intended purpose of the test.

It should come as no surprise that the demands placed on regulators are high, as they are tasked with defining operational safety standards in a challenging environment. Creating meaningful standards in the complexities of today’s environment within the constraints of the regulator’s environment is already a challenge. What we need are not just standards for the training devices in which the training takes place, but training and competence standards for instructors and evaluators. If we are to make a difference in safety, much lies in the hands of the instructor and the evaluator.

Instruction - A Fading Art

To be an instructor in the past, one had to be selected for the job. You were considered the crème de la crème of the pilots, of “top gun” caliber, and highly skilled in your ability to transfer knowledge and experience to the trainee. Selection of instructors was a rigorous process defined by the airline or training organization.

Now, in today’s budget-strangled environment, there are few benefits to becoming an instructor. It means a major change in lifestyle, working hours, and it means being constrained to a less exciting job. Some airlines allow only their captains to instruct. A few choose first officers to give instruction, while inspections and proficiency checks are performed only by captains. These proficiency checks are rigorously fixed programs, established by regulatory minima. All pilots are exposed to the same failures and conditions (some now barely relevant) in order to achieve a basic standard in the training. Again, we point to the importance of regulation based on actual needs rather than meeting a plain vanilla basic minimum.

A good pilot is not always a good instructor. It takes a special set of skills to transfer knowledge to the aviator, and to emphasize the correct priorities. Instructor training is therefore an incredibly important aspect of our system - an aspect that seems to vary between airlines, and it’s a fading art.

In today’s economic realities, many airlines are forced to employ absolute minimum training, and to rely on their regulator to define what that minimum is. As a result, the responsibility is then shifted to the regulator. Ironically, the quality assurance can NEVER be handed over to the regulator as this is not their responsibility; they are not trainers and instructors: It would be a false sense of safety.

Solutions - Where to Next?

Maintaining regulator and instructor competence go hand-in-hand. Simulators are training tools used to impart knowledge and skills to both pilots and instructor, and one needs to understand how to get the most out of them. An instructor must know how to use the device, appreciate its strengths and weaknesses, and know where it does and doesn’t mimic the aircraft. The instructor provides the training, and the simulator is a great tool - not the other way around.

A good example is Upset Prevention and Recovery Training- clearly, a focal point as industry tries to reduce Loss of Control In-Flight accidents. The ICATEE working group identified that most UPRT may be conducted in flight simulators in combination with “back-to-basics” aerodynamic knowledge. A simulator instructor needs to therefore impart confidence to pilots in recognizing and immediately preventing a developing upset. Or, if all else fails, the pilot must know how to recover from that situation.

Most pilots including instructors will scarcely, if ever, have seen a high pitch/bank angle excursion, or have experienced a full aerodynamic stall. As line pilots, we are rarely exposed to such events, due to the several wonderful technology safety nets protecting us from going there. Ironically, it is during those extremely rare circumstances that we do not seem to have consistent skills on how to get out of such situations.

It should therefore come as no surprise that some astute airlines are placing emphasis and investment on training their instructors and evaluators on UPRT first. Some, like South African Airways, have received substantial financial support from their insurers. In this area of training, regulation is aggressively trying to catch up in order to ensure that the instructors of these “train-the-trainer” programs are adequately qualified, and that the evaluators of these are also appropriately skilled in making their assessments. Developing this tiered safety process, within the existing framework of regulation, and maintaining consistency between member states will be a challenge. However, this approach is what is needed to ensure quality and safety throughout the system.

Simulators cannot do everything, and particularly when dealing with upsets (see CAT Issue 6, 2014, pg. 34), and this is where an instructor’s understanding of the limitations and capabilities becomes crucial: Use the simulator properly to develop awareness, enforce the correct strategy, pay attention to the right cues, appreciate the type-specific interfaces and the training will have a better chance of prevention or recovery from upsets. An instructor that is unable to explain the shortcomings of the device, including the differences that would be encountered in reality, could propagate inadequate or negative transfer of skills. Accidents like American Airlines 587 in November 2001 are considered to have been the products of negative training transfer, despite the best intentions of the airline.

ICAO 9625

After the massive industry effort to re-write ICAO 9625, the end result, Edition 3, was an astounding 680-page manual (the original 53-page version was like a leaflet by comparison). Seven device levels created, Type 1 (lowest) to Type 7 (highest, like Level D + ATC). It was ready for the taking.

Slowly, this document has started to see its implementation, though it has not fully aired on prime time of simulation guidance: Russia, Singapore, South Africa, Australia and China have indicated their plans to embark upon its incorporation. The FAA has taken elements of ICAO 9625 Edition 3 into its recent Notice of Proposed Rulemaking. EASA, on the other hand, intends to await Edition 4, which will incorporate:

ICAO has indicated that Amendment 4 will be published in 2015. The on-line version is already available.

Future Needs

Looking at the current status of our industry, there is a need for practical training & testing standards for pilots. Regulation needs to develop not only a baseline requirement, but to encourage higher standards. According to former FAA inspector Arnab Lahiri, currently heading ZenSim, “The available instructions, tools inspections are not necessarily inadequate - it is the spirit in how these are applied that seems to be often a problem”.

Standards for instructors and evaluators need to be sharpened. Instructors should not lose sight of maintaining their own basic skills and enforcing these within their students. For example, if an approach is unstable, why was it that way? Programs like AQP or Evidence-Based Training rely on data derived through feedback from instructors. That statistical “data mining” is dependent on what the instructors have interpreted and observed. If instructors are not trained, they cannot always judge accurately. However, when properly established, training should indeed be evidence-based or AQP-oriented, instead of fulfilling rigidly and less relevant routines.

Maybe there will come a day when instructors are evaluated by the best-qualified examiners, and regulators will have the resources to develop and enact rules in a time-effective way. Perhaps future simulator qualification will be based on type (like aircraft type-certification), rather than onerously performing multiple checks on each device, several times a year. Mutual recognition of standards from the first step would reduce latent discussion on implementation. Rethinking outside the box will enable our industry to move out of the “back-side of the power curve”, and streamline its processes. Simulation and training imperfections need not be an impediment, but an opportunity for pilots, instructors, evaluators and regulators to develop an even safer, more resilient training system.

There was a time when pilots became pilots because they were genuinely interested in airplanes. They developed a deep understanding of aeronautics, and when something unusual happened, they reacted not just from training experiences, but through that fundamental understanding. After all, aviation is - and should remain - about the passion of flight. Let’s never allow our self-created and formidably complex rules and systems to overshadow the need to pass on the beauty and wonder of this industry, from the regulators right down to the future pilot.

About the Author:

Sunjoo Advani, PhD., is a graduate aerospace engineer with 33 years of experience in flight simulation. He founded ICATEE under the Royal Aeronautical Society, which led to the creation of international guidelines for UPRT. Currently, through his company International Development of Technology, he supports industry globally in UPRT implementation and other training and simulation matters.