Final Step in Pilot Professional Development Requirements Process

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FAA Publishes N 8900.545 on Pilot Professional Development

Began with Colgan and Pinnacle Crashes

Driven by Congress and aided by several ARCs

Notice issued after long process

This National Policy, N8900.545, was issued and effective on April 24, 2020. It is another step in the implementation of the Pilot Professional Development (PPD) Final Rule, issued on February 25, 2020. The initial step in this rulemaking was an NPRM issued on October 7, 2016.

ppd notice

The four years of Federal Register process to issue PPD standards was followed by a quick issuance of this policy statement. The history- before proposals were issued and finally promulgated- is even longer, indicative of the public firestorm, professional safety professional debate and Congressional guidance:

  • In response to the October 14, 2004 Pinnacle Airlines and the February 12, 2009 Colgan Air, Inc. crashes, the NTSB and the Congress identified problems with the professionalism of the pilots. The NTSB issued recommendations based on their investigations of the Pinnacle and Colgan accidents, which are well summarized in this quote from the later Board decision:

“Develop, and distribute to all pilots, multimedia guidance materials on professionalism in aircraft operations that contain standards of performance for professionalism; best practices for sterile cockpit adherence; techniques for assessing and correcting pilot deviations; examples and scenarios; and a detailed review of accidents involving breakdowns in sterile cockpit and other procedures, including this accident. Obtain the input of operators and air carrier and general aviation pilot groups in the development and distribution of these guidance materials.”

  • Congress enacted the Airline Safety and Federal Aviation Administration Extension Act of 2010 (Public Law 111-216). That statute directed the FAA to convene advisory groups and conduct rulemakings related to the results of the NTSB investigation of these accidents.
  • The FAA established three ARCs in 2010:

the Air Carrier Safety and Pilot Training (ACSPT) ARC,

the Flight Crewmember Mentoring, Leadership, and Professional Development (MLP) ARC and

the Flightcrew Member Training Hours Requirement Review (THRR) ARC.

All three ARCs were comprised of labor, industry, and FAA experts who provided recommendations to the FAA (see above links).

Thus, 16 years have been consumed between the initial accident and the final action.

Inclusion of diverse stakeholders contributes to the quality of the rules to be developed as well as the practicality of their implementation. At the same time, the broader perspective consumes time to organize sessions and requires significant dialogue/debate to come to a consensus.

The period between the ARCs’ issuance of their recommendation and the 2016 NPRM involves (i) considerable editing of the proposals to rules that are enforceable, (ii) an exhaustive research project to justify the proposed standards (in any Administrative Procedure Act review the substance of the rulemaking must be reasonably related to science) (iii) the economics of the proposed federal action are subject to very exacting financial tests) and (iv) iterative reviews by the Office of the Secretary and then The Office of Management and Budget (both scrutinies entail significant political perspectives. In a matter with the Colgan crash and their families, the Congressional interest was high.)

Frustrating, but these seemingly superfluous steps are mandated by law and most time consuming!!!

PPD panel

 

 

Notice 8900.545 includes:

  • Changes to the second in command (SIC) to pilot in command (PIC) Recurrent (§§ 121.409 and 121.427) a. Recurrent Ground Training. b. Recurrent Line-Oriented Flight Training (LOFT).] upgrade curriculum requirements;
  • A new requirement for all PICs to complete leadership and command and mentoring training;
  • A new requirement for SICs serving in part 121 operations that require three or more pilots to complete leadership and command training; (§ 121.432)
  • A new requirement for new-hire pilots to complete operations familiarization;
  • Operations Familiarization (§ 121.435).
  • Preflight Visual Inspection (Part 121 Appendices E and F and § 121.434)
  • Pilot Recurrent Ground Training Content and Programmed Hours (§ 121.427).
  • Flight Simulation Training Device (FSTD) Conforming Changes.
  • SIC Training and Checking Conforming Changes
  • Pilot Transition Ground Training (§ 121.419).
  • FE to SIC Conversion Ground Training (§ 121.419).
  • Action
    1. Planning.
    2. Early Compliance.
    3. Advanced Qualification Program (AQP).

This tortuous process is slow, but these amendments to Parts 91, 121 and 135 should result in better performance by the cockpit crews. The roles of the PIC and SIC will have been reinforced by training. Leadership and command skills will have been reinforced. Time in simulators will be more focused for flight situations. Preflight and inflight best practices will be refreshed. {NOTE: there is no mention here of the previously implemented 1,500 hour rule.}

 

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2 Comments on "Final Step in Pilot Professional Development Requirements Process"

  1. Robert D Reser | May 5, 2020 at 1:17 pm | Reply

    An excellent discussion of flight control was published in the 2014 Mar/Apr FAA Flight Safety Bulletin, page 13
    For an indepth discussion of Basic Flight Control, request e-book from bob@safe-flight.net.

  2. Paul Kolisch | May 6, 2020 at 3:14 pm | Reply

    I had the privilege of serving on a couple of ARCs before I retired from the airline. When the subjects were proposed, prior to establishing the ARCs resulting from HB 11-216, I wrote to Mrs. Hersman, who was Chairman of the NTSB at the time. I suggested that not only pilots, but airline management and FAA inspectors should be addressed in the development program.
    After more than 30 years flying with several regionals – including training and checking pilots in several other countries – I have seen too many occasions of regional managers abusing pilots. Until I arrived at Mesaba Airlines, I usually found resistance to discussion of safety matters that might absorb a few dollars or require some change in routine. (What a relief to be at Mesaba, where safety and compliance defined its essence.) Now that I have retired, I do not hide the fact that I lost four flying jobs for refusing to do dangerous, stupid, and/or illegal things. When I was removed from the examiners’ roster when I would not ignore the ATP standards for issuing a Type Rating, it sent a chilling message to my colleagues. Such results served as warnings in too many places for others inclined to comply with regulations and safe practices.
    There is an ironic injustice in place for pilots faced with the caprice of their employers. The law requires pilots to make decisions that do not always conform with the economic interests of their employers. If a pilot is sacked for abiding by the regulation, it serves as an unsettling warning for others. The FAA has no authority to either protect the pilot or punish an offending company in such circumstances. On the other hand, if the FAA catches a pilot engaged in cooperating with an employer that wants him to fly defective equipment or, perhaps, take an overweight airplane, the pilot will have no defense or support when he says the boss told him to do it! The PIC is responsible – even when the employer may enforce a “my way or the byway” policy.
    Complicating this atmosphere is the inclination of some FAA Inspectors to intimidate pilots with threatening letters when the pilots exercise their discretion to make judgments in the course of abnormal operations. There may be cause for discussion, but it should not be initiated as an attack.
    Pilot responsibilities include seeing to it that they arrive on duty with adequate rest and in good health – that is their obligation in order to meet the requirements of the medical certificate. Regardless, it is common for regional pilots to be harassed with threatening letters if they call in sick. Granted there are people who abuse the system, but many regional managers act as though most people who call in sick are not. (COVID 19 has forced change at heretofore guilty carriers.) Another health issue routinely ignored in regional airlines is hunger. It is not uncommon for regional pilots to have no more than 30-40 minutes between legs. These are not meal breaks: they are times for doing post- and pre-flight duties for the next leg. Prior to the economic collapse, it was not uncommon for pilots to be rostered ten and more hours without time for a meal break. Yet, the regional carriers that provide crew meals are the exception. Given the data that point to the importance of proper nourishment for critical thinking, it is hardly reasonable to permit pilots to fly hungry.
    If we want pilots to do their jobs right, we must see that they have the tools and the time to do so. We have fine training programs, and we hold pilots to technically high standards – the same standards at all 121 carriers. When the pilots go to work, they should have some confidence that the management will champion their efforts to get it all right. When they are confronted with challenges that require quick decisions – barring deliberate violations – they should expect support as they make their best judgments. This will require a cultural change in the industry and in some FAA circles: it cannot be legislated. The goals of the Board to achieve change in pilot behavior will require the managers of regional operations to proceed as though they are operating major airlines on a smaller, but not inferior, scale.

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