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Safety Recommendation Details

Safety Recommendation A-09-113
Details
Synopsis: On June 4, 2007, about 1600 central daylight time, a Cessna Citation 550, N550BP, impacted Lake Michigan shortly after departure from General Mitchell International Airport, Milwaukee, Wisconsin (MKE).1 The two pilots and four passengers were killed, and the airplane was destroyed. The airplane was being operated by Marlin Air under the provisions of 14 Code of Federal Regulations (CFR) Part 135 and departed MKE about 1557 with an intended destination of Willow Run Airport (YIP), near Ypsilanti, Michigan. At the time of the accident flight, marginal visual meteorological conditions prevailed at the surface, and instrument meteorological conditions prevailed aloft; the flight operated on an instrument flight rules flight plan.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require all 14 Code of Federal Regulations Part 91K and Part 135 operators to incorporate upset recovery training (similar to that described in the airplane upset recovery training aid used by many Part 121 operators) and related checklists and procedures into their training programs.
Original recommendation transmittal letter: PDF
Overall Status: Open - Acceptable Response
Mode: Aviation
Location: Milwaukee, WI, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: CHI07MA160
Accident Reports: Loss of Control and Impact with Water, Marlin Air Cessna Citation 550, N550BP
Report #: AAR-09-06
Accident Date: 6/4/2007
Issue Date: 10/27/2009
Date Closed:
Addressee(s) and Addressee Status: FAA (Open - Acceptable Response)
Keyword(s): Training and Education

Safety Recommendation History
From: NTSB
To: FAA
Date: 7/11/2019
Response: -From Daniel K. Elwell, Acting Administrator: On March 30, 2016, the FAA published the Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks Final Rule (81 FR 18177). This final rule amends the qualification performance standards for flight simulation training devices (FSTD) to improve existing and introduce new technical standards for full stall and stick pusher maneuvers, upset recognitions and recovery maneuvers, maneuvers conducted in airborne icing conditions, takeoff and landing maneuvers in gusting crosswinds, and bounced landing recovery maneuvers. This final rule also updates the FSTD technical standards to better align with the current international FSTD evaluation guidance, and introduces a new FSTD level expanding the number of qualified flight training tasks in a fixed-base flight training device. Pending the Board's review of the final rule, the FAA will consider further action to address these safety recommendations.

From: NTSB
To: FAA
Date: 10/2/2014
Response: We have reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled “Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks,” published at Federal Register 39462-39753 on July 10, 2014. An acceptable response to this recommendation requires that Parts 91K and 135 be subject to the same upset recovery training as was contained in the November 12, 2013, crewmember and dispatcher training final rule for pilots of Part 121 carriers. FSTDs with the necessary capabilities must be available to comply with such a requirement. The NPRM contains requirements necessary for FSTDs used by Parts 91K and 135 operators to be suitable for upset recovery training. This recommendation is currently classified “Open—Acceptable Response.” However, before this recommendation can be closed as acceptable, the FAA will need to implement a requirement for upset recovery training by Part 91K and 135 operators.

From: NTSB
To: FAA
Date: 6/13/2014
Response: We are aware that, on July 6, 2010, you published Information for Operators (InFO) Bulletin 10010, “Enhanced Upset Recovery Training,” which recommended that operators incorporate applicable material contained in the upset recovery training aid (URTA) into flightcrew training. The InFO also provided information on where the URTA could be found on the Internet. We have previously said that issuing the InFO constituted an appropriate interim action until the recommended rulemaking for Part 135 and Part 91, Subpart K, operators could be developed and issued. We have not heard from you about further progress in addressing this recommendation since November 22, 2010, when you said that future rulemaking might address upset recovery training for Part 135 operators as well. As we have previously stated, to complete the recommended action, you need to issue an appropriate final rule to require upset recognition and recovery training for Part 135 and Part 91, Subpart K, operators. Now that the final rule has been issued for Part 121 operations, please provide us information regarding the status of similar rulemaking for Part 135 and Part 91, Subpart K operations. Pending our receipt of your reply and completion of the recommended action, Safety Recommendation A-09-113 remains classified OPEN—ACCEPTABLE RESPONSE.

From: NTSB
To: FAA
Date: 5/12/2014
Response: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) draft Advisory Circular (AC) 120-UPRT, “Upset Prevention and Recovery Training,” which was posted for comment on the FAA’s website on March 12, 2014. Draft AC 120-UPRT describes the philosophy and recommended training for airplane upset prevention and recovery. The purpose of the AC is to provide recommended practices and guidance regarding academic and flight simulation device training for pilots to prevent the development of airplane upset conditions and ensure correct and consistent recovery responses to upsets. The AC was created from recommended practices developed by major airplane manufacturers, labor organizations, air carriers, training organizations, simulator manufacturers, and industry representative organizations. Although this AC is directed to air carriers in implementing 14 Code of Federal Regulations (CFR) Part 121 regulations, the FAA encourages all airplane operators, pilot schools, and training centers to implement upset prevention and recovery training and to use the guidance contained in the AC, as applicable to the type of airplane in which training is conducted. We generally support the draft AC (with specific suggestions below). On November 12, 2013, the FAA published a final rule titled “Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers.” Draft AC 120 UPRT and draft revised AC 120-109A provide the guidance necessary for operators and FAA inspectors to implement the requirements in the final rule. On February 15, 2011, the FAA published Information for Operators (InFO) Bulletin 10010, “Enhanced Upset Recovery Training,” which recommends that operators consider incorporating applicable material contained in the upset recovery training aid into flight crew training. We indicated that we regarded the InFO to be an appropriate interim action until the recommended rulemaking for Part 135 and Part 91 subpart K operators could be developed and issued. To complete the recommended action, the FAA needed to issue an appropriate notice of proposed rulemaking and final rule to require upset recognition and recovery training for Part 135 and Part 91 subpart K operators. Pending that action, we classified Safety Recommendation A 09 113 as “Open—Acceptable Response.” Draft AC 120 UPRT provides useful information for Part 135 and Part 91 subpart K operators to incorporate into their training programs. However, we would still urge the FAA to issue a final rule requiring such training.

From: NTSB
To: FAA
Date: 4/30/2012
Response: Notation 8406: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled “Pilot Certification and Qualification Requirements for Air Carrier Operations,” which was published at 77 Federal Register (FR) 12374 on February 29, 2012. The notice proposes to create new certification requirements for pilots in air carrier operations, including requiring that first officers in 14 Code of Federal Regulations (CFR) Part 121 operations hold an airline transport pilot (ATP) certificate and type rating for the aircraft to be flown; allowing pilots with an aviation degree or military pilot experience but fewer than 1,500 hours total time as a pilot to obtain an ATP certificate with restricted privileges; and requiring at least 1,000 flight hours in air carrier operations to serve as pilot in–command (PIC) in Part 121 air carrier operations. The notice also proposes to modify the requirements for obtaining an ATP certificate with an airplane category multiengine class rating or type rating to require 50 hours of multiengine flight experience and completion of a new FAA-approved ATP certificate training program that would include academic training and training in a flight simulation training device. According to the NPRM, these changes would help to ensure that pilots entering an air carrier environment have the training and aeronautical experience necessary to adapt to a complex, multicrew environment in a variety of operating conditions. The NPRM cites the 2009 Colgan Air accident near Buffalo, New York, as an event that focused public, congressional, and industry attention on flight crew experience requirements and training for conducting Part 121 air carrier operations. In February 2010, the FAA published an advance notice of proposed rulemaking (ANPRM), titled “New Pilot Certification Requirements for Air Carrier Operations” (75 FR 6164, February 8, 2010) that sought input on current Part 121 eligibility, training, and qualification requirements for seconds-in-command (SICs). The current NPRM is based on comments in response to the ANPRM, input received from an aviation rulemaking committee established in July 2010, and statutory requirements for modifying ATP certification outlined in the Airline Safety and Federal Aviation Administration Extension Act of 2010 (Public Law 111-216). Adding to that foundation, the NPRM states that the FAA conducted a study of 61 NTSB investigation reports from fiscal year (FY) 2001 through FY 2010 (31 Part 121 accidents and 30 Part 135 air carrier accidents, with 107 fatalities, 28 serious injuries, and 44 minor injuries). The study showed that the accidents examined involved pilot deficiencies in aircraft handling, including stall and upset recognition and recovery, high altitude training, active pilot monitoring skills, effective crew resource management (CRM), stabilized approaches, operations in icing conditions, and hypoxia training. The NPRM asserts that the changes to air carrier pilot qualification would address, in part, 21 NTSB safety recommendations in the following areas: Safety Issue Recommendations Training flight crews to respond to sudden, unusual, or unexpected aircraft upsets: A-96-120, A-04-62, A-07-3, and A-09-113 Developing and conducting stall recovery training and providing stickpusher familiarization training for pilots of stickpusher-equipped aircraft: A-10-22 and -23 Training in high altitude operations: A-07-1 and -2 Training and guidance for rudder use in transport-category aircraft: A-02-2 Airport situational awareness: A-07-44 Stabilized approach concept: A 01 69 and A-08-18 Landing performance calculations: A-07-59 and A-08-41 CRM training: A-03-52 Pilot monitoring duties: A-10-10 Requirements for flight crewmember academic training regarding leadership and professionalism: A-10-15 Training in icing conditions: A-07-14 Hypoxia awareness training: A 00 110 Training in landing and taking off in crosswinds with gusts: A 10-110 and -111 The NTSB is generally supportive of the proposed rule as it relates to many of the issues previously identified in our safety recommendations. Specific comments on several areas of the NPRM follow. Academic Credit To Reduce Flight Experience Requirements Although the NTSB has not made recommendations for flight hour minimums for air carrier pilots (instead focusing its recommendations on specific procedures and training, needed regulations, and needed guidance to crews and operators), we stated in our comments on the ANPRM that: Ensuring a high level of knowledge, skills, and professionalism for flight crewmembers is essential, but total flight hours or an airline transport pilot certificate does not necessarily equate to the level of knowledge, skills, and professionalism required for consistently safe flight operations. The comments went on to state that, “the NTSB recognizes the value of academic training for air carrier pilots, but the NTSB also believes that academic training is not a substitute for practical experience.” An important tenet in the recent NPRM is the concept that, “in certain circumstances, the combination of focused academic training and structured flight training can substitute for actual flight experience” (p. 12379). The NTSB concurs with the FAA’s acknowledgement that there may be multiple pathways to becoming a qualified air carrier pilot. However, there remain unresolved issues for how academic credit should be applied, including student performance within an accredited academic program and the type of degree conferred. These issues are not addressed in the NPRM and require more evaluation before this proposal is implemented. It is essential that the content and rigor involved in academic training be clearly defined and, most importantly, appropriate resources allocated to conduct evaluation and oversight of these alternative methods of qualification. ATP Certification Training Program The NPRM discusses the establishment of an FAA-approved ATP certificate training program for a multiengine class ATP or type rating. The proposed training program outlined under section 61.154 would include 24 hours of classroom training and 16 hours of simulator training (8 in a full flight simulator of at least Level C standards) and is intended to provide pilots with the core knowledge and understanding in areas critical to operating high performance aircraft in a complex and high altitude environment. The training would be provided by an authorized training provider and would be required to be completed before a pilot would be eligible to take the ATP knowledge test. Issued as part of the NPRM, draft Advisory Circular (AC) 61-ATP, “Airline Transport Pilot Certification Training Program for Airplane Category Multiengine Class Rating or Type Rating,” contains an outline of the curriculum topics and objectives for both the classroom and simulator training making up this training program. The AC is intended for use by training providers when developing the program and by the FAA when reviewing and approving the programs. Many of the topics contained in the draft AC address issues from NTSB safety recommendations; in fact, the FAA notes that most of the 21 recommendations cited in the NPRM are addressed, in part, by the proposed amendments and advisory material. Although the NTSB concurs with the FAA’s assessment that, in most cases, the topics addressed will serve to partially satisfy the action requested in existing recommendations, the amount of specificity provided in the proposed rule and AC does not allow a comprehensive review of the degree to which the FAA’s proposed actions would satisfy the intent of the NTSB’s recommendations. In some instances, neither document provides evidence that a recommendation topic is addressed. The NTSB notes that recent safety recommendations in this area have focused on attempts to improve crew response to in-flight emergencies, including task prioritization and training. While AC 61-ATP does include a classroom training objective named “differences between emergency and non-normal checklist procedures and checklists,” the guidance on emergency procedures should be made more explicit to incorporate the issues identified in these NTSB recommendations. CRM is another topic relevant to previous NTSB recommendations and outlined in AC 61-ATP. However, the list of proposed topics in the AC does not explicitly refer to the importance of first officer assertiveness, which is an issue addressed in Safety Recommendation A-11-39. This recommendation is not cited in the NPRM, but the NTSB believes that it is within the scope of the draft advisory material and suggests amending the AC to include information consistent with Safety Recommendation A-11-39 to help support this important aspect of CRM. The NTSB is encouraged that the NPRM proposes to centralize the process for approving ATP certification training programs. Specifically, the NPRM states that only authorized training providers can administer the training required under section 61.154. These providers can be certificate holders providing training and operating under Parts 141, 142, 121, or 135, and each provider must receive approval of their ATP certification training program by the FAA Air Transportation Division (AFS-200). The NTSB notes that, theoretically, centralization should help to ensure standardization of these programs, but suggests that additional guidance documentation with more specific and robust detail about the content of the proposed training is necessary to provide a solid foundation on which the FAA can evaluate the program content (and to assist training providers to develop courses likely to receive FAA approval). For example, additional detail, such as cross-referencing material from draft AC 120-STALL, would be appropriate in the discussion of stall training in AC 61-ATP. In addition, the FAA will need to provide the appropriate oversight resources to these programs—not only in their initial approval but also to conduct ongoing oversight to demonstrate that the content delivered is consistent with the approved program. The rigor with which these programs are implemented and overseen will determine their ultimate influence on improving safety in air carrier operations. Pilot-in-Command Requirements for Air Carrier Operations The NPRM proposes primarily experience-based requirements for new PICs in air carrier operations. However, the NTSB has previously issued safety recommendations addressing the need for a specific leadership training course for upgrading captains. Although the NPRM cites Safety Recommendation A-10-15 and describes it as applicable to leadership and professionalism training, it addresses only the latter topic. The NPRM does not mention Safety Recommendations A-10-13 and -14, which were issued with -15, but the NTSB believes that a leadership training course for upgrading captains is within the scope of the proposed rulemaking and that section 121.436 should be amended to include a specific requirement for such a course. In addition to the requirements already outlined in section 121.434, the NTSB has recommended that Part 135 pilots who need a type rating for the aircraft they fly be required to have a minimum level of initial operating experience. Given the applicability of the NPRM to Part 135 pilots who are engaged in air carrier operations, the NTSB believes it would be appropriate to incorporate similar experience requirements for these pilots as exist for Part 121 pilots. The NTSB supports the use of simulators in training environments and notes that the training program outlined in the NPRM specifies that training on topics such as low energy states/stalls and upset recovery techniques will be conducted in a Level C or higher full-flight simulator. Simulators, regardless of their fidelity, are dependent on their physical limits of motion, as well as the efficacy of the available computer programs (which are often limited in issues of upset training because of the lack of flight test data at the extreme areas of the flight envelope). Simulators are not always adequate in portraying upsets and stalls and may inadvertently introduce negative training. Consistent with Safety Recommendation A-04-62, the FAA should allow flexibility in determining what level of simulation or automation is appropriate for specific training. Summary Observations This NPRM addresses many training issues applicable to becoming an air carrier pilot, including some critical issues demonstrated in recent accident history to be responsible for accidents. The NTSB is encouraged that its recommendations were considered in the development of this proposed rule, especially as the issue areas relate to the core content to be provided to new entrant pilots through the ATP certification training program. However, the intent of our recommendations in this area is for all pilots to receive training in these topics. Therefore, it is important that air carriers provide equally robust training in these topic areas for their current air carrier pilots on a recurrent basis. The NTSB appreciates the opportunity to comment on this NPRM.

From: NTSB
To: FAA
Date: 2/15/2011
Response: On July 6, 2010, the FAA published Information for Operators (InFO) bulletin 10010, “Enhanced Upset Recovery Training,” which recommends that operators consider incorporating applicable material contained in the upset recovery training aid (URTA) into flightcrew training. The InFO also provides information on where the URTA can be found on the Internet. The NTSB has previously informed the FAA that issuing an InFO would be an appropriate interim action until the recommended rulemaking for Part 135 and Part 91, subpart K, operators could be developed and issued. As discussed above, the FAA is currently developing this rulemaking for Part 121 operations and has indicated that it is considering similar actions for Part 135 operators. The NTSB notes that the actions specified in Safety Recommendation A-09-113 are needed for both Part 135 operations and Part 91, subpart K, operations. Issuance of the InFO completes the interim action being taken. To complete the recommended action, the FAA now needs to issue an appropriate NPRM and final rule to require upset recognition and recovery training for Part 135 and Part 91, subpart K, operators. Pending completion of the recommended action, Safety Recommendation A-09-113 remains classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 11/22/2010
Response: MC# 201000423: - From J. Randolph Babbitt, Administrator: On July 6, 2010, the Federal Aviation Administration published Information for Operators (InfO) 10010, Enhanced Upset Recovery Training (enclosure). The InFO was addressed to part 121, 125, 135, and 91K operators and part 142 training centers. InFO 10010 recommends operators consider incorporating applicable material contained in the upset recovery training aid (URTA) into flightcrew training. It also provides information on where the URTA can be found on the Internet. The FAA will continue to improve the URTA's exposure and promote training in this arena to the extent of current simulator capabilities. We recognize loss of control is a universal problem that applies to all types of operations. The FAA has decided to take measured steps in addressing upset recovery training for certificated operators. We anticipate publishing the Supplemental Notice of Proposed Rulemaking (SNPRM), Qualification, Service and Use of Crewmembers and Aircraft Dispatchers, later this year. It contains language that addresses upset recovery training for part 121 operators. While this SNPRM only addresses part 121 operations, future rulemaking may address upset recovery training for part 135 operators as well. I will keep the Board informed of our progress on these recommendations and provide an updated response by November 2011.

From: NTSB
To: FAA
Date: 11/17/2010
Response: The NTSB is pleased that the FAA supports rulemaking to require upset recovery training for 14 CFR Part 91K and Part 135 operators and is evaluating what regulatory changes will be needed. The NTSB also believes that the planned publication of an Information for Operators (InfO) document to highlight the Airplane Upset Recovery Training Aid is an appropriate interim step in addressing this recommendation. Accordingly, pending issuance of the recommended requirement, Safety Recommendation A-09-113 is classified OPEN – ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/28/2010
Response: Letter Mail Controlled 5/5/2010 12:17:19 PM MC# 2100167 - From J. Randolph Babbitt, Administrator: The Federal Aviation Administration is in continuous development of new training regulations and policies. We agree that the Airplane Upset Recovery Training Aid contains valuable information for all operators and we also believe rulemaking is the correct vehicle for this type of change. We are evaluating this recommendation to determine what regulatory changes would be needed to implement this safety recommendation. In the interim, the FAA will publish an Information for Operators (InFo) to all operators highlighting the merits of the Airplane Upset Recovery Training Aid and its availability on the Internet. This InFo will be published by July 3 1, 20 10. I will provide an update on the progress of this safety recommendation by September 30, 2010.