Notation 8106A: The National Transportation Safety Board has reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled, “Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers,” which was published in 74 Federal Register 1280 on January 12, 2009.
The notice proposes to amend the regulations for flight and cabin crewmembers and dispatcher training programs in domestic, flag, and supplemental operations. Proposed changes include requiring the use of flight simulation training devices (FSTD) in traditional flight crewmember training programs and adding training requirements in safety-critical areas. In addition, the proposal reorganizes qualifications and training requirements in the existing rule by moving several sections of advisory information to the regulatory section. The NPRM also addresses issues raised in numerous safety recommendations issued to the FAA by the Safety Board; 13 of these recommendations remain open.
The Safety Board generally supports the proposed rule changes. However, the Board suggests additional requirements, including substantive changes that improve or enhance crew and dispatcher procedures, qualifications, and training and the replacement of advisory circulars and other recommended guidance with regulatory changes requiring compliance.
At an April 7, 2009, presentation on the NPRM, the Safety Board learned that the FAA principle regarding training is “Train like you fly and fly like you train.” The Board agrees with this principle and with several initiatives that are especially appropriate for flight operations in today’s environment. For example, the Board supports the NPRM’s proposals for adding a continuous analysis process and FSTDs in training programs, requiring special hazards and environment training, and establishing qualifications for training centers and other 14 Code of Federal Regulations (CFR) Part 119 facilities. The Board also concurs with the FAA that it is important for flight crewmembers to be trained and evaluated in a complete flight crew environment, which means that, during training for pilot flying and pilot monitoring roles, crewmembers should occupy the seats for—and perform the duties of—the position for which they are being trained.
The Safety Board is aware that, in the past, some considered upset recovery training to be inappropriate due to limitations in aerodynamic model fidelity; however, unusual attitudes do not equate to being outside the angle of attack and sideslip range of the aerodynamic model. Many, if not most, upsets occur well within this envelope. Therefore, the Board concurs with the FAA’s “Airplane Upset Recovery Training Aid” referenced in the NPRM and believes that training could be further improved by feedback to the pilot from the simulator. The training aid suggests that, in a scenario in which the pilot has maneuvered the simulator to an extremely high angle of attack or sideslip, there should be a change in the visual display when the aerodynamic envelope is exceeded; specifically, a color change would alert pilots that they are at an angle of attack or sideslip that should be avoided during recovery efforts.
The Safety Board notes that some aircraft, such as the Saab 340 and Bombardier CRJ, have experienced upsets due to premature stall caused by icing. Because icing contamination can cause the critical angle of attack to be reduced considerably, these upsets can occur without warning. A stall roll-off departure from normal flight is often the flight crew’s first indication of an upset due to icing contamination; however, the Board has found that flight crews often do not apply decisive and timely recovery controls when this occurs, which results in prolonged upsets that increase the probability of ground impact. For aircraft that have experienced upsets due to icing contamination, the Board suggests that upset recovery training should include recognition of these excursions from normal flight attitudes and prompt application of proper recovery procedures.
Although the NPRM continues to encourage the traditional training approach to stall recovery (recovery from stick shaker), the Safety Board is concerned that flight crews are not recognizing stalls and are not applying aggressive recovery procedures, as indicated by several aviation events. Among these events is the October 14, 2004, accident in which a Bombardier CL-600-2B19 crashed in Jefferson City, Missouri, when the flight crew was unable to recover after both engines flamed out as the result of a pilot-induced aerodynamic stall. Another example occurred during a December 22, 1996, accident in which a Douglas DC-8-63 experienced an uncontrolled flight into terrain in Narrows, Virginia, after the flying pilot applied inappropriate control inputs during a stall recovery attempt and the nonflying pilot failed to recognize, address, and correct these inappropriate control inputs. Because of examples like these, the Board advises that training in stall recovery should go beyond approach to stall to include training in recovery from a full stall condition. In addition, in cases when flight data are available (whether from flight test or accidents/incidents), these data should be used to model stall behavior to facilitate training beyond the initial stall warning.
If the proposed rule becomes final, it would likely meet the intent of 5 of the 13 open safety recommendations related to crewmember training. The following is a list of the 13 recommendations and an explanation of whether or not the NPRM addresses each of them.
Amend 14 CFR Parts 121, 125, and 129 to require Traffic Alert and Collision Avoidance System [TCAS] flight simulator training for flight crews during initial and recurrent training. This training should familiarize the flight crews with TCAS presentations and require maneuvering in response to TCAS visual and aural alerts.
The NPRM contains requirements for TCAS training, as recommended. Therefore, the NPRM is responsive to the recommendation. If the NPRM (as currently presented) becomes a final rule, the Safety Board likely will consider it an acceptable action, and the recommendation will be closed. The Board notes that this is currently the oldest open aviation recommendation.
Revise 14 CFR Section 121.445 to eliminate subparagraph (c), and require that all flight crewmembers meet the requirements for operation to or from a special airport, either by operating experience or pictorial means.
The NPRM proposes the following language for 14 CFR 121.1235(c): “The Administrator may determine that certain airports (due to items such as surrounding terrain, obstructions, or complex approach or departure procedures) are special airports requiring special airport qualifications and that certain areas or routes require a special type of navigation qualification.” In addition, special routes, areas, and airports for special operations are among the subjects in the NPRM’s list of required training. Therefore, the NPRM is responsive to the recommendation. If the NPRM (as currently presented) becomes a final rule, the Safety Board likely will consider it an acceptable action, and this recommendation will be closed.
Revise the certification standards for Part 25 and for Part 23 (commuter category) aircraft to require that a flight simulator, suitable for flight crew training under Appendix H of Part 121, be available concurrent with the certification of any new aircraft type.
The NPRM proposes a requirement that a flight simulator be available for training. The Safety Board has previously indicated that such a requirement would be an acceptable alternative response to a design requirement for an aircraft. Therefore, if the proposed rule becomes final, the Safety Board likely will consider it an acceptable action in response to the recommendation.
Require, by December 31, 1997, operators that conduct scheduled and nonscheduled services under 14 CFR Part 135 in Alaska to provide flight crews, during initial and recurrent training programs, aeronautical decision-making and, judgment training that is tailored to the company’s flight operations and Alaska's aviation environment, and provide similar training for Federal Aviation Administration principal operations inspectors [POI] who are assigned to commuter airlines and air taxis in Alaska, so as to facilitate the inspectors’ approval and surveillance of the operators’ training programs.
The FAA has previously indicated to the Safety Board that the NPRM would include aeronautical decision-making and judgment in the crew resource management portion of the proposed training rule. However, Safety Recommendation A 95 124 is specific to Part 135 operations in Alaska, while the NPRM addresses Part 121 operations. Therefore, the FAA has not supplied a satisfactory response. Thus, the NPRM, as drafted, would not meet the intent of this recommendation, and the status would remain “Open—Unacceptable Response.”
Develop a controlled flight into terrain training [CFIT] program that includes realistic simulator exercises comparable to the successful windshear and rejected takeoff training programs and make training in such a program mandatory for all pilots operating under 14 CFR Part 121.
The NPRM proposes to require special hazards training, including methods for preventing CFIT and approach and landing accidents. Therefore, if this requirement is included in the final rule, the Safety Board likely will consider it an acceptable action, and the recommendation will be closed.
Require 14 CFR Part 121 and 135 operators to provide training to flight crews in the recognition of and recovery from unusual attitudes and upset maneuvers, including upsets that occur while the aircraft is being controlled by automatic flight control systems, and unusual attitudes that result from flight control malfunctions and uncommanded flight control surface movements.
The Safety Board is pleased that, in response to Safety Recommendation A-96-120, the NPRM includes training on recognizing and recovering from “special hazards,” which are sudden or unexpected aircraft upsets. The Board interprets that this proposal would also include a requirement that gives FAA POIs the authority to review and require changes to training programs that do not adequately address a special hazard. Lack of such authority was a concern identified during the Board’s investigation of a November 12, 2001, accident involving American Airlines flight 587, an Airbus Industrie A300 605R. During this investigation, the Board learned that the POI knew that aspects of American Airlines’ training program had undesirable effects; however, he lacked the authority to force American to change its program.
In addition, a topic covered in the special hazards training section of the NPRM is recovery from loss of control due to airplane design, airplane malfunction, human performance, and atmospheric conditions. The “Upset Recognition and Recovery” section of the NPRM lists a number of items that should be covered, including catastrophic damage due to rapidly reversing controls and the use of light pedal forces and small pedal movements to obtain the maximum rudder deflection as speed increases.
This recommendation is currently classified “Open—Unacceptable Response” because of the FAA’s delayed response. Although the NPRM proposes requirements for Part 121 operators, similar action for Part 135 operators will be needed before Safety Recommendation A-96-120 can be closed.
Require air carriers to adopt the operating procedure contained in the manufacturer’s airplane flight manual and subsequent approved revisions or provide written justification that an equivalent safety level results from an alternative procedure.
The FAA has previously indicated to the Safety Board that the NPRM would address the issues in this recommendation. However, the Board did not see any language in the NPRM that specifically addresses Safety Recommendation A-98-102, which is currently classified “Open—Acceptable Response” pending a requirement for the action recommended.
Amend 14 [CFR] 121.417 to require participation in firefighting drills that involve actual or simulated fires during crewmember recurrent training and to require that those drills include realistic scenarios on recognizing potential signs of, locating, and fighting hidden fires.
The NPRM addresses the substantive issues in this recommendation. Although the NPRM does not propose to revise 14 CFR 121.417, it contains training requirements on the actions to take in the event of fire or smoke in the aircraft, including realistic drills with emphasis on combating hidden fires. This training includes simulated locations of hidden fires, such as behind sidewall panels, in overhead areas and panels, or in air conditioning vents. The NPRM also contains firefighting training requirements for flight attendants, including operation of each type of installed hand fire extinguisher. This recommendation is currently classified “Open—Unacceptable Response” pending a requirement for the recommended action. If the requirements proposed in the NPRM are enacted in the final rule, the Safety Board likely will consider it an acceptable action, and this recommendation will be closed.
Require all 14 [CFR] Part 121 and 135 air carriers to incorporate bounced landing recovery techniques in their flight manuals and to teach these techniques during initial and recurrent training. (A-05-30)
Although the NPRM contains detailed requirements for training on landing, the Safety Board did not see anything in the NPRM related to bounced landing recovery techniques. This recommendation is currently classified “Open—Acceptable Alternate Response” pending the results of a survey indicating that all operators’ training programs include the recommendations in a Safety Alert for Operators.
Require that all 14 [CFR] Part 91K, 121, and 135 operators establish procedures requiring all crewmembers on the flight deck to positively confirm and cross-check the airplane’s location at the assigned departure runway before crossing the hold short line for takeoff. This required guidance should be consistent with the guidance in Advisory Circular 120-74A and Safety Alert for Operators 06013 and 07003.
The NPRM contains training requirements related to runway safety. Special hazards topics must include how to ensure that takeoff clearance is received and that the correct runway is being entered for takeoff before crossing the hold short line. This recommendation is currently classified “Open—Unacceptable Response” because of continuing delays in the issuance of this NPRM. If the NPRM becomes final, the proposed requirement is partly responsive to this recommendation because it addresses only Part 121 operators. Action will still be needed for Part 135 and Part 91 subpart K operators for this recommendation to be closed.
Require air carriers to revise their cabin crew training manuals and programs to ensure that the manuals and programs state that a door must remain open while the air conditioning (A/C) cart is connected, advise that the A/C cart can pressurize the airplane on the ground if all doors are closed, and warn about the dangers of opening any door while the air conditioning cart is supplying conditioned (cooled or heated) air to the cabin.
The NPRM proposes a requirement for training that will familiarize cabin crewmembers with each aircraft on which they will work. Among these aircraft familiarization requirements are cabin pressurization indicators and systems. However, the NPRM does not fully address the recommended action because it only addresses specific actions to take when the door remains open while the A/C cart is connected. This recommendation is currently classified, and would remain, “Open—Acceptable Response” pending timely and acceptable revisions to Notice 8400.35 and Order 8900.1.
Require 14 [CFR] Part 121, 135, and Part 91 subpart K operators to include, in their initial, upgrade, transition, and recurrent simulator training for turbojet airplanes, (1) decision-making for rejected landings below 50 feet along with a rapid reduction in visual cues and (2) practice in executing this maneuver.
The NPRM proposes a requirement to use a simulator for training on rejected landing maneuvers, including the initiation of a rejected landing between 30 and 50 feet above the runway. Thus, the NPRM addresses the second part of this recommendation “practice in executing this maneuver.” In addition, although the NPRM did not specifically address decision-making, this topic may be covered during training in the maneuver. Safety Recommendation A 08 16 is currently classified “Open—Response Received.” The NPRM partially responds to the recommendation because it addresses only Part 121—and not Part 135 or Part 91 subpart K—carriers. Action for Part 135 and Part 91 subpart K operators will still be needed for this recommendation to be closed.
Require 14 [CFR] Part 121, 135, and Part 91 subpart K operators to include, in their initial, upgrade, transition, and recurrent simulator training for turbojet airplanes, practice for pilots in accomplishing maximum performance landings on contaminated runways.
The Safety Board did not find any language describing how to accomplish maximum performance landings on contaminated runways. In addition, any proposed requirements associated with this NPRM would only apply to Part 121 carriers and not Part 135 or Part 91 subpart K operators. This recommendation is currently classified “Open—Response Received.”
Thank you for the opportunity to comment on this NPRM.