CANADIAN AVIATION REGULATION ADVISORY COUNCIL (CARAC) NOTICE OF PROPOSED AMENDMENT (NPA) CREW RESOURCE MANAGEMENT

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1 EXECUTIVE SUMMARY CARAC ACTIVITY REPORTING NOTICE #: Contemporary Crew Resource Management (CRM) concepts and training programs have been proven by aviation human factors experts to be effective in reducing aviation incidents and accidents. The current Canadian legal framework for CRM training for airline operations involves a basic approach to CRM training that does not reflect many contemporary CRM training concepts used by commercial pilots in Europe and the United States of America. In December 2014, Transport Canada (TC) published a Preliminary Issue and Consultation Assessment (PICA) to notify the aviation industry of its intent to propose new regulatory requirements pertaining to the CRM. The comment period yielded a total of eight comments from stakeholders with half from airlines operators. Out of the eight comments received, five clearly stated in their response that they were supporting the concept of CRM and three stakeholders confirmed their support for the consultation stream. At the exception of the support for the issue, no specific comments or suggestions were provided during the consultation period. This NPA addresses the issues presented in the PICA and other issues that arose in the process of preparing this document. The objective of the proposed amendments is to integrate CRM into commercial aviation crew training programs in accordance with Transportation Safety Board (TSB) recommendations and achieve harmonization with the United States Federal Aviation Administration (FAA), European Aviation Safety Agency (EASA) and the International Aviation Organization (ICAO). The proposed amendments will mainly affect subparts 722, 723, 724 and 725 of the Commercial Air Service Standards (CASS). BACKGROUND In October 2009, the Transportation Safety Board of Canada (TSB) recommended that TC require commercial air operators to provide contemporary CRM training for subparts 703 and 704 of the Canadian Aviation Regulations (CARs) (TSB recommendation A09-02). TC conducted a detailed Risk Assessment and in August 2010, the Risk Assessment team recommended that a balanced approach between the four areas of regulatory action, oversight, training and guidance be implemented. In September 2010, TC accepted the recommended regulatory action and at the September 2011 meeting of the Civil aviation Regulatory Committee. A CRM team comprised of Canadian aviation industry representatives, human factors experts and TC representatives was commissioned and tasked to develop a set of recommendations with respect to: Page 1 of 14

2 o A contemporary CRM training standard for pilots and flight attendants operating under subpart 705 of the CARs, which will enhance or replace the existing standard in subsection (39) of the CASS; o Contemporary CRM training standards for air taxi and commuter pilots operating under subparts 703 and 704 of the CARs, in order to extend a CRM training requirement to subsections 723 and 724 of the CASS for aeroplanes and helicopters; o o o A contemporary CRM training standard for aerial work pilots operating under subpart 702 of the CARs; Qualification requirements for CRM Instructors; and An accreditation program for CRM training providers. Contemporary CRM integrates technical skill development with communications and crew coordination training and in its latest iteration, operational risk management by applying threat and error management concepts. CRM is also the practical application of the various aspects of human factors, such as cognitive and interpersonal skills, including situational awareness, problem solving, decision making, threat and error management (TEM), team cooperation and communication among the various people who are involved in the operation of flights. STATEMENT OF THE PROBLEM AND POLICY CONSIDERATIONS The current regulatory framework is insufficient and does not reflect contemporary CRM concepts and methodology for aviation crew training programs used by commercial pilots working globally. CRM training is only required for airline flight and cabin crew operating under subpart 705 of the CARs. Transport Canada Civil Aviation (TCCA) conducted a risk assessment and committed to develop a contemporary CRM training standard for operations under subparts 703 and 704 of the CARs, as well as qualification requirements for CRM training providers, and an associated accreditation program. TCCA also decided to extend CRM training to aerial work pilots operating under subpart 702 of the CARs to improve aviation safety in all commercial flight operations, as recommended by TSB Recommendation A The current standard for CRM training for airline operations in subsection (39) of the Commercial Air Services Standards (CASS) published in 1996, involves a basic approach to CRM training that does not reflect many contemporary CRM training concepts which lead to an improved level of aviation safety. TCCA has committed to develop a contemporary CRM training standard to enhance or replace the existing CRM training standard in subsection (39) of the CASS. Additional sections of the CASS such as 722, 723 and 724 might need to be amended as well. Page 2 of 14

3 ANALYSIS SUMMARY Current Domestic Regulatory Framework: The current regulatory framework only addresses CRM training requirements for subpart 705 of the CARs. Subparts 702, 703 and 704 of the CARs do not include any CRM references. Section of the CARs requires the air operators to establish and maintain a training program that is designed to ensure that each person who receives training acquires the competence to perform the person s assigned duties and approved by the Minister in accordance with the CASS and in respect of flight attendants, in accordance with the CASS and the Flight Attendant Training Standard. Subsection (39) of the CASS requires an air operator to provide CRM including initial training for all crew members and shall cover the following subjects: attitudes and behaviours, communication skills, problem solving, human factors and conflict resolution, decision making, team building and maintenance and workload management. Nevertheless, the current legal requirements for CRM training for airline operations, involves a basic approach to CRM training that does not reflect many contemporary training concepts. The proposed changes will integrate CRM into aviation crew training programs and achieve harmonization with ICAO, EASA and the FAA. International Regulatory Framework: CRM training is a mandated requirement for commercial crews working under most regulatory bodies worldwide including the FAA, EASA and ICAO. The recent FAA Final Rule (CRM training) section requires that each certificate holder must have an approved crew resource management training program that includes initial and recurrent training. EASA has stated that human factors continue to be one of the significant causes of accidents and incidents. CRM as the effective utilisation of all available resources to achieve safe and efficient operation with emphasis of non-technical aspects of the crew performance is an important factor in this respect. (European Aviation Safety Agency, 2012). According to the EASA requirements, in order to strengthen the CRM performance, the flight crew, but also cabin crew and technical crew shall complete CRM training at various stages of their careers, including initial and recurrent training and on appointment to command and training must be carried out by approved instructors. Also, all personnel assigned to, or directly involved in ground and flight operations shall be properly trained, demonstrate their capabilities in the performance of their assigned duties and be aware of Page 3 of 14

4 their responsibilities and the relationship of their duties to the operation as a whole. (EASA -ORO. AOC 135). ICAO regulatory framework considers CRM to be part of human performance. ICAO Annex 6 Part 1 Chapter 9, Paragraph requires an operator to establish and maintain a ground and flight training programme approved by the State of the Operator, which ensures that all flight crew members are adequately trained to perform the assigned duties. (see CARAC Notice of Activity # PICA - Crew Resource Management, paragraph 7, ICAO Obligations). Additionally, ICAO acknowledges that the contemporary concept of the CRM is about people in their living and working situations, about their relationship with machines, with procedures and environment about them; and also about their relationship with other people at work. Triage Statement As there will be no change to the regulations, a triage for regulatory changes is not required. Recommended Consultation Stream As CARAC stakeholders and targeted stakeholders were consulted through a PICA, TCCA intends to conduct consultation on the NPA to be posted online through the CARAC Activity Reporting System and sent by to CARAC shareholders and additional targeted stakeholders for a consultation period of 45 days. RECOMMENDED SOLUTION Based on recommendations from the TSB, the joint TC-industry focus group recommended that the following 10 items replace the current CRM training Standard found in subsection (39) of the CASS, and the same Standard applies for subsections 702, 703, 704 and 705 of the CARs. 1. Threat and Error Management (errors are seen as a normal by-product of humans at work and bringing the errors back to the persons in day-to-day operations will then lead to a better understanding of human error and the CRM principles. Threat and error management can then be a part of the CRM training). 2. Communications 3. Situational Awareness 4. Pressures & Stress Page 4 of 14

5 5. Fatigue 6. Workload Management 7. Decision Making 8. Leadership & Team Building 9. Automation and Technology Management 10. Joint Annual Training- Safety Emergency Procedures (CAR 705 only) Contemporary CRM recurrent training will be conducted on an annual basis. The focus will be placed on Threat and Error Management (TEM), while discussing in-depth a minimum of three (3) additional elements of the standard. The scenario used in recurrent training should also be updated annually to reflect current safety trends within the operation and the industry. The contemporary CRM training can either be conducted as a distinct modular course, or it can be incorporated into other technical or non-technical training programs. TC will not mandate specific instructor qualifications for CRM instructors within the regulations, other than the general qualification of all training personnel as described in paragraph (4)(a) of the CASS, which should apply to all subparts. Operators shall be prepared to demonstrate to TCCA on request that their CRM instructor has, in addition to the general qualifications referred in paragraph (4)(a) of the CASS, competency to deliver the CRM course through an acceptable combination of skills, education and expertise. The following skills and knowledge of the Contemporary CRM instructor would be mandatory : - Knowledge of human factors; - Knowledge of the specific operation; - Knowledge of the company s and or industry s environment; - Knowledge of the company culture; - Credibility from related operational experience; - Technical knowledge. Private and commercial pilot s licence curriculum needs to be updated to include the topics in the revised Page 5 of 14

6 CRM training Standard, TC will review existing training requirements set out in the regulations and standards to ensure that there is not a duplication of regulatory requirements. This NPA will have a postdated applicability date. Consequently, TC will develop a transition plan for crews operating in the current environment that have not received CRM training previously. OBJECTIVES The overarching objective of these proposed amendments is to continue improving the safety of Canadians who travel by air. The specific objective is to improve the CRM knowledge and skills of commercial crew members engaged in a commercial air service by reviewing, amending and expanding the CASS on the CRM training. These amendments will integrate CRM into commercial aviation crew training programs in accordance with TSB recommendations and to achieve harmonization with the FAA, EASA, and the International Civil Aviation Organization (ICAO). The proposed amendments will affect subparts 722, 723, 724 and 725 of the Commercial Air Service Standards (CASS). The recommended revised standards will reflect contemporary concepts and are considered comprehensive and achievable. It will also remain current and allow for integration of future evolution of CRM concepts. PROPOSED CHANGES TCCA has committed to develop a contemporary CRM training standard to enhance the existing CRM training standard in subsection (39) of the CASS. Additional sections of the CASS such as 722, 723 and 724 will be amended as well, and the same Standards will apply to subparts 702, 703, 704 and 705 of the CARs. The enabling dispositions are : (1)&(2)(d)(iv), (1)&(2)(d), (1)&(2)(e) and (1)&(2)(e). Amendments to the following : The term contemporary crew resources management is not defined under the current regulatory framework. The following definition will be added under the Division I - General - Definitions of the Standard Airline Operations Aeroplanes, and under Aerial Work, 723 Standard 723 Air Taxi Aeroplanes and Helicopters and 724- Commuter Operations Aeroplanes and Helicopters of the Standards. Proposed definition for CRM "CRM is the effective utilisation of all available resources including crew members, Page 6 of 14

7 aircraft systems, supporting facilities and persons to achieve safe and efficient operations. The objective of CRM is to enhance communication, interaction, human factors and management skills of the crew members concerned. Emphasis is also placed on the non-technical aspects of crew performance." (39) of the CASS Current: Proposed: (39) Crew Resource Management Training for Crew Members Amend by enhancing or adding the following: An air operator shall provide Crew Resource Management Training (CRM) in accordance with the following: (a) Initial training is required for all crew members and shall cover the subjects in both (a) and (b): (i) attitudes and behaviours; (ii) communication skills; (iii) problem solving; (iv) human factors; (v) conflict resolution; (vi) decision making; (vii) team building and maintenance; and (viii) workload management. (b) Annual training in safety and emergency procedures. It shall include, as applicable, joint participation of pilots and flight attendants and cover the following items: Threat and Error Management Communications Situational Awareness Pressures & Stress Fatigue Workload Management Decision Making Leadership & Team Building Automation and Technology Management Page 7 of 14

8 (i) relationship of crew members; (ii) review of accidents/incidents of air operators; (iii) presentation and discussion of selected coordinated emergency procedures (practice of CRM skills); and (iv) crew member evacuation drills, including debriefing. Amendments to sections 722, 723 and 724 of the CASS: similar to the proposed amendments to (39) Other correlative amendments to the CASS: Review and remove references: TCCA will ensure that there is not a duplication of regulatory requirements. For example: VFR Flight Minimum Flight Visibility - Uncontrolled Airspace CASS (2) (c) Pilot Training & (1) (d) Pilot Training - Human performance factors, human error counter measures, good airmanship and Pilot Decision Making exams. Applicability The proposed amendments to the Standards will apply to the following operations: 1. All operators operating under subpart 705 of the CARs including: i. Flight crew; ii. Cabin crews; iii. Dispatchers/Flight followers; iv. Ground Crew; v. Maintenance The proposed new requirements will apply to: 2. All operators operating under subpart 704 of the CARs including: i. Flight crew; ii. Cabin crews; iii. Dispatchers/Flight followers; iv. Ground Crew; v. Maintenance 3. All operators operating under subpart 703 of the CARs including: i. Flight crew; Page 8 of 14

9 ii. Cabin crews; iii. Dispatchers/Flight followers; iv. Ground Crew; v. Maintenance 4. All operators operating under subpart 702 of the CARs including: i. Flight crew; ii. Cabin crews; iii. Dispatchers/Flight followers; iv. Ground Crew; v. Maintenance Current enabling provisions-cars The new amendments to the Standards must not be in conflict with the current provisions of the CARs which lay out the current general training programs that need to be established and maintained by every commercial air operator as required by the following provisions of the CARs. The following provisions are broad and state the same: any other training required to ensure a safe operation under this subpart (1) & (2) (d) (iv) Training Program 1) Every air operator shall establish and maintain a ground and flight training program that is (a) designed to ensure that each person who receives training acquires the competence to perform the person's assigned duties; and (b) approved by the Minister in accordance with the Commercial Air Service Standards. (2) An air operator's ground and flight training program shall include:(d) initial and annual training, including (vi) any other training required to ensure a safe operation under this Subpart (1) & (2)(d) Training Program (1) & (2)(e) Training Program (1) &(2)(e) Training Program NOTES: The following training will be tailored to the needs and size of the organization. CRM training should cover the operator s safety culture, its company culture, the type of operations and the associated procedures of the operator. This should include areas of operations that may lead to particular difficulties or involve unusual hazards. The guidance Page 9 of 14

10 material will be an advisory circular for the industry and a staff instruction for Transport Canada. (Flight crew - initial operator s training) 1.1 General Human factors in aviation General instructions on CRM principles and objectives Human performance and limitations Threat and error management 1.2 Relevant to the individual flight crew member Personality awareness, human error and reliability, attitudes and behaviors, self-assessment and self-critique Stress and stress management Fatigue and vigilance Assertiveness, situation awareness, information acquisition and processing 1.3 Relevant to the flight crew Automation and philosophy on the use of automation Specific type-related differences Monitoring and intervention 1.4 Relevant to the entire aircraft crew Shared situation awareness, shared situation acquisition and processing Workload management Effective communication and coordination inside and outside the flight crew compartment Page 10 of 14

11 1.4.4 Leadership, cooperation, synergy, delegation, decision-making, actions Resilience development Surprise and startle effect Cultural differences 1.5 Relevant to the operator and the organization Operator s safety culture and company culture, standard operating procedures (SOPs), organizational factors, factors linked to the type of operations Effective communication and coordination with other operational personnel and ground services. 2. Recurrent training shall compromise of the following: (Flight crew operator conversion course, recurrent CRM training and command course) 2.1 Ground training 2.2 A review of all basic CRM elements 2.3 Emergency and safety equipment training 2.4 Aircraft/FSTD training 2.5 Operator proficiency checks 2.6 Line checks These establish the ability to perform satisfactorily a complete line operation including pre-flight and post-flight procedures and use of the equipment provided The flight crew should be assessed on their CRM skills When pilots are assigned duties as pilot flying or pilot monitoring they should be checked in both functions Line checks are to be conducted by a commander nominated by the operator. Page 11 of 14

12 2.7 Flight crew incapacitation training 2.8 A personnel qualified to teach a CRM training course 3. Helicopters Emergency Medical Services (HEMS) Training 3.1 Familiarization with the helicopter type(s) operated 3.2 Entry and exit under normal and emergency conditions both for self and patients 3.3 Use of the relevant on-board specialist medical equipment 3.4 The need for the commander s approval prior to use of specialized equipment 3.5 Method of supervision of other medical staff 3.6 The use of helicopter inter-communication systems 3.7 Location and use of on board fire extinguishers 3.8 The operator s crew coordination concept including relevant elements of crew resource management 4. CRM Instructors (CRM trainer vs CRM instructor - CRM trainer/examiner - CRM trainer assessment) 4.1 Qualifications Adequate knowledge of CRM Adequate knowledge of Human Performance and Limitations (HPL) Have completed CRM training themselves Have completed additional training in group management, group personnel and group dynamics Have experience assessing the effectiveness of group training programs 4.2 Training Training shall be 24 hours or 40 hours without an instructor certificate for complex motor-powered Page 12 of 14

13 aircraft Training shall be theoretical and practical Training shall cover the development of trainer skills, particularly as they apply to CRM Training shall cover all the basic elements of the CRM training program Training shall include a review of emergency procedures Training shall include a review of handling safety and emergency equipment A refresher course may be no less than 8 hours. 4.3 Assessment To be completed by a CRM trainer examiner, who: a. Has demonstrated recent and relevant background experience in CRM protocol. b. Has completed at least two CRM training workshops in the last year The examiner will observe, record, interpret and debrief the trainer The trainer s assessment validation shall be no longer than three years and the trainer must conduct no less than two CRM training sessions per year for it to remain valid. 5. Program Assessment 5.1 The crew is to be assessed in an operational environment. 5.2 Non-Technical Skills (NOTECHS) assessment is a validated method for assessing CRM skills. It consists of four main categories: Cooperation Leadership and managerial skills Situation awareness Decision-making Page 13 of 14

14 5.3 The assessment shall be based on: Observable behavior CRM skills that enhance safety Behavior that contributes to a significant reduction in safety margins Additional training shall be available in the event of a failed assessment. *UNTIL APRIL 6, 2016, COMMENTS ON THIS NOTICE MAY BE ADDRESSED, IN WRITING, TO: carrac@tc.gc.ca *Comments received after the above mentioned deadline will not be considered in subsequent updates to this document or the Standards. Page 14 of 14