Maintaining Qualified Instructors
Trainer Qualification Is As Important As Crew Qualification
Although vitally important in maintaining the legality and qualification of crewmembers, training departments have not historically received senior management attention. But with increased focus on crew qualifications — and complexities in regulations and qualification parameters — carriers are challenged to place training in proper perspective to avoid excessive costs and further resource restriction.
Clearly, training is a vital function. And with regard to training, compliance is a necessity — one that can easily be taken for granted because everyone involved often assumes that crewmembers operating an airline’s fleet are current on their training qualifications.
Fortunately, in many cases they are — as are the airline mechanics and other industry professionals who are also required to be qualified and current. However, it is important to keep in mind that it only takes one case of non-compliance to lead to a negative financial — or even more serious — impact.
In addition to the potential disastrous impact of qualification currency, the crucial nature of qualification tracking and compliance can also have significant financial impact. The monetary penalties for a non-current instructor performing training and/or evaluation can quickly accumulate.
Luftfahrt-Bundesamt (LBA), the German equivalent to the U.S. Federal Aviation Administration, tracks all exams and pilot evaluator currency in a central database. If the examiner is not current, any exams performed will become invalid, and the examined pilot will be declared not current.
The examiner will be charged for the reexamination of the pilot and may face legal consequences, such as the loss of his or her evaluator’s license. The airline will face monetary losses due to crewmembers not being cleared to fly. Additionally, there will be expenses for repeated exams as well as the need for additional resources, such as simulators, aircraft and rooms that will need to be rescheduled, often causing bottlenecks in the planning cycle.
According to U.S. Federal Aviation Administration regulations, a penalty of US$10,000 may be assessed for each leg that each pilot flies under circumstances in which that pilot has been trained and/or evaluated by an unqualified instructor.
For example, if an instructor is non-current for just two weeks, during which he or she evaluates eight crews, those two weeks can initiate an enormous domino effect. If the crews fly 10 legs each before the instructor’s status is discovered, this situation could potentially result in a fine of more than US$1.5 million.
In other jurisdictions, such as Germany, when non-compliant instructors are identified, students of that instructor require reexamination, and associated reexamination costs apply.
Typically, it is the responsibility of airline training departments to ensure personnel are qualified and current. A deeper dive into the operations of the training department can yield a much greater understanding and appreciation regarding the volume and accuracy of its work.
The training department must transform regulatory and service requirements into instructional courses. It then schedules courses, simulators and flight instructors and ensures all crewmembers are qualified and current.
Add the pressure to maximize the use of expensive simulator and instructor resources, and it becomes clear just how many constraints the department must function under.
In recent years, in fact, new requirements have been introduced into crew qualifications, with the advent of additional qualification processing. Furthermore, the traditional syllabus-based educational approach has become somewhat more fluid and is now focused more on performance rather than simply on a completion date and a projected date for recurrent training.
The instructors and operations personnel are tasked with fully understanding the requirements, properly conducting the courses and signing off on crewmembers who successfully complete the training.
Meeting The Challenge
While an airline’s focus may typically be on the output (qualified personnel) of the training department, a better understanding of the challenges and vital importance of maintaining qualified instructors may actually improve the carrier’s success rate in the department’s real output.
Maintaining qualified instructors is a critical first step toward qualified crewmembers and other personnel. Therefore, it is imperative for an airline to understand the considerable challenges and pitfalls associated with this task:
- Various interpretations of compliance rules can lead to their incorrect application.
- Multiple methods for tracking the expiration of an instructor’s qualifications can lead to confusion.
- Additional resources are needed to develop, maintain and enforce consistent guidelines and interpretations, which means additional costs.
- Unclear assignment of responsibility and/or accountability to maintain instructor-training records can lead to numerous organizational headaches over time.
Whether considered separately or together, these factors can result in instructors who are training students on segments and events for which they themselves are not qualified. Unqualified instructors equal a non-compliant airline.
The consequences of utilizing non-compliant instructors or personnel, in addition to monetary fines, are severe and include:
- Temporary cancellation of qualifications and/or closure of the training department, while instructors must devote significant time to “recertify” their qualifications,
- Additional costs to retrain students who trained while the instructors were non-compliant,
- Implementation of additional rules and regulatory oversight, depleting valuable personnel and monetary resources.
Airlines can take numerous steps to significantly reduce the risk of non-compliance in the area of qualification management.
First, it is strongly recommended that a carrier implement a process to closely monitor compliance, giving careful consideration to:
- Documentation — Clearly document the rules for currency tracking, meaning to track crewmembers who are current in their training.
- The interpretation of rules — Rules are often delineated and presented in legalistic language, which may lead to varying interpretations. Definitions must be agreed upon and, of course, must be approved by the necessary authorities or inspectors.
- Roles and responsibilities — Roles and responsibilities should be thoroughly documented and discussed to effectively manage a proper set of qualification rules.
- Consequences of non-compliance — Ensure personnel who have specific roles thoroughly understand their responsibilities to ensure compliance.
A typical instructor may be qualified in a number of areas such as line pilot, pilot instructor and pilot evaluator training.
These qualifications may require some initial training and/or prerequisites as well as co-requisites, meaning the qualification is dependent on the full validity of other qualifications.
For example, to maintain his or her current status, a line pilot may have to satisfy a specific set of requirements, such as:
- A number of flying days each month,
- A number of landings made every 90 days,
- A current and satisfactory medical evaluation.
A pilot instructor is typically indoctrinated through an instructor training course. After he or she completes training, his or her pilot-instructor qualification is then dependent on line-pilot qualification currency as well as on a number of other ongoing prerequisites, including:
- Attendance at an annual standardization meeting,
- An annual quality-control evaluation.
Additionally, a pilot instructor may go a step further and train to become a pilot evaluator.
After completing training, a number of ongoing prerequisites may be required for the pilot evaluator to maintain currency, such as:
- Attendance at an annual rater-reliability training session (instructor-related conferences about how to rate),
- An annual evaluator quality-control evaluation,
- A biennial quality-control evaluation with the U.S. Federal Aviation Administration, or other requirements per the respective government authorities,
- Performance of a certain number of evaluations during a rolling period of months,
- Maintenance of pilot-instructor currency.
While these higher-level qualifications have their own dependencies, they are also based on the lesser qualifications. In this example, the pilot-evaluator qualification depends on the currency of the pilot-instructor qualification, which, in turn, depends on the line-pilot qualification currency.
Pilot Instructor Qualification
After a pilot completes his or her instructor-training course, instructor qualification is dependent on the currency of his or her line-pilot qualification as well as on a number of other ongoing prerequisites. The pilot instructor is then eligible to train to become a pilot evaluator.
Training Management System
The management and verification of even a single qualification is a complex task, and there are a number of opportunities for non-compliance to occur. However, various IT solutions facilitate the implementation and monitoring of these qualifications. A training management system, such as Sabre® AirCentre™ Crew Training Manager, provides:
- Full integration of qualifications, requirements and scheduling tools, preventing the assignment of instructors to events for which they are not qualified;
- Auto-management of record keeping for recurrent instructor training, enabling the accurate and effective maintenance of currency records, which, in turn, supports the automatic update of expiration dates for instructor qualifications;
- Support for the planning process through identification of recurrent training for instructors;
- Workflow with a critical notification component, meaning the flow for which courses should take place (workflow) and notifications for when non-compliance or breaks in this occur.
In addition, this level of automation provides many benefits for airlines, including:
- Consistent application of compliance rules,
- Common naming conventions and terminology,
- Transparent view into instructors’ qualifications and recurrent training requirements,
- A standard method for monitoring employees’ qualifications.
It is always a tense moment when the auditor requests proof of all qualifications and asks questions such as, “When was the instructor’s last quality-control check?” and “Did the instructor conduct at least four line-operations events last year?”
Carriers that maintain proper training management system records have this information readily available. Furthermore, that information is updated automatically when events are completed, and the records and related reports are also easily available with a couple of keystrokes.
Given the financial and operational risks associated with instructor training, as well as the complexities of managing and maintaining qualified instructors and crewmembers, airlines can benefit by leveraging powerful and reliable tool sets in their training departments.
The relatively inexpensive investment in the tools — especially when compared with the potential high cost of non-compliance — is well justified.