How Good Intentions Can Lead to Negative Training

Author: Scott Macpherson

Every year, we read many clients’ manuals from many parts of the world, and we regularly observe that over-committing the operation far above prescribed requirements is a common way to earn a finding in an audit. During an audit, you will be held to what you have claimed you will do, and if you haven’t done it, the auditor will write this up. For Canadian private operators, this is going to be very important when Transport Canada starts to conduct Program Validation Inspections on private operators, expecting operators to tie written commitments to SMS risk management activities.

An example of well-intended over-commitment would be prescribing an entire initial Crew Resource Management syllabus in the text of a training section while committing to annual CRM training. Even the inspectors don’t think that annual, initial CRM is good training, and the operators (there have been several) don’t either; it is just an overly zealous mistake. Another example is high-frequency operators (e.g., 6 to 8 legs per day) prescribing a FRAT for every leg when most legs could be covered by the risk profile, which results in pilots skipping or pencil-whipping the FRAT, rendering it impotent.

In Canada, the private operations regulation (CAR 604), if unchanged, has non-type training requirements that are far more prescriptive and demanding than any other regulatory regime in the world, creating negative training. Don’t make it worse by adding to it in your manual unless you use flexible language, for example: “such as”, “may include”, “as required”, “from time to time”, etc unless a requirement is imposed. You can always do more than you have committed to, but heaven help you if you do less and have an audit.

On a related note, it is fairly common for training sections to prescribe minimum training times for non-type training and also to post summary matrices in training sections. There is nearly always a disconnect between the text and matrix references to topics and their frequencies. Though matrices make auditors’ lives easier, we often suggest at least removing all training time references for non-type training because there is no standard or guidance for the times, and they often vary wildly between operators without basis. It is usually best if the text section can be the exclusive reference, but a matrix with controlled links to each topic syllabus can be a very good tool for all. Just avoid having the same/conflicting information in two places.

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Scott Macpherson is the President and Founder of TrainingPort.net and Vice Chairman of the International Business Aviation Council (IBAC) Governing Board. He is currently Captain on a Falcon 900LX.