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Pending Canadian Contemporary CRM Requirements for Commercial Ops

SRM, CRM | January 12, 2018

UPDATE (July 18, 2019): The information below is now outdated, please see our most recent blog post on CRM here.

UPDATE (May 25, 2018): has received two conflicting answers from Transport Canada as to when the training must be completed and operator approval received with regards to AC 700-042. We have requested a judgement from Transport Canada in Ottawa to gain clarity on this new Contemporary CRM. They have responded that January 31, 2019 is the compliance date, meaning that operators have to be in full compliance by that date.

We have been told that the training must be approved and completed by the ‘effective date.’ However we received two different interpretations of the actual ‘effective date.’ The two dates are:

  • January 31, 2019; or
  • 18 months from the publication of the official standard, which is stated verbatim in the AC itself. The official standard has yet to be published.

Though we are doubtful that this interpretation is correct, we are revising our CRM and SRM topics to be ahead of the game so that all clients will be in full compliance by the applicable date. We will post updates in our newsletter and blog to get the word out when we have a concrete answer.

BLOG DATED: January 12, 2018

Further to my article below, here is the answer from Transport Canada, not that it helps much…

“As the publication of new/revised Regulations and Standards goes through a lengthy consultation and approval process, I do not have an answer for you as to when the revised Standards for CRM training will come out.

702-3-4 Operators will be expected to have completed all required CRM training by the end of the 18 month period after the publication of the official Standard.”

So, no rush then… Nonetheless, we are revising our CRM and SRM topics to be ahead of the game.

We have started receiving questions from Canadian commercial operators about Transport Canada’s AC 700-042 regarding “Contemporary CRM” training requirements for CAR 702, 703, and 704 operators.

The AC is very large and has a great deal of detail, including some probable mistakes (see the matrix in section 7.3, its notes and think through the implications…), so in the next weeks we will finish the gap audit of our content (we just finished a CRM revision which used the draft of this AC as input), develop scenarios to allow all roles and case study requirements to be met, create job aids such as guided discussion sheets, and provide a clear gap statement regarding what may be done in the simulator.

AC 700-042 is dated 31 January 2019 and says (in the last sentence of section 5, on page 12 of 51) that operators will “have 18 months from the date of publication of the official Standard to implement CRM training” but it is unclear when the official standard will be published.  We are waiting for Transport Canada to respond to our request for information on just when that might be.  It is also unclear whether the implementation means that initial training can be started at that point or must be completed by that point, another clarification we are pursuing.

So, while we seek information about the publishing date of the official standard(s) we suggest a ‘wait and see’ approach because there is time built in.  One question has been regarding the trainer qualification requirement, but nothing has changed there.  The AC doesn’t actually say that TC has to approve the trainer, simply that the trainer must satisfy “the air operator that he/she has the knowledge and skills required to conduct the training” (CASS724.115(4)) and that a form must be filled out annually to provide to TC.

More to come…

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