European Aviation Safety Agency Comment-Response Document 2014-17 Crew Resource Management (CRM) training CRD TO NPA 2014-17 — RMT.0411 (OPS.094) — 25.9.2015 Related Decisions 2015/022/R and 2015/023/R EXECUTIVE SUMMARY This Comment-Response Document (CRD) contains the comments received on NPA 2014-17 (published on 26.6.2014) and the responses, including a summary thereof, provided thereto by the European Aviation Safety Agency. Based on the comments and responses, Decisions 2015/022/R and 2015/023/R were developed. Applicability Process map Affected Decision 2014/025/R (Part-ARO); Concept Paper: No regulations Deicsion 2014/017/R (Part-ORO); Terms of Reference: 12.11.2012 and decisions: Decision 2012/019/R (Part-SPA); Rulemaking group: Yes Decision 2012/005/R (Part-CC) RIA type: Light Affected Air operators; training organisations; Technical consultation stakeholders: personnel/licence and certificate during NPA drafting: No holders; EASA Member States Publication date of the NPA: 26.6.2014 Duration of NPA consultation: 3.5 months Driver/origin: Safety; stakeholder request Review group: Yes Reference: Safety Recommendations: Focussed consultation: No SPAN-2011-026; SPAN-2011-027; Publication date of the Opinion: N/A FRAN-2012-042; FRAN-2012-043; Publication date of the Decision: 2015/Q3 FRAN-2012-044; FRAN-2012-021; FRAN-2013-019 TE.RPRO.00064-002 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/Internet. Page 1 of 173 An agency of the European Union European Aviation Safety Agency CRD to NPA 2014-17 Table of contents Table of contents 1. Procedural information .................................................................................................................................... 3 1.1. The rule development procedure............................................................................................................ 3 1.2. The structure of this CRD and related documents .................................................................................. 3 1.3. The next steps in the procedure .............................................................................................................. 3 2. Summary of comments and responses ............................................................................................................ 4 3. Individual comments and responses .............................................................................................................. 14 TE.RPRO.00064-002 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/Internet. Page 2 of 173 An agency of the European Union European Aviation Safety Agency CRD to NPA 2014-17 1. Procedural information 1. Procedural information 1.1. The rule development procedure The European Aviation Safety Agency (hereinafter referred to as the ‘Agency’) developed this CRD in line with Regulation (EC) No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is included in the Agency’s 4-year Rulemaking Programme under RMT.0411 (OPS.094). The scope and timescale of the task were defined in the related Terms of Reference (see process map on the title page). The draft Acceptable Means of Compliance (AMC) and Guidance Material (GM) have been developed by the Agency based on the input, among others, of the Rulemaking Group RMT.0411 (OPS.094). All interested parties were consulted through NPA 2014-173, which was published on 26 June 2014. 406 comments were received from interested parties including industry, national aviation authorities, training organisations and aviation associations. The text of this CRD has been developed by the Agency based on the input of the Review Group 2014-17. The process map on the title page contains the major milestones of this rulemaking activity. 1.2. The structure of this CRD and related documents This CRD provides a summary of the comments and responses as well as the full set of individual comments (and responses thereto) received to NPA 2014-17. 1.3. The next steps in the procedure This CRD is published together with the Decisions 2015/022/R and 2015/023/R containing the amended AMC/GM on CRM training. 1 Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1). 2 The Agency is bound to follow a structured rulemaking process as required by Article 52(1) of the Basic Regulation. Such process has been adopted by the Agency’s Management Board and is referred to as the ‘Rulemaking Procedure’. See Management Board Decision 01-2012 of 13 March 2012 concerning the procedure to be applied by the Agency for the issuing of Opinions, Certification Specifications and Guidance Material (Rulemaking Procedure). 3 http://www.easa.europa.eu/document-library/notices-of-proposed-amendment/npa-2014-17. TE.RPRO.00064-002 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/Internet. Page 3 of 173 An agency of the European Union European Aviation Safety Agency CRD to NPA 2014-17 2. Summary of comments and responses 2. Summary of comments and responses The following paragraphs provide a summary of the comments and contain the conclusions on the main topics that have been identified in the NPA public consultation process. Whenever reference is made in this chapter to a draft provision, it relates to the respective paragraph of Chapter 3 of NPA 2014-17. Computer-based training In the NPA, the Agency introduced draft provisions concerning computer-based training as follows: 1. Flight crew: a. for multi-pilot operations: computer-based training not as stand-alone but as complementary training4; b. for single-pilot operations: computer-based training as stand-alone training5. 2. Cabin crew: a. for multi cabin crew operations: same as for multi-pilot operations6; b. for single cabin crew operation: computer-based training as stand-alone training for aircraft with a maximum operational passenger seating configuration of 19 or less7. 3 commentators stated that computer-based training should not be permitted as stand-alone training method, even for single-pilot and single cabin crew operations8. In contrast, 7 commentators explained that limiting computer-based training as stand-alone method to single-pilot and single cabin crew operations is a reasonable approach9. Based on the comments received, the Agency decided not to change the original approach as described above. Minimum training times Based on the input received, the Agency proposed the introduction of minimum training times as AMC in the NPA as follows: 1. Flight crew: a. combined CRM training for multi-pilot operations: 8 hours over a period of 3 years, which may be reduced when evidenced by the operator’s management system10; b. initial operator’s CRM training for multi-pilot operations: 24 hours, of which 16 hours should be classroom training11; c. initial operator’s CRM training for single-pilot operations: 4 Paragraph (a)(3) of AMC1 ORO.FC.115. 5 Paragraph (b)(4) of AMC2 ORO.FC.115. 6 Paragraph (a)(3) of AMC1 ORO.CC.115(e). 7 Paragraph (c) of AMC2 ORO.CC.115(e). 8 Comments Nos 29, 32, 268, 275, 283 and 289 (some commentators provided more than one comment on the same subject). 9 Comments Nos 73, 95, 135, 164, 213, 351 and 408. 10 Paragraph (a)(6)(ii) of AMC1 ORO.FC.115. 11 Paragraph (b) of AMC1 ORO.FC.115. TE.RPRO.00064-002 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/Internet. Page 4 of 173 An agency of the European Union European Aviation Safety Agency CRD to NPA 2014-17 2. Summary of comments and responses — 8 hours for complex motor-powered aircraft12; — to be determined by the operator for other-than complex motor-powered aircraft13. 2. Cabin crew: a. combined CRM training for multi cabin crew operations: 8 hours over a period of 3 years, which may be reduced when evidenced by the operator’s management system14; b. operator’s CRM training for multi cabin crew operations: 8 hours15; c. operator’s CRM training for single cabin crew operations: 4 hours for aircraft with a maximum operational passenger seating configuration of 19 or less16. 3. CRM trainer: a. 40 hours which is reduced to 24 hours for: — flight crew trainees holding an instructor certificate17; — cabin crew trainees when the operator can justify that the trainee already has received sufficient and suitable instruction in training skills18; b. refresher training: 8 hours19. The topic of minimum training times triggered a large number of comments. These comments are summarised in Table 1. The main items can be highlighted as follows: — Proposal ‘no minimum training times for any training’ vs proposal ‘minimum training times for all trainings’: after further consideration and discussion within the Review Group, the Agency came to the conclusion that introducing minimum training times for certain trainings, as listed above, but not for others, is an acceptable compromise and should not