Transport Canada and HAC Still Struggling over CRM Training Requirements
You will recall that the CRM AC 700-042 implementation deadline was extended to September 30 2019.
HAC’s members raised a number of issues with the terms of the AC, and how CRM training could possibly apply to some helicopter operations. A conference call of operators was held earlier this year, and the most significant concerns raised seem to centre on the definition of “Crew Member”, which triggers the requirement for training, according to the terms of the AC “a person assigned to duty in an aircraft during flight time”. When is a person “assigned to duty”? If they are an observer in the aircraft (during a wildlife survey for example), is that an assigned duty? If they are tech in the back of the aircraft during an airborne survey, is that an assigned duty? Clearly “passengers” are not assigned duties during flight. Is a camera operator, operating doors-off during filming operations, a “crew member”? If a passenger is instructed by the pilot how to pass equipment from the cabin to others on the ground while the aircraft is in a hover, are they a “crew member”? Most of our members understand the importance of ensuring that there is clear and effective communication between the pilot and these “crew members” during these in-flight operations. Some would argue that the act of observing, or operating equipment in the back of the aircraft are not “assigned duties”. Assuming that crew members are receiving technical instruction on their duties, what is the role of CRM? HAC’s recent discussions with Transport Canada on this subject have also tried to clarify which specific elements of a CRM course are really at the heart of this issue, and do they require full-blown CRM training? To what extend should an operator be compelled to reach out to its customers to provide training to these “crew members” given their limited duties in-flight? For example, there are certain elements of CRM which are not generally emphasised during the technical training process, that could bring safety value to an operation – for example (in no particular order):
- The importance of speaking out (and how to do, that), as a crew member, when the safety of the operation may be jeopardized;
- Situational awareness;
- The importance of effective communication between pilots and other crew members – that constantly change from flight-to-flight;
HAC is discussing the potential for developing a generic CRM course, that could be delivered by customers to their employees flying with us as “crew members”, that would address the essential generic elements of CRM for our customers. Stay tuned for more.