Commercial Air Transport Operators of ‘Complex Motor-Powered Aeroplanes’ are required to provide initial and recurrent training in aeroplane upset prevention and recovery to their pilots.
Why were these requirements introduced?
A number of aircraft accidents could have been prevented if the pilots had avoided entering an ‘aircraft upset’, or had recovered from the upset once it occurred. In particular the accidents to Air France 447 on 1 June 2009 and Air Asia 8501 on 28 December 2014 both resulted in the loss of all passengers and crew on board. In both these events the aircraft would have been controllable if the pilots’ actions had been different.
Responsible aircraft operators will have already reviewed these accidents and ensured that their training programmes address the associated risks; nevertheless the European regulator (EASA) decided to introduce requirements to ensure that all operators have suitable training programmes. This is in line with international standards.
Which operators are affected by the UPRT requirements?
The UPRT requirements apply to commercial air transport operators of complex motor powered aeroplanes. There are no changes to licensing requirements so training organisations are not affected (yet). Operators who have an approved ‘alternative training and qualification programme’ (ATQP) will need to ensure that their programmes achieve at least an equivalent level of proficiency to following the new requirements..
What do operators have to do in order to comply?
Operators need to ensure that elements of upset prevention training are included in their initial and recurrent flight crew training programmes. They also have to ensure that recurrent training programmes include all the required upset recovery exercises over a three-year period. Both upset prevention and upset recovery training should include both theoretical (‘ground-school’ and practical (simulator) training.
Prevention training helps pilots to avoid getting into an ‘aeroplane upset’ and recovery training teaches them to recover from an upset that has already happened. The new requirements include a list of training elements for each type of training (41 elements for prevention and 5 for recovery). The content of the training programmes should be based on an operator’s specific risks as identified through the management system (SMS).
Instructors will need specific training and standardisation before delivering UPRT. This requirement is not yet addressed in the TRI/SFI course. The focus of this training will be to ensure that the instructors teach the correct techniques and understand the limitations of using a simulator for this type of training.
Is this mandatory?
The UPRT requirements are published as ‘acceptable means of compliance’ (AMC). This means it is possible to propose an ‘alternative means of compliance’ (AltMoC) if some aspect of the AMC does not suit your operation (for example if you don’t provide training in a simulator). You would need to demonstrate that the intent of the rule is met and that your proposed AltMoC would achieve an equivalent level of safety to the new AMC.
How do I make sure our training is compliant?
The first step will be to study and understand the requirements. EASA has provided references to several useful other documents. After this a ‘gap analysis’ should be conducted to compare your previous training programmes with the new requirements. If you identify any gaps then you should amend your training programme to meet the UPRTrequirements. The revised programme (operations manual part D) will then need to be approved by the competent authority. You will probably need to run special training sessions for simulator instructors. The content of these sessions should also be detailed in the part D.
Is there an easier way?
We also offer a one-day training programme for instructors in order to prepare them to deliver UPRT. This programme covers all the theoretical training elements required by GM5 ORO.FC.220 & 230; in particular it provides an overview of the qualification and approval requirements of different types of flight simulation training devices (FSTDs) and help instructors to understand the capabilities and limitations of flight simulators for UPRT. We can deliver this training ‘in-house’ for your team if required. The theoretical training can be complemented by practical (simulator) training sessions based on your aircraft type and your operating procedures.
If the new requirements pose a difficulty for your operation then we can help you find a solution or prepare an alternative means of compliance (AltMoC) for approval. Please get in touch for more information.