Devising a Training Plan for a Part 91 Flight Department, Part 2
Another way to keep training from becoming stagnant is to annually assess the training plan to not only assure compliance but also weed out items that are no longer relevant to the operator’s mission or the regulations. “Training can be made a lot more efficient this way,” says Dan Boedigheimer, founding partner at Advanced Aircrew Academy. He suggests constantly assessing what is necessary and what can be eliminated. “Don’t train out of inertia,” he cautions. Instead, consider “what should we be training for?”
A constant theme Boedigheimer hears is that people train too much. “What we recommend is to train smarter, that is, conduct training that is more aligned with risks that are prevalent today,” he says. This means annually reassessing the prevalent risks and then modifying the program to accommodate them. “You have to constantly refresh your training plan to keep it relevant,” Boedigheimer emphasizes. “Is it up to date; is it adapted to business aviation; and is it operator-specific--for example, ‘no night ops into dangerous mountain airports?’”
A Safety Management System (SMS) can also be a guide for developing a relevant training plan. “What aircraft do I operate?” Boedigheimer posits. “What is the experience level of my team, and what are the areas we operate to? Under an SMS, you can compose a safety risk profile that will drive your training needs assessment,” he says. He suggests reviewing that annually, too, to ensure the program’s effectiveness.
But Part 91 does not require an SMS.]. “An operations manual is not required under [Part] 91 either, but you are required to have a checklist: normal and emergency, single-engine performance data for multiengine aircraft, weight and balance data, and performance data. The ops manual is ‘what is,’ and SMS is ‘what will be,’ or the driver of change to improve your operation. The SMS is what forces you to audit your operation for continued safety. This is where lessons learned comes into force, not just SMS but NTSB accident reports, NASA studies and recommendations, and so forth,” says an anonymous chief pilot.
He adds, “When you are a Part 91 operator, you can’t change the checklist from what the OEM has determined. What enhances safety in the cockpit more than anything else, though, is SOPs. Both pilots need to be reading from the same page.” And the operator’s training plan needs to reflect and emphasize SOPs, too, as well as best practices.
Part 61.58 stipulates a 24-month check in the airplane or sim if it’s a turbojet or requires more than one flight crewmember to operate it. “But you can substitute a check in another airplane that requires two crew every 12 months,” the chief says. “I am typed in and fly a Gulfstream and a Hawker and will require a check every year in one or the other of them, and this can fulfill the 24-month requirement. But even if it’s not a requirement, good sense would dictate annual recurrent training at a factory-approved school. Not being current would fall into the same category: Do a sim check. This is why most training companies offer annual recurrent training contracts.”
And how realistic is it for a flight department fielding turbine-powered aircraft to conduct pilot initial and recurrent training entirely in-house? Motion-based simulator training offered by business aviation support companies like CAE and FlightSafety is expensive, and it keeps pilots away from their jobs for several days. While operators on a budget might elect to train at home, it is a controversial subject.
“Depending on your resources, you could conduct all your training in house,” Boedigheimer says. “Part 61.58 requires an authorized check pilot for pilot compliance, and you would have to contract that out if doing your own training. Or you could outsource the training syllabus or adopt one from a third-party source. This could be customized to accommodate the specific operation.” (See “How a Startup Flight Department Developed Its Training Regimen” sidebar.)
But, according to our anonymous chief pilot, “There are times when we absolutely need to have to go back to school, if for nothing else than to know what is going on in the world--it gives you a well-rounded education and the advantage of lessons learned in the field combined with training and knowledge of the airplane.” Just as with the issue of hiring a sufficient number of pilots to staff a small flight department to avoid burnout (see “Finding a Balance Between Work and Personal Life in Business Aviation,” BCA, April 2019), if you can afford to purchase the jet, you should be able to afford an annual simulator check at a training center for the pilots who will fly it, thus ensuring the safety of you and your passengers.
Then there is the issue of online video training, which became a necessity during the first year of the COVID-19 pandemic. “Depending on the subject,” Boedigheimer says, “what we saw when the pandemic hit was that many flight departments said, ‘Let’s accelerate the training schedule to get as much done as possible in the downtime we have available.’ But at that point, we didn’t know how long this thing would last. International procedures training was pretty much dropped, and now there is a backlog to get it done as the industry comes back on line internationally, and so, much of this is being done via computer.”
Pablo Penalva, a Bombardier Global 6000 captain with Prospect Hill Growth Partners, reports that “During the pandemic we did our MedAire [cabin emergency medical] training on line--they shipped us a dummy to practice CPR. It was a full-blown class all day, and we did the classroom block in our respective homes. It wasn’t ideal but it got the job done. Last year, I did the full ground school for my pilot recurrency at home on the computer to reduce the time at CAE in Dallas. Doing it virtually that way, though, you miss out on the live action and exchanges--one of the most valuable experiences you get in attending in-person class. We learn a lot from each other.”
In a large, structured corporate flight operation like a Fortune 500 company, training “is more cut and dried,” Penalva observes. “In our shop, it’s one airplane, three pilots, and a scheduler who also doubles as a flight attendant. If we had to plan for a new pilot, we would be looking for someone with experience in the Global Express. We train once a year at CAE in Dallas. We do FACTS [Frequency and Capacity Trends Statistics] training with Aircare International; that includes cabin safety and emergency procedures training, yearly for flight attendants and every two years for pilots.
“And we contract with MedAire for the cabin medical emergency training, CPR and defibrillator (AED) every two years for full crew,” he continued. “We do our international ops recurrent every two years; same for security training. Our pilots also have access to our online ops manual and SMS on video, and we review that every quarter. We also review everything if we have a bunch of international trips coming up relatively together.” Both MedAire and Aircare come to Prospect Hill’s hangar with a trailer, and their instruction is conducted there.
Don’t Get Upset, and Feel the Gs
“At one time we did unusual attitude and upset training at UAT in Kissimmee, Florida, in an Aero Vodochody L-39 Albatros jet trainer and a TF-51 Mustang, one of the best trainings I’ve ever had,” Penalva enthuses (and no wonder: How many of us get to log dual time in the trainer version of a World War II fighter?). “It is extremely valuable training. You’re pulling Gs and relating to the whole experience--not like in a simulator. It’s a huge factor to be able to feel the Gs.”
Our chief pilot commentator, who has developed his career in both the business and commercial aviation worlds, recommends that operators take advantage of every training opportunity they can. “As a professional,” he says, “you become responsible for your own recurrent training because there is not a department [as there would be at an airline or in the military] feeding you this information. OEM newsletters are a good source. Do your own risk analysis. For new flight departments, a flight risk analysis tool [FRAT] is recommended. You start with a score of 100 and then look down a list of objective indicators. Night ops is a -5; landing at night for the first time in 60 days is a -6; flying in certain parts of Africa is a -60, and so forth. FltPlan.com has a tool for this. You set your own risk thresholds that the company and insurer are comfortable with, and then you have an objective criterion for rating the flight as go or no-go. It might be as simple as ‘We are not going to fly into Aspen at night.’ Use the resources to make safety-based decisions. Use the tools to help you stay safe.”
Editor's Note: This is the second of a three-part series on training. Here's the first article.