A question has been raised about how pilot training, including its sub-components like CRM and Upset Recovery Training, relates to a Safety Management Systems (SMS). Is pilot training a risk mitigation component of SMS?
[Editor’s Note: IAFTP supports the efforts of the NBAA Safety Committee’s Business Aviation Pilot Training Project. This question was raised during a recent project team meeting.]
This Question of the Month was previously posted on two international aviation blogs during September 2012 — Neil Krey’s CRM Developers Forum and the LinkedIn Aviation Safety Management Systems Group. For the complete context of responses, please refer to each of these blogs.
Here are some key points that were made (included here with the authors’ permission):
[CRM Devel blogger #1 -- UK]
“Training itself looks like a one-directional intervention. But that has all the effectiveness of pointing a shotgun into the air and hoping that something will land on a grouse. So training has to be systematic, adaptive and evolutionary as you say. Without going into detail, this is really what the FAA was after with the original AQP programme (but it got lost in a blizzard of paper).
TMS by whatever name is really unavoidable – how can you have SMS-compliant training if you can’t report whether the training is working, whether anyone learned anything, and if not, why not? Typically, an area which is difficult to assess is ignored in an operator’s SMS. This is what Edward Demming was always thundering on about – the need to measure things which matter, not just measure things which are easy to measure. For example, the ICAO documents make it clear that HF is an essential component of an SMS, but when I recently looked at UK CAA’s SMS guidance there was only one mention of HF – in a footnote.
Bottom line – TMS, yes in principle, in practice probably something of a running battle depending on the enlightenment of management.”
[CRM Devel blogger #2 – Hong Kong]
“Strictly speaking [training management system] refers to a software solution associated with running or managing a training system. It is often a commercially available product. Its purpose is to manage the DELIVERY of training.
ISD/SAT is a model of training DESIGN that has been around for a long time. We now have SMS.
I have argued for a few years now that SMS should drive CRM training. Rather than attempt to roll out modules each year that comply with the requirements in regulations an airline should review it’s SMS and develop a flexible model of CRM training design that responds to changes in operational experience.
However, in relation to other forms of training, it could be argued that the SMS is part of your training evaluation strategy (a component of ISD/SAT). AQP and ATQP are only regulatory frameworks based on ISD/SAT, by the way.”
[CRM Devel blogger #3 -- Spain]
“We currently rarely do audits on training to verify compliance and find risks. If we consider training is a defense of the system at the end, this defense should be monitored from SMS. We also have training feedback as part of a management system. The last level evaluation of training can be FDM. Regarding ISD and TNA, safety training and any input or ingredient on safety culture development (e.g. good operating habits, attitudes development, values seeding, etc.) should be embedded in normal training scenarios and curricula, not as separated ‘safety training’.”
[LinkedIn blogger #1 -- Canada]
“Training is a critical component of any safety system. Beyond the obvious requirement to comply with regulations regarding training, your training program is one of the primary means by which you show your people how to do their assigned tasks. It should also be designed to make them aware of the risks associated with those tasks and how to best mitigate them.
Sending someone for additional training after an unsafe event is a little like closing the barn door after the horses have already run away. The training program should have ensured that the door was never left opened and unattended in the first place. In other words, don’t just fix the people, fix the training.
Training programs must receive the same QA and QC attention as your other critical processes. Testing trainees at the end of a training session is not enough to ensure that training is effective. You must also assess how your training program is affecting the way work gets done on the front line (is it achieving the intended results?). If you bring in a new procedure, you must monitor the new procedure to ensure that the training was effective so that it is being followed and being effective in completing the task. Other QA elements should include monitoring the delivery of your training. Are your trainers delivering the material correctly? Are they receptive to the needs of the trainees? Surveying trainees regarding the effectiveness of the training program and the instruction received will help you understand if your training message is being delivered.
When an unsafe event occurs, the investigation must consider if the training was adequate for the task(s) involved in the incident. It is not enough to remediate the people who were directly involved. When one person has an unsafe event, you must assume that anyone else who does the same job could have the same event under the same conditions and training must make everyone aware of the issues involved.
So yes, pilot training is a key risk mitigation component. If your training program is just ticking regulatory boxes, you may be missing more than one golden opportunity to prevent accidents.”
[LinkedIn blogger #2 -- Peru]
“Pilot Training is not only a risk mitigation tool, it is one of SMS’ primary defenses, and developing adequate pilot training programs should be as important as any of other SMS components implementation. Remember that pilots are the last line of defense against threats, errors and latent conditions; and adequate training gives them the required tools to manage unsafe conditions.”
WHAT DO YOU THINK? Is the following a valid positioning statement?
A Safety Management System (SMS) is the formal, top-down business approach to managing safety risk, which includes a systemic approach to managing safety, including the necessary organizational structures, accountabilities, policies and procedures. The Training Management System (TMS) provides a systematic approach to managing the training component of an SMS.
From the pilot’s perspective, the TMS is an education system designed to develop necessary aviation skills including aircraft handling, airmanship, flight deck resource management, risk management, and decision making. It is delivered in a structured learning environment and includes a continuous improvement process aligned with that of the SMS.