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Interim Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: IR19980176
Date issued: 06 November 1998
Safety action status:
Background:

SUBJECT - CO-PILOT INSTRUMENT RATING


INTRODUCTION - REGIONAL AIRLINES SAFETY STUDY

Between October 1995 and July 1997, the Bureau of Air Safety Investigation undertook a study of the safety of Australian regional airlines. The objectives of this study were to:

(a) identify safety deficiencies affecting regional airline operations in Australia; and
(b) identify means of reducing the impact on safety of these deficiencies.

For the purpose of the survey, regional airlines were grouped according to the number of passenger seats fitted to the largest aircraft operated by that airline in January 1997. The groups are defined as follows:

(a) Group 1: 1-9 seats;
(b) Group 2: 10-19 seats; and
(c) Group 3: more than 20 seats.

The study involved analysing data obtained from:

(a) responses to a survey of Australian regional airline employees;
(b) discussions with Australian regional airline employees and managers;
(c) air safety occurrence reports involving regional airlines over a 10-year period (1986-1995) from the BASI database.

This recommendation addresses one of the safety deficiencies identified as a result of this study.


SAFETY DEFICIENCY

Training requirements for the initial issue of co-pilot instrument ratings are inadequate and currency requirements for co-pilot instrument ratings are not clearly defined.


FACTUAL INFORMATION

Survey results

Sixty-seven pilots (17%) reported that they held a co-pilot instrument rating, rather than a command instrument rating, on multi-engine aircraft. Seventy-four per cent of the pilots holding a co-pilot instrument rating only were flying Group 3 aircraft while 26% flew Group 2 aircraft. Aircraft from both Group 2 and Group 3 were, in general, high-performance, complex aircraft.


Regulations

Pilots may obtain and exercise the privileges of a co-pilot instrument rating. Candidates for co-pilot instrument ratings need only satisfy the aeronautical experience requirements of the pilot licence held. A co-pilot employed by a regional airline operator would, as a minimum, require only the aeronautical experience of a commercial pilot licence. Co-pilot candidates would then be required to pass the Civil Aviation Safety Authority (CASA) instrument rating exam in addition to an instrument rating flight test. The instrument rating flight test must cover the same test components as that of a command instrument rating test except that the requirement to demonstrate proficiency in asymmetric flight is limited to performance in the cruise phase of flight.

Note: It is also possible for a pilot who holds a command grade of instrument rating for single-engine aircraft only, to act as a co-pilot while the aircraft is flying in instrument flight conditions.

Civil Aviation Order (CAO) 40.2.1 contains detailed recent experience requirements that must be complied with in order to exercise the privileges of an instrument rating. However, references are only made to the pilot in command. Discussions with CASA personnel indicated that while co-pilot recency requirements were not specifically mentioned in CAO 40.2.1, the intention was that co-pilot requirements are equivalent to pilot in command requirements and are therefore implied within the CAO. Notwithstanding, CASA staff agreed that this aspect of CAO 40.2.1 was ambiguous.

Current Australian regulations allow for co-pilot endorsements on multi-engine aircraft that require multi-crew operations. The syllabus of training for co-pilot aircraft endorsements, as outlined in appendix V of CAO 40.1.0, does not require an element of instrument flying. Civil Aviation Advisory Publication (CAAP) 5.23-1 (0), issued in September 1996, provides supplemental guidance to the CAOs on the conduct of training for the initial issue of a multi-engine endorsement (rating). The CAAP includes a 1-hour flight training exercise on instrument flying (where the candidate holds an instrument rating) as part of the 8-hour flight training section of the syllabus. As this information provides advice only as to the preferred method for complying with Civil Aviation Regulations, instrument flight training is therefore not a mandatory element for the issue of a co-pilot endorsement.


Current multi-crew practices

Historically, co-pilots did not participate in flight deck duties in the same way as the pilot in command. Co-pilots were employed principally in a support or ancillary role with the majority of flying duties, particularly critical phases of flight such as takeoff, landing and instrument approaches, being undertaken by the pilot in command. The current practice has changed considerably and co-pilots are now expected to fly "leg-for-leg" during any one period of flying duty. Whilst the pilot in command has ultimate responsibility for the safety of the flight, the co-pilot participates fully as the "flying pilot" in all phases of flight including takeoff, landing and instrument approaches. Partly in recognition of these increased responsibilities, many operators now require applicants for co-pilot positions to hold a command instrument rating and be eligible, pending accumulation of relevant aeronautical experience, for an airline transport pilot licence. Many co-pilots are now also expected to demonstrate proficiency in all the elements of instrument flight including asymmetric operations during critical phases of flight.


Proposed changes to co-pilot training requirements

Discussions with CASA personnel revealed that some consideration is being given to the removal of co-pilot endorsements, and therefore co-pilot instrument ratings, from current domestic regulations. The Bureau was advised that one of the reasons for this proposed change was so that domestic practice reflected overseas practice. Co-pilot endorsements and co-pilot instrument ratings are not available in many other countries.



ANALYSIS

Although there is no evidence to suggest that incidents or accidents have resulted from this situation, the current limited training requirements and the lack of definition of currency requirements for co-pilot instrument ratings, have the potential to impact on safety.

The current aeronautical experience requirements for co-pilots may mean that some co-pilots would have limited background experience to draw upon, particularly in asymmetric operations, and would therefore be exposed to a greater risk of making skill- and knowledge based-errors. As co-pilots are not expected to demonstrate proficiency in asymmetric flight during an instrument rating test in anything other than the cruise, and are not required to undertake specific instrument flying exercises during co-pilot aircraft endorsements, it is possible that deficiencies in co-pilots' instrument flying skills during critical flight phases such as takeoff, landing and instrument approaches, may remain undetected. These potential deficiencies in experience and proficiency may not be subsequently addressed in those cases where an operator or individual has interpreted the CAOs such that they do not consider that co-pilots need to meet the recency requirements of the instrument rating. With little initial training and limited ongoing practice, co-pilots' instrument rating skill levels are not likely to be consolidated. Additionally, it is possible that some co-pilots' experience in instrument flight conditions, including instrument approaches, is likely to be gained only on fare-paying, passenger-carrying flights and when the co-pilot is not legally "current" in accordance with the intention of CAO 40.2.1.

Given the current practice in both Australian and international airlines regarding the participation of co-pilots in "leg-for-leg" flying, it would seem more appropriate from a safety perspective for co-pilots to be required to undertake the same instrument rating training as that specified for a pilot in command.

Output text

The Bureau of Air Safety Investigation recommends that the Civil Aviation Safety Authority give consideration to the removal or amendment of the current co-pilot instrument rating requirements. Notwithstanding, whilst the current regulations are in force, the ambiguity in relation to recency requirements for co-pilot instrument ratings should be addressed.

Initial response
Date issued: 26 February 1999
Response from: Civil Aviation Safety Authority
Action status: Closed - Accepted
Response text:

I am writing in response to your letter addressed to [name supplied] in which you requested advice on the Authority's proposed action with respect to Air Safety Interim recommendation IR980176. Please accept my apologies for this belated reply.

While it is noted that there is no direct evidence of safety deficiencies resulting from the training specified in Civil Aviation Orders for the holders of a co-pilot's Instrument Rating, the Authority acknowledges the changed role of co-pilots in the years since these regulations were first conceived.

In view of these changed circumstances, a review of the applicability of the co-pilot Instrument Rating in the current environment will be undertaken as part of the total review of the flight crew licensing structure. This review will be the pre-cursor to detailed work on the new Part 61 of Civil Aviation Safety Regulations. The same review will also look at the applicability of the co-pilot aircraft endorsement.

The licensing review has a high priority but, as you will appreciate, it is a large undertaking involving many other complex issues. Because no direct safety deficiency has been identified, the review of the co-pilot requirement will proceed in the context of the overall review. It is intended that a decision on the licensing structure, including the need for specific co-pilot qualifications will be made in the coming year.

With regard to the stated ambiguity of current recency requirements, CASA does not agree that any ambiguity exists. CAO 40.2.1 clearly states that recency requirements only apply to the pilot in command. The Authority's flight crew licensing section is not aware that any other requirement was ever intended. Overseas practice does not require recency for co-pilots in instrument procedures as part of the licensing requirements, even where these pilots are required to hold the equivalent of a commend instrument rating.

It would be difficult to justify a unique licensing requirement for formalised recency for co-pilots because an instrument approach procedure flown by a co-pilot will always be monitored by a pilot in command who is recent. Also, under the regulations which apply to operators, co-pilots are required to undertake flight proficiency and rating renewal tests at regular intervals which, combined with the common practice of leg for leg flying by co-pilots, ought to be adequate to maintain proficiency. Again, I note that no specific safety deficiency has been identified in this regard.

It may be that co-pilots' proficiency in asymmetric flight is a matter which requires consideration and this will be taken into account in the review of the co-pilot qualification.

 

 
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Last update 01 April 2011