The following abbreviations are used during this response:
LHS - Left Hand Seat
RHS- Right Hand Seat
PF - Pilot Flying
PNF - Pilot Not Flying
PM - Pilot Monitoring
The reporter indicates two separate areas of concern. Firstly, the reporter indicates a belief that an experienced and current captain would be unable to safely land the aircraft from the RHS given a LHS incapacitation. Secondly, the reporter suggests that an experienced captain would not be able to apply the company assertion framework which may culminate in physically taking control of the aircraft in an emergency.
While we accept that the reporter's concerns are genuine, the potential outcomes related to the PM/PNF LHS operations policy are unequivocally refuted. Furthermore, we have previously considered these potential issues during a risk review of these operations and believe that the evidence supports the policy. The argument used to support this contention follows below.
The current operator policy on RHS operations states: For initial RHS PM/PNF operations a minimum of 2 sectors as PM in the RHS with a training or check captain occupying the LHS must be completed. Subsequently line captains and Level 2 training captains may only continue to operate as PM/PNF in the RHS if: the LHS is occupied by a check captain or training captain or; they have completed a sector as PM/PNF within the previous 90 days.
Notwithstanding the above, a Line Captain or Level 2 Training Captain must have completed 2 sectors in the RHS as PM/PNF with a Training or Check Captain in the preceding 12 months. When operating in the right-hand seat, the checks required for operating in the left-hand seat must, in addition, be valid and current. Note: Low Visibility Take-Off (LVTO) operations and CAT II/III operations from the RHS as PM are not permitted.
While, the Australian regulatory suite does not differentiate or require specific competency checks, recency requirements or articulate training required for a particular seat of operation, we undertook a review of operations in consultation with the applicable CASA Certificate Management Team in mid to late 2012.
Skills and competencies for RHS operations
Integral to this review was a comprehensive risk analysis. The risk assessment considered that, in the event of LHS incapacitation, the underpinning competencies and procedures required to operate and land an aircraft from the right hand seat (i.e. the seating position, effects of controls, landing technique, checklists used) are essentially the same as when operating from the LHS. Additionally aircraft and company procedures, state the use of autopilot to reduce workload in the event of incapacitation in either seat, this would include during approach and landing as applicable.
In this regard, given a similar degree of exposure to the probability of LHS incapacitation while operating as a normal crew, the risk assessment found that conducting these operations with a qualified captain operating in the LHS posed a similar or reduced risk to those operations with a normal crew complement facing a similar LHS incapacitation event. A normal crew may include a junior or recently qualified first officer with limited experience. It was determined that, as the handling differences between operating in LHS or RHS were minor in these jet aircraft, a captain operating in the RHS would certainly not be in a worse position to make the appropriate command decisions associated with managing an incapacitated pilot.
It is important to note that a captain rostered to operate as PM/PNF in the RHS must still retain landing recency and must have completed a landing in that type of aircraft within the previous 35 days.
The risk assessment also addressed flight deck gradient and command issues. This is one reason why it supported operations as PM/PNF only from the RHS. Retaining the requirement for the LHS captain to operate as PF and retain command clearly underscores the support nature and role when operating as PM/PNF in the RHS. Restricting PF operations to the LHS supports the natural command gradient while still allowing the experienced PM/PNF in the RHS to speak up and question the operating captain. It was felt that allowing the captain in the RHS to operate as PF would dilute the required command gradient and also lead to situations where the actual commander, operating as PM/PNF in the LHS, may be less likely to question or correct the actions of the other captain.
The risk assessment did identify that as captains in the RHS may be less familiar with PM duties from the RHS they may be more prone to unintentional errors of a procedural nature. This situation coupled with the greater time of exposure during normal line operations supported the establishment of both initial assessment and ongoing recency requirements when operating as PM from the RHS.
While there is a high degree of commonality in the ergonomics of the flight deck layout, it does differ slightly from left to right hand seat. Hence, the policy requires 90 day recency in Pilot Monitoring operations to ensure greater familiarity with both the minor procedural variations and visual cues when operating from that seat.
Assertion Statement Framework
The company Assertion Statement Framework is designed as a tool to maintain crew situational awareness during flight. The logic is also applied to the situation where a Captain would be required to escalate to the emergency take-over statement.
Some comments have already been made about the readiness or likelihood of an experienced captain being empowered to speak up and intervene when operating in support as PM/PNF from the RHS. The whole intent of the assertion framework is to address situations well before a take-over is needed. In this regard, we contend that the arrangements in place for PM/PNF operations in the RHS support the application of the framework. While captains rostered to operate in the RHS normally fulfil a PM/PNF role, it certainly does not forbid them from exercising their right to take physical control when the safety of flight is threatened. We believe that it is disingenuous to suggest that merely being rostered for PM/PNF duties evaporates all established airmanship and command skills.