Policy Letter 153

Subject

Practical Training - Emergency Procedures Training for Pilots

File Number

RDIMS # 99813

Date

2005.12.19

Policy Statement

This Policy Letter is intended to clarify the requirement for, and the intent of practical training during emergency procedures training for pilots.

Applicability

This policy applies to air operators operating under Subparts 703, 704, and 705 of the Canadian Aviation Regulations (CARs).

Background

It has been determined that there are differing interpretations of the term "practical training". The variations in the interpretation of the term "practical training" are not limited to air operators but also exist within Transport Canada.

Transport Canada is taking action to clarify the meaning of, and requirements for, "practical training".

Regulatory Requirements

Subsections 703.98(2), 704.115(2), and 705.124(2) of the CARs require an air operator's training program to include emergency procedures training to meet the criteria of Subsections 723.98(11), 724.115(12) and 725.124(14) of the Commercial Air Services Standard (CASS).

Where practical training is required it shall be completed on initial training and every three years thereafter.

Practical training is required for the following areas:

  1. use of fire extinguishers;
     
  2. operation of emergency exits;
     
  3. donning and inflation of life preservers;
     
  4. passenger preparation for an emergency (landing);
     
  5. evacuation procedures;
     
  6. life rafts/slide rafts;
     
  7. pilot incapacitation.

In addition, pilots are to receive training on the location and operation of emergency equipment onboard the aircraft. Except where noted, equipment used during practical training must be identical respecting the features and operation of equipment installed on the air operator's aircraft.

Discussion

The Oxford Dictionary (Ninth Edition) defines "practical" as of or concerned with practice or use rather than theory.

In aviation, practical training is commonly referred to as "hands on" training. Practical training ensures the effectiveness of the application of theory when combined with the skill set required to perform a task, especially when performance must be assessed. Although instructional videos, lectures or reading assignments may provide the basic theory, they do not satisfy the requirement of practical training.

The correlation between the effect of practical training and performance is evident in many facets of daily routine and is not limited to aviation. However, in aviation it is critical in areas such as piloting skills. A pilot learns to fly by receiving training composed of theoretical and practical elements, with emphasis on practical training to obtain mastery of the skills necessary to operate an aircraft - manipulating the controls and flying the aircraft. A pilot would have great difficulty successfully operating an aircraft for the first time after receiving all of the theory but none of the practical training.

Obviously this scenario is not acceptable in aviation nor would it be acceptable in any industry, trade, or activity where safety may be at risk due to inadequate training received by an individual.

Policy

In evaluating an air operator's emergency procedures training program, the following should be considered respecting elements requiring practical training:

  1. Use of fire extinguishers:  The program should require each pilot to remove the extinguisher from its bracket/stored position and simulate operating the fire extinguisher (pull, aim, squeeze and sweep). It does not require the pilots to fight a live fire nor does it require that a fire extinguisher be discharged. If the extinguisher is accessible from the pilot's seat, then the training should be conducted with the pilot strapped into his/her seat.
     
  2. Operation of emergency exits:
     
    1. For operations under Subpart 705 of the CARs:

      The pilot must be able to operate the main entrance door installed on the aircraft. It is not necessary for the pilot to evacuate through the exit during this training. It is not intended that pilots open each exit on every aircraft where:
       
      1. exit operation in emergency mode for each exit on an aircraft is identical; or
         
      2. exit operation on one aircraft type is identical in operation to exits on another aircraft type.
         
    1. For operations under Subparts 704 and 703 of the CARs:

      If the pilot has assigned duties during an evacuation and is or could be required to operate or direct a passenger to operate an exit, he/she must be able to operate each type of exit installed on the aircraft. It is not necessary for the pilot to evacuate through the exits during this training. It is not intended that pilots open each exit on every aircraft where:
       
      1. exit operation in emergency mode for each exit on an aircraft is identical; or
         
      2. exit operation in emergency mode will cause automatic ramp/slide deployment and inflation (exits equipped with slides shall include slide or slide drag simulation), potentially causing damage to the aircraft; or by design can be used only once and then require maintenance action. In such cases, an approved video depicting the emergency operation can be used as an alternative; or
         
      3. exit operation on one aircraft type is identical in operation to exits on another aircraft type.
  1. Donning and inflation of life preservers:  Each pilot removes the life preserver, dons it correctly, tightens straps, locates the manual and oral inflation tabs/tubes, and simulates inflation and deflation techniques.
     
  2. Passenger preparation for an emergency (landing):  each pilot practices the air operator's approved procedures for preparing passengers during an emergency. This portion of the training can be incorporated with procedures described in the air operator's approved Airplane Flight Training Program.
     
  3. Emergency evacuation procedures:  if the pilot has assigned duties during an evacuation, he/she must participate as a crewmember in an evacuation of the aircraft. For air operators operating under Subpart 703 and 704 of the CARs, as the pilot(s) is/are ultimately responsible for evacuating the passengers, he/she/they must participate in an evacuation of the aircraft as per the operator's procedures.
     
  4. Removal from stowage, deployment, inflation and boarding of life rafts/slides: pilots shall demonstrate their ability to:
     
    • access the raft compartment and experience the difficulty associated with moving the weight of a packaged life raft within a space representative of the aircraft aisle;
       
    • examine all features of a fully inflated raft;
       
    • board raft(s); assist persons into raft; access the inflation lanyard;
       
    • access the raft release mechanism while verbally describing the procedure to release the raft from the aircraft; and
       
    • examine the raft survival kit and review the operation of all components.

      Rafts may be substituted provided there are no substantive differences with respect to weight, dimensions, appearance, features, and operation and training for the differences has been provided.

      Pilots shall also be instructed in techniques for righting an overturned raft, erecting the raft canopy, and raft management. This may be accomplished through theoretical instruction and/or practical training.

  1. Pilot incapacitation - as applicable to flight crew complement of two or more:  Each pilot participates in a drill with one pilot incapacitated. The training should include directions the pilot should give to a passenger/flight attendant to secure the incapacitated pilot in his/her seat and any communication/coordination procedures to assist the remaining flight crewmember.

Civil Aviation Inspectors involved in the approval and monitoring of air operator training program should verify that the emergency procedures training meets the intent of the applicable CASS, particularly where practical training is required.

Future Disposition

This Policy Letter shall remain in effect until an appropriate amendment is made to the Part VII advisory material.

Reference Number

This Policy Letter is designated AARX No. 153.

Michel Gaudreau
Director
Commercial & Business Aviation

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