- CRM training should not be ‘check-relevant’, i.e. must not lead to a failure during a check ride, when a pilot’s license is at stake;
- CRM assessments should not be based on subjective terms, but must be linked to clearly understood terms like ‘technical failure’ to avoid subjective treatment;
- CRM methodology should be set up and maintained in close cooperation with the pilots and must therefore be agreed with flight crew representatives.
These three core provisions have proven to work very well over the past years, provide a clear framework, and helped to build and maintain trust in the system. To maintain the trust also in future, and to prevent that CRM gradually looses acceptance within the pilot community – and thereby its effectiveness as a safety-enhancement tool – maintaining these 3 ‘pillars’ is a prerequisite for a successful CRM training in future.
Removing the foundation of CRM training
Regretfully, EASA’s NPA-2014-17 proposes to remove these 3 pillars and thereby opens the door for the CRM concept to lose credibility, trust and support.While proposing to remove these pillars, EASA does not provide convincing reasons as to why their removal is required. Furthermore, while there are welcome improvements contained in the NPA elsewhere, these improvements do not compensate the removal of the very foundations upon which CRM has been built. Once CRM assessments become check-relevant, i.e. leading a pilot to fail a check ride and lose his/her pilot license, based on subjective terms and interpretations, and without a requirement for flight crew representatives to agree to the CRM training methodology, CRM will become open to (ab)use for other than safety-purposes. This would be a major step backwards in the concepts of safety culture and ‘Just Culture’. Both concepts still have some way to go to be fully applied and rooted in the aviation sector. With commercial pressure and competition growing in the sector, it becomes even more important to strengthen the regulatory safety barriers that prevent safety margins from being eroded. The 3 above mentioned provisions are part of this ‘safety barrier’ and must therefore remain solidly enshrined in Europe’s future CRM training rules. Commenting on NPA-2014-17 Europe’s pilots are convinced that CRM and the CRM-related training need to be strengthened to further enhance aviation safety in Europe. To do so, and to ensure CRM training benefits from the trust of those who are trained on CRM and who apply the concept in their daily operations – the pilots – the three pillars upon which CRM training has been built need to be maintained. On behalf of Europe’s pilots, ECA therefore calls upon stakeholders to:
- comment on EASA’s NPA-2014-17 (deadline: 10 Oct. 2014);
- reject the proposed removal of the 3 pillars; and to
- request the related current rules to remain unchanged.