‘Rules are for the obedience of fools and the guidance of wise men’

Group Captain Harry Melville Arbuthnot Day GC, DSO, OBE

The compliance-based system of training management is the support pillar for a pilot licensing system. It supports the issue of a license, and it supports the ongoing delivery of a satisfactory performance by the pilot in the workplace.

I believe that this system has had its day and is no longer fit for purpose. The advent of the flight simulator has made it possible to use a training and testing regime that in most circumstances can replicate the actual work environment or at least can create a more representative testing environment based on LOFT principles.

Let me observe at the outset that we are lucky enough to have some of the ablest and knowledgeable aviators in the various national and international aviation regulatory bodies. I in no way wish to impugn their expertise, but it is a reality that no one can know everything and our biggest headaches often emerge from things we did not realise we did not know.

More than 20 years ago one national authority mandated the fitting of autopilot systems for police helicopters engaging in night operations outside the confines of a well-lit city environment. They did not foresee the need for the necessary training on how to manage an autopilot system and as a consequence, a pilot on a night police mission mishandled the autopilot and crashed. Fortunately, all on board survived. The authority was well motivated in their intent but did not have the expertise to realise the scale of the ‘Pandora’s box’ they were opening for they were not experts in autopilot training.

The problem with a compliance-based system is that it puts the regulators at the top of the ‘tree’ and makes them the de-facto experts on how to produce a competent pilot and then how to maintain that competency.  The regulators are, by design, the experts and centre of excellence when it comes to ‘regulating’. In my opinion, the training schools are, by design, the experts and the centres of excellence for pilot training. If you are doing it every day, day in day out then it gives you an insight into the nature of pilot training that does not necessarily come to light in any audit. We, those that do it day in day out, need to be involved in that somewhere along the line.

The problem is that because everything cascades down from the regulations the schools are focusing their efforts of ‘compliance’ with the regulations instead of paying attention to the quality of the finished product.

I believe this is a conspiracy of the willing for by leaning on the compliance system the schools can use a ‘tick-box system to measure the standard of the finished product which is a relatively simple process. The competence-based system relies heavily on the quality of the assessments made by the instructor, and this requires an instructor with more skills than the normal TRI/SFI training provides.

Why is a move to Competence (or Evidence) Based Training (CBT or EBT) a headache for the regulator? It’s a headache because the instructors need more training (cost and time) and the outcome of any given training course may be less clear-cut.

With a tick-box system a manoeuvre or procedure is delivered and provided an adequate representation of the manoeuvre or procedure is witnessed the box is ticked and the instructor moves on to the next item. There is no analysis of the trainee or candidate’s overall appreciation of the situation he has just been dealing with.

If an analogy is required to help understand this problem then think about it like this. You explain a concept in English to your trainee, and you ask him ‘do you understand’. He replied yes. What he in fact means is that he recognises each of the words you have used and understood their meaning. That’s not really what you are interested in though. You want to know if he ‘comprehends’ the explanation you have given, which is a different thing entirely. In reality, the only way you can ascertain for sure that he has full comprehension of the subject is to ask him to explain it back to you.  You may well use this technique in the briefing and debriefing, but we need to be designing lessons that also ask the questions but of course in another way. That is the beauty of LOFT scenarios for they can be designed to combine situations that allow the instructor to assess the degree to which these things have been properly understood as well as providing a window into the thought processes at work in the minds of the crew.

The ‘compliance’ system uses people who understand compliance to ‘police’ the school systems, so it is not necessary for them to understand pedagogy (the science of teaching) in any shape or form. They just need to be able to verify that the system ‘complies’. The compliance system is. However, also responsible for the quality of the training system and this is a problem.

The Quality Assurance and Quality Control processes are critical parts of the system so any department that is responsible for teaching in any shape of form should be staffed by professionals with appropriate teaching experience. You wouldn’t ask an engineer to audit a pilot and vice versa, at least I hope you wouldn’t.  I know people that do and once upon a time I was asked to do that very thing.  That is the worst kind of audit though, for it depends on a checklist to function and a ‘tick-box’ process that is not supported by expertise.