ACP Bulletin 01/12

Subject

Flight crew concept and the notion of jeopardy for a seat substitute during a multi-crew Pilot Proficiency Check (PPC) or Line Operational Evaluation (LOE)

Purpose

To amend the policy affecting the status of a person who participates in a PPC or LOE as a seat substitute

Background

Longstanding policies have to this point supported the notion of one’s privileges being at risk anytime that person served as a seat substitute during a multi-crew PPC or LOE. The recent publication of updated guidance with respect to administrative procedures made it clear however that in order for the Minister to take an administrative action affecting a person’s privileges, that person needed to be an applicant intending to obtain or renew privileges in the first place.

An individual filling in as a seat substitute during a multi-crew PPC or LOE is not a PPC / LOE candidate, inasmuch as this individual has not completed the requirements of an approved training program and been issued a recommendation for the purposes of being evaluated during such an event.  This individual merely fills in and occupies an aircraft operating seat for the sole purpose of providing competent support to the candidate being evaluated during that PPC or LOE.

This person will not receive any credit for providing good support during a multi-crew checking event; likewise, this person’s privileges cannot be considered at risk of administrative action when failing to provide the appropriate level of support expected during that event.

Intended Staff Guidance

This policy change applies only in situations where a person acts as a seat substitute during a multi-crew PPC or LOE for the sole purpose of providing competent support to the candidate being evaluated during that event.

Applicable text in TP 6533 – ACP Manual, TP 14727 – PPC and Aircraft Type Rating Flight Test Guide (Aeroplane), TP 14728 – PPC and Aircraft Type Rating (Helicopter)and TP 14672 – AQP Evaluator Manual will be modified in due course to the effect that an individual filling in as a seat substitute during a multi-crew PPC or LOE will not be at risk of losing privileges associated with his or her PPC, LOE and / or instrument rating (IR) for a poor supporting performance, since that person cannot be considered a PPC or LOE candidate in the first place.

In accordance with the above, an Approved Check Pilot (ACP) or AQP Evaluator will not initiate an administrative action process and a Transport Canada Civil Aviation (TCCA) inspector will not take administrative action towards a person acting as a seat substitute, when that person fails to provide the appropriate level of support expected during a multi-crew PPC or LOE.

Because poor performance by any one flight crew member involved in a flight check may translate into a valid safety concern (whether they happen to be a candidate or not), an ACP, AQP Evaluator and / or TCCA inspector involved in such a situation therefore must act with diligence and ensure that the air operator or training center which assigned the seat substitute is being made aware of that person’s poor supporting performance during the event.  It is strongly suggested that this feedback to the air operator or training center be made in writing, either directly by the ACP, AQP Evaluator, or TCCA inspector or via TCCA, at the ACP or AQP Evaluator’s discretion.  It is then up to that organization to take that person’s inadequate performance into account and take action as deemed necessary.

Although unlikely in a flight crew concept where two or more individuals communicate and act towards a shared outcome, an ACP, AQP Evaluator, or TCCA inspector has discretion to call the flight check incomplete (as opposed to a flight check failure for the sole candidate) if the delegate deems the seat substitute to be the only individual who contributed to the unsatisfactory performance of a flight sequence.

Effective date

This instruction takes effect immediately.  The next editions of TP 6533 – ACP Manual, TP 14727 – PPC and Aircraft Type Rating Flight Test Guide (Aeroplane), TP 14728 – PPC and Aircraft Type Rating (Helicopter)and TP 14672 – AQP Evaluator Manual will reflect this change.

Contact Person

Tom Dunn
Program Manager, Approved Check Pilot / Advanced Qualification Programs (AARTF)
613-998-8168
tom.dunn@tc.gc.ca

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