Staff Instruction (SI) No. 700-002
Flight Crew Checking and Monitoring
|Issuing Office:||Standards||Document No.:||SI 700-002|
|File No.:||Z 5000-32||Issue No.:||02|
|RDIMS No.:||14186118 V19||Effective Date:||2019-01-02|
Table of Contents
- 1.0 Introduction
- 2.0 References and Requirements
- 3.0 Background
- 4.0 CASI Qualifications
- 5.0 ACP / AQPE Application Process
- 6.0 ACP / AQPE Monitor Checks
- 6.1 Authority to Conduct Monitor Checks
- 6.2 Authority to Check in an Aircraft and Simulator
- 6.3 Revision Monitor Check
- 6.4 Requalification Monitor Check
- 6.5 Monitor Check Validity Periods
- 6.6 Preparation for a Monitor Check
- 6.7 Monitor Checks Conducted by an ACP (Type M) or AQPE (Type M)
- 6.8 Releasing ACP / AQPE Records to Type M Delegates
- 6.9 Document Completion for Initial or Revision Monitor Checks
- 6.10 Administration of Monitor Report Forms
- 7.0 Administering a Delegation of Authority
- 8.0 Quality Assurance / Oversight
- 9.0 Database Updates
- 10.0 Information Management
- 11.0 Document History
- 12.0 Contact Office
(1) The purpose of this document is to provide guidance to Transport Canada Civil Aviation (TCCA) personnel who are involved in the conduct or approval of flight checks, evaluations, or monitor checks associated with the Approved Check Pilot (ACP) and Advanced Qualification Program Evaluator (AQPE) programs.
(1) This document is applicable to all TCCA personnel who are involved in the conduct or approval of flight checks, evaluations, or monitor checks associated with the ACP and AQPE programs.
1.3 Description of Changes
(1) A wide variety of changes have been incorporated in this Issue, including the incorporation of policies previously contained in Internal Process Bulletin (IPB) 2016-05, Inspector Requirements for Flight Crew Checking Activities and Policy Letter (PL) 166, Quality Assurance for the ACP Program. Readers should therefore review this document in entirety.
(2) Guidance on the conduct of a monitor check has been removed from this Staff Instruction (SI) and inserted in Advisory Circular (AC) 700-051 Monitor Checks on Approved Check Pilots and Advanced Qualification Program Evaluators. Other changes in this Issue are primarily related to the addition of guidance in the following areas:
- (a) Civil Aviation Safety Inspector (CASI) qualification requirements to conduct flight and monitor checks;
- (b) Processing ACP / AQPE ministerial delegations;
- (c) ACP / AQPE knowledge assessments and monitor checks;
- (d) Administering a Delegation of Authority;
- (e) Quality assurance; and
- (f) Database management.
2.0 References and Requirements
2.1 Reference Documents
(1) The following reference materials must be used in conjunction with this document:
- (a) Aeronautics Act (R.S., 1985, c. A-2);
- (b) Advisory Circular 700 – 051 - Monitor Checks on Approved Check Pilots and Advanced Qualification Program Evaluators;
- (c) Staff Instruction (SI) QUA-008 – Risk Management Process for Aviation Safety Activities;
- (d) SI SUR-014 – Suspension or Cancellation of Canadian Aviation Documents for Safety Reasons;
- (e) Civil Aviation Directive (CAD) ADM 005 (Appendix A) – Required Training for Civil Aviation Employees who Develop, Deliver and/or Support Oversight Activities;
- (f) Risk Assessments conducted to support the delegation of Monitor Checks – Record Document Information Management System (RDIMS) No. 12738094, 13376626, and 13582258;
- (g) Part VII, Subpart 02 of the Canadian Aviation Regulations (CARs) — Aerial Work;
- (h) Standard 723 of the Commercial Air Service Standards (CASS) — Air Taxi - Aeroplanes;
- (i) Standard 723 of the CASS — Air Taxi – Helicopters;
- (j) Standard 724 of the CASS — Commuter Operations – Aeroplanes;
- (k) Standard 724 of the CASS — Commuter Operations – Helicopters;
- (l) Standard 725 of the CASS — Airline Operations – Aeroplanes;
- (m) Transport Canada Publication, TP 6533E — Approved Check Pilot Manual;
- (n) Transport Canada Publication, TP 14727 — Pilot Proficiency Check and Aircraft Type Rating Flight Test Guide - Aeroplanes;
- (o) Transport Canada Publication, TP 14728 — Pilot Proficiency Check and Aircraft Type Rating Flight Test Guide - Helicopter; and
- (p) Transport Canada RDIMS No. 4179408 — Risk Indicator Table – Approved Check Pilots.
2.2 Cancelled Documents
(1) As of the effective date of this SI, the following documents are cancelled:
- (a) Internal Process Bulletin (IPB) 2016-05 Issue 03, dated 2018-01-23 – Inspector Requirements for Flight Crew Checking Activities; and
- (b) Policy Letter (PL) 166, dated 2004-07-08 – Quality Assurance (QA) for the Approved Check Pilot (ACP) Program.
(2) By default, it is understood that the publication of a new issue of a document automatically renders any earlier issues of the same document null and void.
2.3 Definitions and Abbreviations
(1) The following definitions are used in this document:
- (a) Approved Check Pilot (ACP) – In this SI, means a person applying for or holding an official authorization to conduct any or all of the following activities on behalf of the Minister of Transport pursuant to Part 1, Section 4.3(1) of the Aeronautics Act: Pilot Proficiency Checks (PPCs), Line or Qualification Checks, and Monitor Checks;
- (b) Advanced Qualification Program Evaluator (AQPE) - In this SI, means a person applying for or holding an official authorization to conduct evaluations and/or validations on behalf of the Minister of Transport pursuant to Part 1, Section 4.3(1) of the Aeronautics Act, within a given air operator’s approved Advanced Qualification Program (AQP);
- (c) Certificate Action – The suspension or cancellation of a Canadian Aviation Document (CAD) under the authority of section 7 or section 7.1 of the Aeronautics Act;
- (d) Conduct - To take an active role in all phases of a flight check, including pre-flight preparation and briefing, the control and pace of the various sequences, assessment of the candidate’s performance, and the debriefing and completion of the required documents;
- (e) Flight Check – In this SI, the following activities are considered ‘flight checks’: Pilot Proficiency Check (PPC), Line Check, AQP Manoeuvres Validation (MV), AQP Line Operational Evaluation (LOE), and AQP On-line Evaluation (OE);
- (f) Flight Crew Member – In this SI, means a person occupying a pilot seat for the purposes of acting as a safety pilot and / or conducting a flight check or monitor check;
- (g) In-flight Surveillance: Airborne surveillance activities that are conducted to assess the in-flight procedures of a commercial operator as part of an Assessment or Program Validation Inspection (PVI); or conducted on its own as a Process Inspection (PI); or on a routine basis such as in-flight inspections;
- (h) Issuing Authority — A Civil Aviation Manager or Associate Director that holds the appropriate delegation to issue an ACP and / or an AQPE delegation, or issue notices of refusal to issue, suspension, refusal to renew or cancellation of an ACP / AQPE delegation;
- (i) Letter of Accreditation – An official authorization to exercise a Ministerial Delegation;
- (j) Monitor Check – In this SI, refers to the conduct of an initial, recurrent or requalification ACP or AQPE monitor check;
- (k) Professional Suitability – In this SI, refers to a delegate that possesses the knowledge, competency, judgement, integrity and communication skills to represent the Minister in a favorable manner and who has demonstrated the willingness to work cooperatively with TCCA to promote aviation safety;
- (l) Requalification Monitor Check – An assessment that is conducted by a CASI on an ACP or AQPE when the validity period of their last monitor check has expired. Treated as a recurrent monitor check for administration purposes; and
- (m) Valid PPC – In this SI, means that a PPC was successfully completed and included the completion of all associated mandatory technical and non-technical ground school subjects.
(2) The following abbreviations are used in this document:
- (a) ACP: Approved Check Pilot;
- (b) AQPE: Advanced Qualification Program Evaluator;
- (c) CASI: Civil Aviation Safety Inspector;
- (d) CARs: Canadian Aviation Regulations;
- (e) CASS: Commercial Air Service Standard;
- (f) CFS: Commercial Flight Standards;
- (g) DAPLS: Distributed Air Personnel Licensing;
- (h) DIS: Delegation Information System;
- (i) FTAE: Flight Training Aviation Education;
- (j) FTR: Flight Test Report;
- (k) NACIS: National Aviation Company Information System;
- (l) PI: Process Inspection;
- (m) POI: Principal Operations Inspector;
- (n) PPC: Pilot Proficiency Check;
- (o) PVI: Program Validation Inspection;
- (p) RDIMS: Record Document Information Management System;
- (q) SI: Staff Instruction;
- (r) TATC: Transportation Appeal Tribunal of Canada; and
- (s) TCCA: Transport Canada Civil Aviation.
(1) The expanded scope of this Issue addresses a broad range of subject areas that includes CASI qualifications for the conduct of checking and monitoring activities, as well as the oversight, administration and quality assurance of the ACP and AQPE programs.
(2) From an accountability, risk and credibility perspective it is important that CASI qualifications and competencies closely mirror those of the ACPs and AQPEs who conduct the same activities. Areas that warranted change have been addressed in this SI through the enhancement of qualification and recent experience requirements for CASIs.
(3) There was also a need to revise this SI to address TCCA’s recent decision to provide carefully selected industry ACPs / AQPEs with “Type M” authorization to conduct ACP and AQPE monitor checks in accordance with the conditions defined in AC 700-051.
(4) CASIs must refer to this SI and AC 700-051 for guidance on the conduct of monitor checks.
4.0 CASI Qualifications
(1) This section defines qualification requirements with respect to aircraft type ratings, Pilot Proficiency Checks (PPCs) and recent experience for CASIs assigned to conduct flight checks or monitor checks for which aircraft knowledge and experience is essential.
(2) The policy direction herein is intended to assist managers, typically at the Associate Director Operations (ADO) or Chief level, with their responsibility of ensuring that tasks requiring aircraft knowledge and experience are assigned to a properly qualified and competent CASI.
4.2 Transition Period
(1) There may be cases where CASIs require additional training (or recent experience) in order to comply with the revised qualification requirements in this SI. To accommodate this training and minimize operational impacts, TCCA regions and National Operations will have twelve-months from the effective date of this SI to meet the revised requirements. In the interim, the current CASI qualification requirements stated in IPB 2016-05 remain in effect.
4.3 Sharing Resources
(1) If a region does not have a qualified CASI available for a flight or monitor check, regional managers are expected to seek assistance from another region, when practical. This type of mutual support should also be considered if a region has a ‘one-off’ aircraft type that could be better supported by another region, as opposed to unnecessarily qualifying CASIs in both regions.
(2) Although the duplication of CASI flight qualifications across regions is often necessary, unnecessary duplication must be avoided.
4.4 One-time Authorizations
(1) Flexibility may be required in exceptional circumstances when there is a need to assign a task to a CASI that does not have the required qualifications, and support from another region is not possible or practical. In such cases, ADOs or Chiefs may consider issuing a one-time authorization to a CASI on a case-by-case basis to conduct a specific activity. Examples of one-time events includes the following:
- (a) A request to have a PPC conducted in a specific Official Language; or
- (b) A new aircraft type is being introduced or re-introduced into Canadian operations and CASI resources are required to conduct flight checks.
(2) In the case of one-time authorizations, the following process should be used:
- (a) The authorization is documented in RDIMS;
- (b) The authorization states the time period and/or series of events; and
- (c) The authorization contains statement(s) that address safety and CASI credibility.
4.5 Acting as a Flight Crew Member
(1) CASIs conducting checking, monitoring or in-flight surveillance activities will not act as a flight crew member unless they meet the qualification, minimum experience, and recent experience criteria defined in this SI. CASIs should obtain the required flight qualifications through their Professional Aviation Currency Program (PACP) to the maximum extent possible.
(2) CASI checking and monitoring authorities (“authorized types”) must be clearly defined and documented using a format similar to a Letter of Accreditation for an ACP / AQPE. This record should be signed by the applicable regional authority and entered as an RDIMS document in FTAE in accordance with section 9.2 of this SI.
4.6 Conducting Flight Checks and Evaluations
(1) A CASI must meet the following qualification, minimum experience, and recent experience requirements in order to conduct a flight check or evaluation in an aircraft or simulator:
- (a) Valid ACP or AQPE course as applicable. (Industry or TCCA course);
- (b) Must have been monitored at least once while conducting a flight check or evaluation as a CASI, ACP or AQPE;
- (c) Type rating (blanket or individual) on the aircraft;
- (d) Valid PPC to the PIC standard on one of the CASI’s authorized types. (To the extent practical, the type selected for the PPC should alternate each year between the CASI’s assigned types / expected flight and monitor check duties);
- (e) Appropriate and valid certifications if evaluating special authorizations, capabilities, or qualifications, such as RNP and/or RNP AR, RVR 1200/600/300 Cat II/III operations, offshore instrument approaches, heads up display, and enhanced vision systems;
- (f) Knowledge of company operations manual(s), standard operating procedures, special authorization(s), Aircraft Flight Manuals (AFMs), Minimum Equipment Lists (MELs), Safety Management System (SMS) and any other pertinent operational publications that are applicable to the check; and
- (g) Meet the recent experience requirements defined in section 4.1 of the ACP Manual under the title “Pilot Proficiency Check(s) – Aeroplanes” and “Pilot Proficiency Check(s) – Helicopters”.
(2) If the check is conducted in an aircraft and the CASI is acting as a flight crew member, the following additional requirements apply:
- (a) Must have a PPC to the PIC standard on the aircraft type if it is certified as an aircraft that requires two pilots; and
- (b) Must meet the currency requirements (take-offs and landings) stated in CARs for the subpart applicable to the check.
4.7 Conducting Monitor Checks
(1) A CASI must meet one of the following minimum experience requirements in order to conduct a monitor check in an aircraft or simulator without supervision:
- (a) Must have conducted a minimum of 10 flight checks or evaluations as a CASI, ACP or AQPE and must have been monitored at least once while conducting a flight check or evaluation; or
- (b) Must have observed the conduct of a monitor check on an ACP or AQPE and must have conducted one initial and one recurrent monitor check under the supervision of a CASI who performs a standards role in the region.
(2) A CASI must also meet the following qualification and recent experience requirements in order to conduct a monitor check in an aircraft or simulator:
- (a) Valid PPC to the PIC standard on one of the CASI’s authorized types;
- (b) Knowledge of special authorizations, capabilities, or qualifications, such as RNP and/or RNP AR, RVR 1200/600/300 Cat II/III operations, offshore instrument approaches, heads up display, and enhanced vision systems, as applicable to the flight check;
- (c) Knowledge of company operations manual(s), standard operating procedures, special authorization(s), Aircraft Flight Manuals (AFMs), Minimum Equipment Lists (MELs), Safety Management System (SMS) and any other pertinent operational publications that are applicable to the check; and
- (d) Valid TCCA Monitor Check Course / Workshop.
(Note – this is a new qualification and CASIs have two years from the date of this SI to complete the course. During this two-year period, the absence of this qualification will not prevent a CASI from conducting a monitor check. The course is offered nationally by HQ. Regions can also deliver their own course using the national course as the core curriculum. Note that delegates pursuing Type M authority must attend the national monitor check course delivered by HQ or an assigned person).
(3) Additional requirements applicable to initial monitor checks:
- (a) Type rating (blanket or individual) on the aircraft.
(4) Additional requirements applicable to recurrent monitor checks:
- (a) Type rating on the aircraft (in terms of blanket or individual type rating) or a type rating on a similar aircraft type in accordance with the list in AC 700-051 (appendix D).
(5) If the monitor check is conducted in an aircraft and the CASI is acting as a flight crew member, the following additional requirements apply:
- (a) Must have a valid PPC to the PIC standard on the aircraft type if it is certified as an aircraft that requires two pilots; and
- (b) Must meet the currency requirements (take-offs and landings) stated in CARs for the subpart applicable to the flight check.
4.8 In-flight Surveillance
(1) A CASI must meet the following qualification and recent experience requirements in order to conduct in-flight surveillance activities:
- (a) Valid ACP or AQPE course, as applicable. (Industry or TCCA course);
- (b) Must hold the appropriate aircraft type rating (in terms of blanket or individual type rating) for the aircraft type involved or an aircraft type rating on a similar aircraft type in accordance with the list AC 700-051 (appendix D); and
- (c) For in-flight surveillance activities that also require aircraft-specific knowledge, a CASI with the applicable type rating should be assigned whenever possible.
5.0 ACP / AQPE Application Process
5.1 Processing ACP / AQPE Applications
(1) The three types of requests applicable to ACP / AQPE delegations are: Initial, Revision, and Renewal. The ACP and AQPE application forms are available in the TCCA Forms Catalogue and include a selection to request Type M authority.
(2) Candidates must submit their application to the region where they will be conducting the majority of flight checks. The region that processes the application will be responsible for the continued management of the delegate’s file unless there is a logical reason to transfer the file to another region.
5.2 Application Review
(1) The eligibility requirements for accreditation as an ACP or AQPE are defined in the ACP and AQPE Manuals and AC 700-051. An Issuing Authority has the discretion to approve an applicant that does not meet the stated requirement(s), but meets the intent of the requirement(s). For example, an applicant could have an acceptable evaluation of proficiency other than a PPC, or a license issued by a foreign authority that is deemed equivalent.
(2) Requests for an ACP delegation for the sole purpose of supporting operations or training outside of Canada that does not involve a Canadian AOC will normally be denied unless it can be clearly demonstrated that it is in TCCA’s best interest to authorize the delegation.
(3) Although an applicant may meet eligibility requirements, the initial issuance or renewal of an accreditation must be based on operational needs and professional suitability. A Ministerial Delegation is not an ‘entitlement’ and must be assigned judiciously to preserve quality and minimize unnecessary administration and oversight costs.
(4) Regional diligence and regular oversight are important to ensure that all ACPs / AQPEs are fulfilling the requirement to conduct the minimum number of annual flight checks and evaluations, as defined in the ACP / AQPE Manuals and AC 700-051. The stated minimum requirements provide a trigger to review situations where the requirement is not being met. In such cases, the Issuing Authority must determine if there is a reasonable argument or operational requirement that supports the continued issuance of the delegation. If there is no reasonable justification, refer to section 7.3 of this SI for guidance on the removal of authority.
5.3 Knowledge Assessment
(1) The purpose and scope of the knowledge assessment is defined in the ACP / AQPE Manuals. This assessment can be combined with the monitor check or conducted separately. An interview format is used for the assessment and the candidate is allowed full access to reference material during the interview.
(2) The ACP / AQPE Manuals contain a broad list of references that apply to the knowledge assessment. Candidates should be provided with additional guidance on specific areas to study when the knowledge assessment is scheduled.
5.4 Assessment Questions
(1) The following protocols are mandatory to ensure that ACP knowledge assessments are conducted in a fair and standardized manner across all regions:
- (a) The assessment must contain a minimum of 25 questions. Questions must be selected from a national databank (RDIMS 14396594E, 14462772F) and/or regional databank and should be based on the scope and privileges of the candidate’s requested delegation; and
- (b) The candidate must obtain a minimum pass mark of 80% (corrected to 100%).
(2) Recommended changes or additions to the national databank of questions should be submitted to the ACP Program Coordinator in CFS.
(3) The responsibility for ensuring that AQPE knowledge assessments are conducted in a fair and standardized manner rests with National Operations.
5.5 Unsuccessful Assessment
(1) Unsuccessful assessments are to be managed in accordance with the direction contained in the ACP / AQPE Manuals. A candidate that receives two unsuccessful assessments must redo the ACP / AQPE course prior to being eligible for reconsideration as an ACP / AQPE.
6.0 ACP / AQPE Monitor Checks
6.1 Authority to Conduct Monitor Checks
(1) TCCA is the only entity that is authorized to conduct the following types of monitor checks:
- (a) Initial monitor;
- (b) Requalification monitor for a delegate that has an expired monitor;
- (c) Revision monitor, which is a discretionary monitor conducted for the purposes of adding an authority such as a type rating to a letter of accreditation;
- (d) Monitor on an ACP / AQPE that has Type M authority. Applies to monitors conducted to assess a Type M delegate while they are exercising a Type A, Type E or Type M authority; and
- (e) Monitors conducted on other CASIs.
(2) ACPs / AQPEs with Type M authority are only eligible to conduct recurrent monitors in accordance with the conditions defined in AC 700-051.
6.2 Authority to Check in an Aircraft and Simulator
(1) An ACP that requests authority to conduct flight checks in both an aircraft and simulator requires one initial monitor check (either in the aircraft or simulator). The platform selected for the monitor check is at the discretion of TCCA. If the monitor check is conducted in a simulator, the ACP must be briefed on the considerations applicable to conducting a flight check in an aircraft (and vice versa if the monitor check was conducted in an aircraft). Subsequent monitor checks should alternate between the aircraft and simulator at the discretion of the Issuing Authority.
6.3 Revision Monitor Check
(1) A revision to an ACP’s or APQE’s delegation can normally be completed without the need to conduct an additional monitor check. The requirement to conduct a revision monitor to add a type rating is at the discretion of the Issuing Authority based on considerations such as the delegate’s knowledge and recent experience on type, or similar types. Revision monitors must be conducted by a CASI.
(2) A revision monitor will renew the monitor check validity period in accordance with the normal monitoring interval, unless the Issuing Authority determines that a reduced validity period is more appropriate based on the circumstances.
(3) When a delegate’s authorities are revised, the delegate must be in possession of the revised letter of accreditation before exercising the revised privileges. The delegate can continue to exercise any existing privileges prior to receiving the revised accreditation.
6.4 Requalification Monitor Check
(1) A requalification monitor check is required when the validity period of an ACP’s / AQPE’s last monitor check has expired. This check is treated as a recurrent monitor for administration purposes and must be conducted by a CASI. All forms or documents that require a delegate’s signature must be signed by the CASI. (The delegate undergoing requalification does not have signing authority).
6.5 Monitor Check Validity Periods
(1) Policies pertaining to the validity period, renewal and extension of all monitor checks is contained in the ACP / AQPE Manuals.
(2) Regardless of published monitor check interval periods, Issuing Authorities retain the right to adjust a monitor interval period or conduct a monitor check on a delegate at any time, for any reason, as a planned or ‘no-notice’ check.
6.6 Preparation for a Monitor Check
(1) CASIs shall conduct monitor checks in accordance with this SI and AC 700-051. The following actions must be completed in preparation for all monitor checks (except initials):
- (a) Request a history of enforcement check;
- (b) Review FTAE, DAPLS, NACIS and RDIMS (as applicable) to confirm that the ACP / AQPE has the required qualifications and authority to conduct the flight check or evaluation;
- (c) Ensure the volume of flight checks conducted by the ACP / AQPE supports the operational requirement to retain a ministerial delegation;
- (d) Generate the following FTAE reports on the ACP / AQPE:
- (i) Grades assigned by the ACP / AQPE on Flight Test Reports (FTR) or evaluations since the previous monitor;
- (ii) The ACP’s / AQPE’s comments on FTRs for grades of 1 or 2. (Stored in FTAE as “Exercise Comments”); and
- (iii) Regional and national statistics for flight test grades since the previous monitor.
- (e) Complete the Risk Indicator Table – Approved Check Pilots (RDIMS 4179408). Insert numerical values for each known risk indicator and the spreadsheet will calculate a percentage of risk. Unknown risks should be left at zero and the spreadsheet will calculate an average of the remaining indicators. The amount of risk is arbitrarily set at 33% and 66%, which means:
- (i) A risk value up to 33% is acceptable;
- (ii) A risk value from 34% to 66% turns the box yellow to suggest that enhanced oversight and/or remedial training may be required. Due to the variables involved and the outcome of the monitor, the plan of action will be determined by the Issuing Authority; and
- (iii) A risk value of 67% or more turns the box red to indicate that enhanced oversight and/or remedial training is required. The plan of action will be determined by the Issuing Authority.
- (f) Be prepared to discuss changes to the ACP or AQPE program that may have occurred since the delegate’s previous monitor - (summarize Bulletins, applicable ACs, etc.); and
- (g) Advise the ACP or AQPE prior to the monitor that they may be required to produce their delegate records for verification during the monitor (including the ability to show compliance with recent experience requirements).
6.7 Monitor Checks Conducted by an ACP (Type M) or AQPE (Type M)
(1) AC 700-051 defines the process that must be followed to inform and seek TCCA approval of monitor checks that are scheduled to be conducted by a delegate with Type M authority.
(2) The Issuing Authority will review the list of planned monitor checks and approve or deny each check based on a risk analysis. Monitor checks on an ACP or AQPE must be conducted by TCCA when the following performance concerns are present:
- (a) The ACP’s / AQPE’s last monitor check was unsuccessful or graded with two or more (2s); or
- (b) The ACP’s / AQPE’s pass rates or grading tendencies are well above or below the national averages for the previous two years, with no apparent justification or rationale.
(3) Monitor checks should be conducted by TCCA when the following risk concern is present:
- (a) The ACP / AQPE is assessed as having a risk value above 66% using the Risk Indicator Table – Approved Check Pilots (RDIMS 4179408).
6.8 Releasing ACP / AQPE Records to Type M Delegates
(1) Regional Issuing Authorities will provide the ACP / AQPE (Type M) with the information identified in steps 6.6 (1) (b) and (d) on the candidate(s) they are monitoring. This information is required to brief the candidate(s) on grading tendencies and the accuracy and quality of comments on FTRs and evaluations.
(2) The mechanism and timelines for exchanging this information between the region and the ACP / AQPE (Type M) will be as agreed upon by both parties.
6.9 Document Completion for Initial or Revision Monitor Checks
(1) Given that industry delegates undergoing an initial or revision monitor check do not have signing authority, the CASI will:
- (a) Insert the CASI’s name as the person conducting the flight check or evaluation on all applicable forms;
- (b) Sign the applicable PPC FTR or Evaluation Form and annotate “Initial or Revision Monitor for (name of ACP or AQPE) and Licence Number” in the remarks section;
- (c) Sign the Application for Endorsement of a Rating, if applicable;
- (d) Sign the candidate(s) licence, if required;
- (e) Ensure payment of any applicable test or rating fees has been made (or otherwise arranged);
- (f) Complete the Monitor Report Form in accordance with the guidance provided in AC 700-051 (Appendix A); and
- (g) Retain all applicable forms for processing.
6.10 Administration of Monitor Report Forms
(1) The Monitor Report Form (26-0844) is completed and submitted electronically through an on-line portal, as described in AC 700-051. Submitted monitor reports are routed to the region responsible for the oversight of the delegate that was monitored. The reports are routed to the respective regional email addresses published at: https://www.tc.gc.ca/eng/civilaviation/opssvs/regions-139.htm
(2) Each region must have a protocol in place to ensure that all received monitor reports are promptly re-directed to an appropriate CASI to facilitate the review and acceptance or refusal of the report (as described in AC 700-051).
(3) The review and acceptance or refusal of monitor reports is carried out in FTAE in accordance with the instructions provided in RDIMS 14684499. Accepted monitor reports are automatically stored in the FTAE database.
7.0 Administering a Delegation of Authority
7.1 Issuing or Extending a Delegation
(1) The valid-to date for an initial issue, revision or renewal of an ACP / AQPE Delegation of Authority shall coincide with the valid-to date of the most recent ACP / AQPE course on record. Extensions to a delegation are addressed in the ACP and AQPE Manuals.
(2) Providing an ACP with Type A authority authorizes the ACP to conduct IFR and VFR PPCs, except for delegates under the purview of National Operations, who are restricted to IFR PPCs. An ACP provided with “Type A – VFR only” authority is only authorized to conduct VFR PPCs.
(3) When issuing an ACP or AQPE with a delegation of authority (initial, revision, or renewal), the following additional actions must be completed:
- (a) Update NACIS (see section 9.1); and
- (b) Update the Delegation Information System (DIS) database as applicable. Ensure information that the delegate wishes to keep private is not entered in DIS.
7.2 Authorized Person Privileges
(1) The letter of accreditation must specify the scope of the ACP’s / AQPE’s Authorized Person privileges. Authorized privileges should be compatible with the ACP’s / AQPE’s experience, span of knowledge and scope of duties. Providing a “blanket authority” often leads to situations where an ACP / AQPE authorizes a privilege without understanding the associated regulatory requirements.
7.3 Removing Authority
(1) A Ministerial Delegation of Authority has the status of a Canadian Aviation Document (CAD). Suspending, canceling or refusing to renew the privileges associated with a CAD must be done in accordance with the criteria and procedures defined in SUR-014.
(2) When the services of an ACP or AQPE are no longer required, refer to SUR-014 for guidance on the revocation of the applicable authority.
(3) The list below provides examples of situations where an Issuing Authority should refer to SUR-014 for guidance on taking certificate action against an ACP or AQPE’s delegation of authority:
- (a) A record of conviction of an offence punishable on summary conviction under 7.3 of the Aeronautics Act or the Canadian Aviation Regulations (CARs);
- (b) Evidence of malpractice or fraudulent use of the designation;
- (c) A record of violation of the CARs;
- (d) An incident or accident in which the ACP or AQPE is implicated;
- (e) The ACP or AQPE no longer complies with the conditions of the Delegation of Authority;
- (f) Failure to attend a required ACP or AQPE Course;
- (g) Failure to maintain an Instrument Rating, where required;
- (h) The need for repeated direction in the proper conduct and administration of flight checks or evaluations;
- (i) Unacceptable performance in any area of the ACP’s or AQPE’s duties or responsibilities, including the inability to accept or carry out the Issuing Authority’s or POI’s instructions;
- (j) Failure to conduct flight checks or evaluations in accordance with the instructions, techniques and procedures set forth in the ACP / AQPE Manuals and applicable Flight Test Guide; or
- (k) For any reason that the Issuing Authority considers appropriate and in the public interest.
(4) Requests for clarification or additional guidance on taking certificate action against an ACP or AQPE should be directed to Aviation Enforcement (NCR), who is the TCCA OPI for certificate action.
8.0 Quality Assurance / Oversight
(1) The quality assurance of flight and monitor checks begins with the careful and rigorous approval of industry pilots for an ACP / AQPE delegation. Equally important is the need to ensure that ACP course providers are delivering an optimum curriculum, and that there is effective and regular oversight of persons conducting checks and monitors. There is considerable inter-dependency between these elements and weakness in any area will impair efforts to achieve the highest level of overall quality assurance.
8.2 Oversight of ACP Course Providers
(1) Oversight of ACP course providers will be conducted and/or coordinated nationally by the ACP / AQPE Program Coordinator. Regions may be asked to assist with this oversight activity and will be provided with HQ guidance when asked to do so. CASIs that monitor an ACP or AQPE course can take credit for completing the ACP or AQPE recurrent course qualification requirements.
(2) Oversight will consist of the following activities:
- (a) Course curriculum and delivery will be monitored on a two-year interval by a CASI that is attending a course as a student or observer - (alternating between an initial and recurrent course on a two-year interval);
- (b) Curriculum will be closely monitored to ensure that the content is suitable to meet the unique training needs of each type of ACP that attends the course (i.e. helicopter, fixed-wing and VFR-only ACPs); and
- (c) Course providers must participate in at least one workshop annually (coordinated by HQ).
(3) In cases where oversight activities generate findings that are significant enough to warrant corrective action, refer to section 8.8 for further guidance.
8.3 Oversight of ACPs / AQPEs (excluding Type M authority)
(1) Monitor checks on ACPs and AQPEs are effective in promoting standardization and ensuring that the policies and procedures contained in the ACP / AQPE Manuals and Flight Test Guides are being applied correctly.
(2) However, monitor checks are less effective in ensuring that ACPs and AQPEs are consistently conducting flight checks and evaluations in an impartial manner. A historical comparison of ‘monitored’ versus ‘un-monitored’ flight test results indicates that delegates often adjust their behavioral and marking tendencies when monitored - scores on test items trend lower and failure rates trend higher. It is also common to see above average pilots assigned to a monitored flight check. This often results in an uneventful, low-value check that presents no grading challenges or debriefing discussions.
(3) The challenges noted above can be countered by regularly reviewing the FTRs that have been completed by delegates to identify areas of concern. This action is referred to as “administrative monitoring” in section 4.22 of the ACP Manual and is described in more detail below.
8.4 Administrative Monitoring
(1) As a minimum, the records of each ACP and AQPE must be reviewed annually to identify areas of concern, such as:
- (a) Pass rates or grading tendencies that are consistently above or below the national averages, with no apparent justification / rationale;
- (b) Flight check times that are consistently shorter or longer than national averages;
- c) Flight check remarks that are poorly worded or do not support the mark awarded;
- (d) Conducting an insufficient number of flight checks to support the need for a ministerial delegation, with no apparent justification / rationale; and
- (e) Documents that have not been completed accurately or in full.
(2) Review FTAE, DAPLS, NACIS and RDIMS (as applicable) to confirm that the ACP or AQPE has performed checks within the scope of their qualifications and authorities.
(3) Document the review in NACIS and indicate whether further action was necessary / taken - (see 9.1 for further guidance on NACIS entries). This measure applies to all ACP / AQPE delegates, including ACPs / AQPEs that have monitor checks completed by delegates with Type M authority. In cases where the findings on an ACP or AQPE are significant enough to warrant corrective action and/or the issuance of a letter of non-conformance, refer to section 8.8 for further guidance.
(4) Regions are also encouraged to consider the use of unannounced monitor checks to enhance the oversight of ACPs and AQPEs. It is unlikely that this practice will eliminate deviations in behavior or marking that often occur during the check; however, TCCA’s unexpected presence eliminates the opportunity to assign above-average pilots to the flight check and creates a deterrent effect that may encourage compliance.
8.5 Oversight of ACPs / AQPEs (with Type M authority)
(1) As stated in AC 700-051, ACPs and AQPEs with Type M authority must be monitored biennially while exercising their Type A or Type E authorities, as per the current policy in the ACP / AQPE Manuals.
(2) The above monitor check must be conducted by a CASI and resets the monitor validity date for all of the ACP’s / AQPE’s authorities, except Type M authority. The ‘valid-to’ date of a Type M authorization is based on the earliest of the following dates:
- (a) Date that the ACP / AQPE is required to attend a monitor check workshop for Type M authority; or
- (b) Date of the next monitor check for Type A or Type E authority; or
- (c) Date of the next ACP / AQPE Recurrent Course.
(3) If a monitor check on an ACP or AQPE is graded as unsuccessful, action to remove all privileges (including Type M authority) on the Letter of Accreditation must be taken in accordance with section 7.3 of this SI.
(4) If an ACP or AQPE with Type M authority receives a grading below three (3) on any of the five items assessed during a successful monitor check, action to remove their Type M authority must be taken in accordance with section 7.3 of this SI. In such cases, the remaining authorizations on their letter of accreditation will remain in effect, which will require the issuance of a revised letter of accreditation.
(5) An ACP or AQPE that has their Type M authority removed can apply for re-instatement of Type M authority after completing a subsequent monitor check that has no items graded below three (3).
(6) If an ACP or AQPE is monitored for sampling or performance reasons while they are exercising Type M authority, the following protocols and procedures apply:
- (a) Complete a PDF version of the Monitor Report on a Person Conducting a Monitor Check, (26-0846);
- (b) Instructions on grading are provided on the form. There is no applicable performance standard or numerical scores that apply to this assessment. The assessment is to be graded as ‘successful’ or ‘unsuccessful’. The primary objective is to mentor the ACP or AQPE as required and make a general assessment of whether the ACP or AQPE exercised their Type M authority in an effective manner;
- (c) A grading of “Unsuccessful” should be rare and only given if it is clear that the ACP or AQPE is not suitable for the Type M role. Should this occur, removal of the delegate’s Type M authority must be actioned in accordance with section 7.3 of this SI. The delegate’s remaining authorizations will remain in effect; and
Note: Delegate’s that have their Type M authority removed under the circumstances described above will not be re-considered for Type M authority until they have gained an additional three-years of experience as an ACP or AQPE and re-attended the Monitor Check Course.
- (d) There is no expiry date applicable to this type of monitor check. The expiry date that applies to the delegate’s other authorizations will remain unchanged.
(7) In addition to the administrative monitoring described in section 8.4 that applies to all ACPs and AQPEs, the records of ACPs and AQPEs that have a Type M authorization must be reviewed annually to assess the following additional items:
- (a) Confirm that the delegate has completed the minimum number of flight and monitor checks, as defined in AC 700-051;
- (b) Confirm that Monitor Report Forms have been accurately completed and comments reflect the marks awarded;
- (c) Check for pass rates or grading tendencies that are consistently above or below the national averages with no apparent justification / rationale; and
- (d) Confirm that the delegate performed monitor checks within the scope of their qualifications and authorities.
(8) At the discretion of the Issuing Authority, concerns in any of the above areas could trigger the need for a monitor check or justify the restriction or removal of a delegate’s privileges.
(9) Document the review in NACIS and indicate whether further action was necessary / taken - (see 9.1 for further guidance on NACIS entries).
(10) If an ACP or AQPE fails to maintain the qualifications and/or recent experience requirements applicable to the Type M authority, the ACP or AQPE can no longer exercise Type M authority; however, the ACP or AQPE can continue to exercise other authorized privileges, assuming that the qualification and recent experience requirements applicable to those privileges have been met.
8.6 Oversight of Pilot Training Programs
(1) TCCA has traditionally used monitor checks as a core activity to conduct oversight of flight check activities. While there is value in this method of oversight, there is a need to expand this focus by increasing oversight of pilot training and conducting a sampling of flight checks on industry pilots.
(2) Deficiencies in pilot competency typically relate back to weak or incomplete training. There is significant value in ensuring that an air operator’s pilot training program is structured and delivered in a manner that promotes pilot competency. Regions are strongly encouraged to incorporate Process Inspections (PI) on pilot training programs in surveillance plans. Conducting this PI is particularly important if the air operator employs delegates with Type M authority.
(3) Regions are also encouraged, where possible, to conduct a sampling of flight checks on industry pilots as an additional method to assess the quality of pilot training. A risk-based approach should be applied to this activity based on the level of confidence that a region has in an air operator’s pilot training and checking programs.
8.7 Oversight of CASIs
(1) TCCA has a responsibility to ensure that CASIs conduct flight and monitor checks in a safe, competent and standardized manner. Failure to maintain this standard reflects poorly on TCCA and diminishes our credibility as a regulator.
(2) Regions are expected to maintain regular oversight of CASIs and respond appropriately to occurrences such as a complaint from a flight check candidate, significant errors in the conduct of a flight or monitor check, or repeated errors on flight check documents. These occurrences may warrant the need for a monitor check and/or enhanced supervision.
(3) Regions must strive to conduct an annual sampling of monitor checks on CASIs that are conducting flight checks. The degree of sampling should reflect the volume of flight checks conducted in the region, CASI experience levels and availability of resources. When a monitor is conducted on a CASI, use the ACP / AQPE Monitor Report (26-0844) or Monitor Report on a Person Conducting a Monitor Check (26-0846), as applicable, to document the monitor.
(4) To facilitate the above oversight, the standards coordinator in each region, or suitability qualified designate(s), is expected to oversee and promote the quality and standardization of flight and monitor checks conducted by CASIs. The standards coordinator should be copied on all routine communication between regions and the ACP Program contacts in HQ.
(1) When a non-conformance or concern is identified during the oversight of a course provider or ACP / AQPE, the Issuing Authority will determine an appropriate response based on the circumstances.
(2) The response could be as severe as limiting, suspending or canceling an authority, or it could entail actions such as enhanced monitoring or counseling. If a written notification is warranted, advise the applicable person(s) of the finding(s) and describe the actions that will be taken. Request a written report on the corrective actions taken, if applicable.
(3) Removing authority must be done in accordance with the protocols specified in section 7.3.
(4) Document all findings and actions in NACIS (see section 9.1).
9.0 Database Updates
(1) The NACIS database is used to track the records of all ACPs / AQPEs, including those with Type M authority. NACIS must be updated after completion of the following activities:
- (a) A Monitor Check / Report (including Administrative Monitor Checks);
- (b) Initial Issuance of Delegation Authority;
- (c) Revision of Delegation Authority;
- (d) Renewal of Delegation Authority;
- (e) Monitor or Course Extensions;
- (f) Letter of Non-Conformance;
- (g) Corrective Action Submission;
- (h) Any other Certificate Action; and
- (i) Deactivation of an ACP Delegation in the DIS database.
(2) Refer to RDIMS 14308304 (English only) for detailed guidance and screen shots on NACIS inputs.
(1) The “CASI ACP ONLY” tab in FTAE is used to track the records of CASIs that conduct flight checks and monitors. CASIs are responsible for ensuring that their qualification records are up-to-date in FTAE.
(2) Accurate data on CASIs facilitates the efforts of regional authorities to leverage CASI resources from other regions to assist with the conduct of flight and monitor checks when it is practical and efficient to do so.
(3) In situations where a flight check is deemed to be invalid (by TATC or TCCA review), the FTR is to be removed from FTAE. This action is to be coordinated with the FTAE manager in CFS. When an FTR is removed from FTAE, a summary of this action and RDIMS reference must be added to the FTAE file of the delegate that conducted the flight check.
10.0 Information Management
(1) All documents related to an ACP’s / AQPE’s delegation of authority must be saved in RDIMS (5802 file), and cross-referenced in NACIS, using the appropriate subject file classification and naming conventions
11.0 Document History
(1) Staff Instruction. (SI) 700-002 Issue 01, RDIMS 4189414 (E), 4245771 (F), dated 2009-04-24 — Approved Check Pilot Monitoring Procedures.
12.0 Contact Office
For more information, please contact:
Commercial Flight Standards - AARTF
Original signed by
Civil Aviation, Transport Canada