The FAA and industry have spent the last three years preparing to replace the existing practical test standards (PTS). As a result, the new airman certification standards (ACS) will go into effect in 2016 for all airman certificates and ratings. This new system can potentially improve the general aviation safety record, but only if flight instructors, designated pilot examiners and FAA inspectors are prepared to teach, test and administer the new system.
We discussed the new standards in a July 2013 article, “The Coming Airman Certification Standards.” We noted the change could potentially “have a greater impact on the general aviation safety record than any regulatory change or new industry training practice in the last 75 years.” Let’s explore what’s coming and why it has potential for beneficial change.
Fixing Disconnects
The FAA decided to replace the PTS for a number of reasons. The most important of these was the fact that the knowledge and practical tests were completely disconnected from each other. Risk management concepts were barely mentioned in the tasks and objectives of individual PTS documents. As a result, pilot training and testing did not always effectively cover what pilots needed to know to operate safely (see “Ineffective Practical Test Standards,” November 2012).
Under the ACS, applicants will be required, for the first time, to demonstrate their ability to tie specific knowledge to individual skill tasks on the practical test. In the past, related knowledge requirements often were glossed over, since the knowledge test was presumed to have been completed separately. Going forward and in addition to knowledge test requirements, applicants also will be required to demonstrate risk management knowledge and skill on each task. This requirement is entirely new to the pilot certification system. The process can be illustrated by looking at a sample task from the draft private pilot ACS document, as presented in the sidebar below.
Under the ACS, applicants clearly will have to be proficient in the risk management process to successfully pass the practical test. Unless they can identify risks and hazards, assess these risks in terms of their likelihood and severity, and then mitigate them to lower acceptable levels of likelihood and severity, they may not pass the practical test. More importantly, they may not be able to conduct effective risk management in the real world.
My own analysis of fatal accident data confirms that, in the majority of fatal accidents, pilots ineffectively managed the risk on the accident flight. This is understandable since risk management has not been a formal part of the pilot training and testing process until the introduction of the ACS.
Training Resources
In fact, currently available materials describing the FAA doctrine on the risk management process is sparse. The agency’s Risk Management Handbook (FAA-H-8083-2) was published in 2009, but is incomplete and only marginally useful as a guide to practical risk management in my view. The latest ACS workgroup pointed out these deficiencies to the FAA and, as a result, the FAA is planning a “limited” revision of the handbook to have it ready for concurrent release of the first ACS documents. A more in-depth revision will take place at a later date.
This is unfortunate since the teaching of risk management, while not rocket science, is a deliberate process that must address the three elements of risk management. Each of the three elements has a critical technique that must be addressed by the guidance material and the training, or the entire process may be ineffective.
For example, identification is key to risk-management awareness for pilots. There are numerous real-world hazards that can create high risk levels and set the stage for a fatal accident. All too often, however, our training system either glosses over these hazards, reduces them to a cautionary bromide or points to regulatory compliance as the barometer for detecting hazards.
For example, pilots training for the private pilot certificate usually only conduct cross-country training flights in good weather. They are admonished to avoid weather below VFR minimums and sent on their way. In reality, basic VFR weather minimums generally don’t provide safe operating margins for low-time private pilots. Under certain conditions—including night operations, low visibility conditions or both—they are completely unsafe for non-instrument rated pilots. Every year there are numerous fatal accidents where the probable cause is listed as “continued VFR into IMC conditions.”
To the FAA’s and industry’s credit, they have developed the well-known PAVE acronym for identifying hazards and risks. That’s Pilot, Aircraft, enVironment, and External pressures. While PAVE has been effectively communicated to the general aviation community, it has not come with sufficient background material to enable instructors to effectively teach the process. The sidebar on the previous page has more.
Adding to the list
Most instructors will need some training in how to teach risk management, including risk identification. First, we must stress there’s an organized process for developing a complete inventory of hazards and risks for any planned flight. This means dropping the typical marketing illusion that aviation is “safe” and emphasizing that’s it’s full of hazards that can increase risk unless identified, assessed and mitigated. The PAVE construct remains highly useful for this purpose.
This type of risk management training is essential yet it’s often underemphasized with pilots during their primary training, as instructors typically spend time emphasizing tasks that will get them through a checkride, like plotting a course or identifying Class E airspace on a chart. These tasks certainly are things a pilot applicant needs to know, and now risk management is being added to the list.
After identifying risk, the next step, risk assessment, usually is more difficult and subjective. Accordingly, instructors should plan on extra effort with pilots-in-training to develop their ability to assess risk likelihood (probability) and severity (consequences). In fact, the main training and operational issue with risk assessment can be determining the levels of risk likelihood and severity. In addition, pilots need to understand they often can control one of the two variables, but rarely both.
After assessing the risk comes its mitigation. Compared to risk assessment, risk mitigation is like a walk in the park. A student already has done the hard work of identifying and assessing hazards and their risks. The task then becomes mitigating them with some common-sense strategies and actions. In all too many cases, however, pilots who have become aware of risks and their consequences have failed to mitigate them and have come to grief. The keys to effective risk mitigation are advance planning and discipline. Pilots who take this approach will find that risk mitigation techniques will allow them to complete most planned missions.
One key can be understanding the difference between flights conducted solely for recreation and those flown for business or personal transportation purposes. Getting from A to B always has more imperative than an optional $100 hamburger flight. It’s important for students to understand both must be cancellable at a moment’s notice, and they may need to say so during the practical test.
Controlling Variables
For example, let’s assume you are planning a flight of several hundred miles and there is a line of thunderstorms at the midpoint, extending 50 miles in each direction. The image above left is representative. In this case, severity of flying directly into the line is fixed and would in most cases be catastrophic. On the other hand, the likelihood of an encounter can be vastly reduced (possibly to improbable) if the pilot offsets the route by 75 miles or so from the straight line track. This would provide a 25-mile margin from the extreme end of the convective line.
In other types of hazards, the likelihood of the risk is fixed while the consequences can be controlled. For example, the day before a planned flight the pilot may be contemplating landing on a relatively short runway in a dense urban area, with a nighttime departure for the return. Mulling that over, she decides she would rather land at an outlying airport, remain overnight, and return home the next day. Why? Well, she reasons that, although small, the likelihood of a catastrophic engine failure taking off from the urban airport at night would have catastrophic consequences. You might say that this is unduly conservative. Aren’t the chances of a catastrophic engine failure improbable?
Maybe not in a piston-engine general aviation aircraft, where “remote” but not “improbable” is the truth. In any case, our pilot has decided she wants a higher safety margin and chooses to reduce the potential consequences to either “critical” or “marginal,” and put the flight more firmly in the green risk area by choosing a daylight takeoff with more emergency landing options.
Instructors should, of course, emphasize all of the tactical risk management steps pilots can take to mitigate risks as the day of the flight approaches. For example, these include changing routes and departure times (including to the day before or after), adding fuel for forecast deviations or departing with less fuel for a departure from a high density altitude situation, or any number of other easy actions that rarely add much time to a flight.
Teaching risk management
Teaching (and learning) risk management is a straightforward process. At best, it should be approached in stages, allowing students to master the concepts and real-world techniques. My recommendation is to approach the process methodically and progress from one stage to another as proficiency is gained. Here are five instructors may wish to consider.
– Master the principles: It’s important to understand basic risk management concepts, such as minimizing all risks and mastering the three-phase process. This can best be done through either an online course or a formal class.
– Analyze case studies: It’s always easier to understand concepts when they’re illustrated through real-world examples, especially when they involve fatal accidents caused by poor risk management. Using a worksheet-like analysis tool will help you gain experience with the process. Again, this should be part of a course or formal class.
– Use FRATs: Once a student “graduates” from training, a flight risk assessment tool (FRAT) can be useful for managing risk on your first few flights. Be wary of those FRATs that have a scoring system that says it’s okay to go if the score is low enough. Students should know there might still be some unacceptable risks remaining. They need to understand mitigating all risks to lower levels, if possible, is the way to go.
– Apply the acronyms: After a few flights, students should be comfortable managing the risks using the acronym approach. That’s the PAVE method of identifying risk. If you’re a lover of acronyms, you can continue by using ALS to assess likelihood and severity. Finally, you can use TEAM to decide whether to transfer, eliminate, accept or mitigate the risk.
While some may disparage using such multiple acronyms, I believe they are useful memory aids that will help make the process second nature to less-experienced pilots.
– Intuitive risk management: Ultimately, with enough practice and experience, instructors should want to see the risk management process thoroughly ingrained in a student’s flight planning and procedures. It should be intuitive and not require the conscious use of tools or acronyms. A FRAT can help if a student has been away from the cockpit for a while or when complex situations are confronted, as can other tools.
I’m a little slow on the draw and it’s taken me more than 9600 hours and 50 years of flying experience, but I finally got the flick on risk management as a preflight and in-flight tool. Most of your students will find it easier to master the process than I did, especially if the FAA and industry provide effective implementation of the ACS system and you avail yourself of the emerging risk management training.
Robert Wright is a former FAA executive and President of Wright Aviation Solutions LLC. He also is a 9600-hour ATP with four jet type ratings, and a flight instructor. His opinions in this article do not necessarily represent those of clients or other organizations he may represent.
