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European Aviation Safety Agency User Guide

Foreign ATO approvals – User guide for FSTD user approval Doc # UG.FCTOA.00005-000

Approval Date 08/06/2012

© European Aviation Safety Agency. All rights reserved.

Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet. of 40

Foreign ATO approvals – User guide for FSTD user approval

UG.FCTOA.00005-000

Name Validation Date

Prepared by: Chaouki CHABBI 08 June 2012

Verified by:

Reviewed by:

Approved by:






DOCUMENT CONTROL SHEET

Process Area Organisation approval

Main Process Flight Crew Licensing Organisation Approval

Scenario ATO approval

Process

Main Process Owner

Reference documents

a) Contextual documents

Basic Regulation: Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC as amended;

Aircrew Regulation: Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council;

Amended Aircrew Regulation: Aircrew regulation as amended by Commission Regulation (EU) No 290/2012 of 30 March 2012.

b) Internal documents

EASA Form 143 - ATO approval certificate

FO.FCTOA.00010 - Application for a Part–ORA ATO Approval

UG.FCTOA.00003 - Foreign ATO approvals - User Guide for Applicants

UG.FCTOA.00004 - Foreign ATO approvals - User guide for ATO Manuals

Log of issues

Issue Issue date Change description

000 08 June 2012 Minor editorial changes from preliminary draft version UG.FCLOA.00000-000 dated 13/10/2011

Disclaimer page 3 deleted as any draft version cannot be confused with the final version of a document.

Update of internal document references






1 Table of content

1 Table of content ........................................................................................................... 3

2 Definitions and Abbreviations ....................................................................................... 4

3 Scope ........................................................................................................................... 4

4 Important considerations ............................................................................................. 5

5 Context ........................................................................................................................ 5

6 Objective ...................................................................................................................... 6

7 FSTD operators compared to ATOs (FSTD users) ............................................................ 6

8 Interpretation of the “Guidance information” on an FSTD certificate ............................. 7

9 Demonstration of compliance ....................................................................................... 7

9.1 For the initial user approval ........................................................................................ 7

9.2 During the oversight phase ......................................................................................... 8

10 Criteria for the use of an FSTD for a given training course .............................................. 9

11 Handling the misuse use of an FSTD ............................................................................ 37

11.1 Warning ..................................................................................................................... 37

11.2 Applicability ............................................................................................................... 37

11.3 Objective ................................................................................................................... 37

11.4 Methodology for risk mitigation ............................................................................... 38

12 Formal approval of the use of an FSTD ........................................................................ 39






2 Definitions and Abbreviations

A&P Applications and Procurements services ACO Approval Coordinator AMC Acceptable Means of Compliance ARE Accredited Recommending Entity ATO Approved Training Organisation

ATPL Airline Transport Pilot Licence BPL Balloon Pilot Licence CFI Chief Flight Instructor

CMS Compliance Monitoring System CPL Commercial Pilot Licence

CTKI Chief Theoretical Knowledge Instructor EASA European Aviation Safety Agency

EU European Union FCL Flight Crew Licencing

FCLAO Flight Crew Licensing Organisation Approval FCLOM EASA’s Flight Crew Licensing Organisation Manager

GM Guidance Material HoD Head of EASA’s Organisations Department

HT Head of Training JAA Joint Aviation Authorities JAR Joint Aviation Requirements

LAPL Light Aircraft Pilot Licence MOR Mandatory Occurrence Reporting MPL Multi-Crew Pilot Licence

MS EASA Member States (as per Art.34 and 66 of Regulation (EC) No 216/2008 as amended) OAM Organisation’s Accountable Manager

OM Operations Manual OPC Oversight Planning Cycle

Part FCL Annex I of Amended Aircrew regulation Part MED Annex IV of Amended Aircrew regulation Part ARA Annex VI of Amended Aircrew regulation Part ORA Annex VII of Amended Aircrew regulation

PPL Private Pilot Licence PTO Pilot Training Organisations SMS Safety Management System SPL Sailplane Pilot Licence TC Third County: outside the territory of MS

TITL Technical Investigation Team Leader TOA Training Organisation Approval

TOAP Training Organisation Approval Procedures TRI Type Rating Instructor

TRM Training Manual TRP Training Programme WG Working Group

WHOC EASA Working Hours Oversight Coordinator ZFTT Zero Flight-Time Training

3 Scope

This user guide for the FSTD user approval is complementary to the requirements of Implementing Rule – Aircrew Regulation (EU) 1178/2111 “as amended” and does not supersede or replace the information defined within that document.






4 Important considerations

This guide is intended to be used by:

Part ORA PTOs (Pilot Training Organisations) - To assist them in establishing the processes and procedures related to the use of FSTD’s to provide the courses under the organisation’s approval scope. This should ease the drafting of the related parts of the organisation’s manuals when submitting an application for an EASA Part-ORA approval (FO.FCTOA.00010 - Application for a Part–ORA ATO Approval). It can also be used for the implementation of related processes and procedures.

Technical Investigation Team Leader - As a guidance when assessing compliance of the ATO’s management system, processes, procedures and manuals submitted to them for approval as well as their implementation.

The user guide is provided for guidance only and shall not prevent any organisation to adapt its content to its needs as necessary to achieve equivalent or better compliance with Part ORA. When deviating from this guidance, it is essential however that the PTO demonstrates that the proposed alternative options are at minimum equivalent to this guidance in terms of compliance and safety as required by:

ORA.GEN.120 and related AMC & GM Assessment demonstrating that Regulation (EC) No 216/2008 and its Implementing Rules are met Risk assessment demonstrating an equivalent level of safety is reached

ORA.GEN.200 (3) Identification and evaluation of aviation safety hazards entailed by the activities of the organisation, Management of associated risks, Risk mitigation and confirmation of effectiveness of actions taken

PTOs using Flight Simulation Devices to provide training are required to satisfy themselves that the training devices they use are assessed for continued suitability (refer to related AMC & GM).

Continued suitability includes the necessity for the user of the device to:

Constantly adhere to the procedures for which the device is qualified and

Constantly operate the device within the specifications and limitations under which it is qualified and

Continually comply with the regulations applicable to the device qualification and

Regularly assess the effectiveness and the quality of the training provided using the device

THE MISUSE OF AN FSTD WHILE PROVIDING PILOT TRAINING SHALL BE CONSIDERED AS AN AVIATION SAFETY CONCERN.1

The organisation is expected to comply with all applicable requirements of the relevant regulations and particularly the ones related to training standards and risks for safety. The organisation’s documents should provide clear, detailed and comprehensive information on how the organisation intends to achieve compliance when using FSTDs to provide training courses.

When considering applicable requirements to the use of FSTDs to provide training, it is essential that the qualification of the device is not interpreted as an approval for its use. The qualification of a device is a prerequisite for its use but does not systematically imply suitability for a specific course.

5 Context

Pilot training using FSTDs involves potential aviation safety risks that have to be managed. Taking actions to mitigate these risks and verifying effectiveness of actions made is part of the management processes expected to be implemented.

Two aspects of FSTDs are to be considered. This can be outlined as follows:

Aspect Covered by Related sub-part of the implementing rules

Fit for use The “qualification” of the device Part-ORA and Part-ORA/FSTD

Fit for purpose “user approval” of the device for given Part-ORA and Part-ORA/ATO

1 See paragraph 11 for more details






training objectives

The risks related to each of these two aspects have different characteristics but the final outcome can be either:

Not fit for use Not fit for purpose

1. Accidents or incidents during training Design flaw or failure of the simulator

Incorrect use of the simulator during a training session

2. Post training aviation accidents or incidents resulting from incorrect training of the pilot

Lack of fidelity of simulation Inadequate use of the simulator given the course objectives

This guide relates to the “user approval” (fit for the purpose) aspects assuming that the FSTD is already qualified according to applicable regulation making it presumably fit for the use.

6 Objective

This guide is aimed at indicating how a PTO can demonstrate compliance with applicable requirements of Regulation (EC) No 216/2008 and its Implementing Rules, when applying for an EASA Part-ORA ATO approval as far as the use of FSTDs to provide training is concerned.

7 FSTD operators compared to ATOs (FSTD users)

The distinction between FSTD operator and FSTD user has to be kept in mind while dealing with FSTDs involved in practical pilot training or testing. This distinction results from the duality between the need for a “qualification” of a training device and the need for a “user approval”.

To simplify, using the table introduced above, this can be represented in this manner:

Aspect Covered by Related sub-part of the

implementing rules Organisation concerned

Fit for use The “qualification” of the device

Part-ORA and Part-ORA/FSTD FSTD operator

Fit for purpose

The “user approval” of the device for given training objectives

Part-ORA and Part-ORA/ATO FSTD user

(PTO in the context of this user guide)

Some FSTD operators do not provide any pilot training. Others are also PTOs. When an organisation is using its own FSTDs to provide training it is regarded at the same time as an FSTD operator and as an FSTD user (ATO).

As an FSTD operator:

The organisation will have to fulfil the relevant Part-ORA requirements to qualify the simulators before they can be used for training.

As a ATO (FSTD user):

The organisation will have to fulfil the relevant Part-ORA requirements to obtain a user approval before providing any training using a given qualified simulator for a given course.






8 Interpretation of the “Guidance information” on an FSTD certificate

A Part ORA/FSTD qualification certificate includes a list of the FSTD specifications. Item L (the last item) of this list is labelled “Guidance information for training, testing and checking considerations”.

L. Guidance information for training, testing and checking considerations

CAT I RVR m DH ft

CAT II RVR m DH ft

CAT III RVR m DH ft (lowest minimum)

LVTO RVR m

Recency

IFR-training / check /

Type rating

Proficiency checks

Autocoupled approach

Autoland / roll out guidance /

ACAS I / II /

Windshear warning system / predictive windshear /

WX-radar

HUD / HUGS /

FANS

GPWS/EGPWS /

ETOPS capability

GPS

Other

As stated in the qualification certificate, the information provided in table L is only an indication on the capacity of the device to provide adequate simulation for the conditions, the systems, the environment or the equipment listed. It does not mean that the device is adequately fit for the purpose of the training stated.

In fact some indications are related to OPS specifications and not to FSTD regulation such as CAT II or CAT III for example. FSTD certification specifications are not systematically linked to OPS specifications. There is no obligation to check for specific equipment such as an “approved lateral guidance system for take-off” as stated in Appendix 1 (Old) to OPS 1.430 §(a)(4)(ii)(B) to release an FSTD qualification certificate with a table L stating “LVTO 75m RVR” for example. Such indication on an FSTD certificate may be misinterpreted by an FSTD user if considered as a user approval specification.

Any indication in table L of an FSTD qualification certificate under “Guidance information for training, testing and checking considerations” has to be crosschecked with the applicable requirements of OPS/FCL or any other regulation relevant to the training course to be provided before considering any training, testing and checking on the device.

The applicable requirements to the crediting of the training to be provided on the device are not necessarily fully covered by the “Guidance information for training, testing and checking considerations” provided on an FSTD qualification certificate.

9 Demonstration of compliance

The list of criteria given in paragraph 10 page 9 , should be used in different ways depending on the type of investigation and the technical aspect to be considered (i.e. documentation or implementation)

9.1 For the initial user approval

Documentation: during the review of the organisation’s documentation system for all aspects that shall be documented, the list shall be systematically checked, then

Implementation: when considered satisfactory, all criteria in the list shall be reviewed during the audit on site for the relevant aspects that are already implemented. When not yet implemented, the items still to be checked shall be deferred to the regular monitoring of the oversight phase. The technical investigation inspector must systematically check effective implementation by attending as many sampled training sessions as needed.






9.2 During the oversight phase

Documentation: the review of the organisation’s documentation system is sampled during the preparation phase of the investigation on site. This sampling shall systematically include all changes introduced after the last technical investigation.

Implementation: samples of the criteria in the list shall be reviewed during the audit on site. Criteria related to all changes introduced after the last technical investigation as well as the deferred items from the initial approval phase, if any, shall be checked. In all cases the criteria related to the compliance monitoring and the safety management in the list shall be systematically reviewed. The technical investigation inspector may check effective implementation by attending as many sampled training sessions as needed.






10 Criteria for the use of an FSTD for a given training course

The use of an FSTD to provide training for a given course will only be granted to a PTO when it can demonstrate that it has adequately addressed the following:

Criteria Yes No N/A Doc ref (as applicable) / notes

1 Management system

1.1 Responsibility and roles throughout the organisation as regards the use of the device (ORA.GEN.200 §(a)(1))

1.1.1 Is the responsible for the initial and continued determination of the qualification and technical specifications of the device clearly identified?

1.1.2 Is the responsible for the operational aspect of the activity on the device clearly identified? (Operational planning and scheduling, documentation to be provided, activity management and control) (see details in part 3 page 18)

1.1.3 Is the responsible for the initial and continued compliance monitoring of the use of the device clearly identified (ORA.GEN.200 §(a)(6))?

1.1.4 Is the responsible for the initial and continued identification of the aviation safety hazards entailed by the training on the device, their evaluation and the management of associated risks, clearly identified (ORA.GEN.200 §(a)(3))?

1.1.5 Are responsibilities and roles throughout the organisation as regards the actions to be taken for risk mitigation related to the use of the device clearly identified (ORA.GEN.200 §(a)(1))?







1.1.6 Are the roles and responsibilities of the instructors clearly determined and sufficiently detailed?

1.1.7 Are the roles and responsibilities of the staff clearly determined and sufficiently detailed?

1.1.8 Are the roles and responsibilities of the trainees clearly determined and sufficiently detailed?

1.2 Documentation related to the use of the device: (ORA.ATO.130 & ORA.ATO.230)

1.2.1 Are the roles and responsibilities of the relevant management staff related to the documentation clearly determined and sufficiently detailed (ORA.GEN.200 §(a)(1))?

1.2.2 Are there documented methods and procedures adopted and applied to develop, validate, produce and distribute the documentation need to make the personnel aware of their responsibilities and duties; particularly the persons indicated in 1.1 (page 9)?

1.2.3 Are the sampled publications indicated in 1.2.2 (page 10), satisfactory?

1.2.4 Are the sampled publications indicated in 1.2.2 (page 10), distributed and made available satisfactorily?

1.2.5 Are there documented methods and procedures adopted and applied to timely review or amend the documentation and make it available to relevant personnel?







1.2.6 Are the sampled publication updates made available as indicated in 1.2.5 (page 10), satisfactorily?

1.2.7 Has the organisation sufficient control on the documentation to ensure traceability of its distribution, to avoid the use of outdated versions or invalid editions and to check document integrity and applicability status?

1.2.8 Are the sampled distribution lists as indicated in 1.2.7 (page 11), satisfactory?

1.2.9 Can the integrity of document samples be checked as indicated in 1.2.7 (page 11), satisfactorily?

1.2.10 Can the applicability of document samples be checked as indicated in 1.2.7 (page 11), satisfactorily?

1.3 Financial resources:

1.3.1 Are there documented methods and procedures adopted to plan for the financial resources needed to deliver the training on the device (budget or equivalent)?







1.3.2 Does the planning as indicated in 1.3.1 (page 11) cover the financial resources needed as regards:

What is to be provided? to achieve the course on the device (not only the device itself but also the briefing rooms, the staff, the training of the instructors, the manuals, the validation of the sessions, etc. …)

How is it to be provided? to achieve the course on the device: processes to be considered, internal and external resources to be allocated and made available, etc. …

When is it to be provided? to achieve the course on the device (not only the time sequencing of the training sessions but also the chronology of the processes enabling the delivering of the training sessions such as when the manuals have to be provided, when the instructors have to be ready, etc. …)

Where is it to be provided? to achieve the course on the device: on-site, at another training centre or place in the same city, in the same country, abroad, etc. …

1.3.3 Is the implementation of the financial planning controlled and the actual results compared with the plans so that action can be taken to modify the operation of the business as time passes, or possibly to change the plans if they become unachievable?

1.3.4 Is the efficiency of the financial planning measured and improved according to clearly stated objectives and criteria?







1.4 Feedback on management system

1.4.1 Are the users (instructors, staff and trainee) of the manuals, documents and publications related to the device as indicated in 1.2 (page 10), given the opportunity to provide feedback on the content, the relevance and the intelligibility of the documentation and the effectiveness of the processes related to its production, control and distribution?

1.4.2 Is the feedback provided by the users of the documentation, as indicated in 1.4.1 (page 13), effective?

Are the users informed about the opportunity to provide feedback? Is any feedback provided? Is the information collected through the feedback used? Has the feedback any impact on the quality of the documentation and its production / distribution? Are the users providing feedback encouraged and informed about the outcome of their inputs?

1.5 Compliance monitoring of the management system (ORA.GEN.200 §(a)(6))

1.5.1 Are the responsibilities and roles throughout the organisation as regards the use of the device as indicated in 1.1 (page 9), under compliance monitoring (compliance with regulation requirements as well as internal criteria, standards and procedures)?

1.5.2 Is the compliance monitoring as indicated in 1.5.1 (page 13), effective?

When was the last check performed? When is the next check expected? What was the result of the last check? What changes have been made? What are the reasons for the changes made?







1.5.3 Do the methods and procedures to review / amend the documentation as indicated in 1.2.5 (page 10), include continuous improvement and compliance monitoring of the manuals and publications (compliance with regulation and internal requirements)?

1.5.4 Is the monitoring and improvement of the documentation related to the use of the device, as indicated in 1.5.3 (page 14), effective?


1.6 Safety management of the management system (ORA.GEN.200 §(a)(3))

1.6.1 Are the potential aviation safety hazards entailed by the management system related to the use of the device as indicated in the relevant criteria detailed in 1.1 (page 9), 1.2 (page 10) and 1.3 (page 11), continually identified, evaluated and associated risks appropriately managed?

1.6.2 Are actions taken to mitigate the risks indicated in 1.6.1 (page 14) and is the effectiveness of these actions verified?







2 Qualification and technical specifications

2.1 Methods & procedures

2.1.1 Are there documented methods and procedures adopted to determine the initial and continued qualification and technical specifications of the device?

2.1.2 Do the documented methods and procedures, as indicated in 2.1.1 (page 15) include the description of a system to adequately monitor changes to the FSTD and to ensure that those changes do not affect the adequacy of the training programme (ORA.ATO.135 §(b)(4))?

2.1.3 Do the documented methods and procedures, as indicated in 2.1.1 (page 15) include the initial and continued management of possible restrictions and limitations of the device qualification?

Note: When changes to the FSTD occur, what are the actions taken? What procedures are applied? What adjustments to the training program or the training methodology are made? How acceptable and unacceptable limits are determined? Who is in charge of the relevant processes? Etc. …







2.2 Implementation

2.2.1 Is the present qualification of the device still valid?

Note: Is it possible to check, if the qualification has been changed, revoked, surrendered, restricted? Is the time needed to check the qualification of the device consistent with the need for swift uncertainty resolution before starting a training session at any time of the day and any day of the year?

2.2.2 Is the present qualification of the device suitable for the course as required by applicable regulation and internal organisation’s criteria?

2.3 Feedback on the qualification and technical specifications

2.3.1 Are the instructors involved enabled to provide feedback on the qualification and technical specifications of the device (feedback system in place, reporting schemes)?

2.3.2 Is the feedback provided by instructors, part of the continued suitability assessment of the device?







2.3.3 Is the feedback provided on the qualification and technical specifications of the device as described in 2.3.1 (page 16) and 2.3.2 (page 16), effective?

Are the users informed about the opportunity to provide feedback? Is any feedback provided? Is the information collected through the feedback used? Are actions taken based on the feedback provided? Are the contributors to the feedback encouraged and informed about the outcome of their inputs?

2.4 Compliance monitoring of qualification and technical specifications (ORA.GEN.200 §(a)(6))

2.4.1 Are the methods & procedures as regards the qualification and technical specifications of the device and their implementation as indicated in 2.1 (page 15) and 2.2 (page 16), under compliance monitoring (compliance with regulation requirements as well as internal criteria, standards and procedures)?

2.4.2 Is the compliance monitoring as indicated in 2.4.1 (page 17), effective?


2.4.3 As a result of the compliance monitoring indicated in 2.4.1 (page 17), are the qualification and technical specifications of the device, compliant with applicable regulation and in particular Regulation (EC) No 216/2008 and all Implementing Rules?







2.4.4 Are the sampled procedures for the qualification and technical specifications of the device, as indicated in 2.1.1 (page 15), satisfactory?

2.5 Safety management of qualification and technical specifications (ORA.GEN.200 §(a)(3))

2.5.1 Are the potential aviation safety hazards entailed by the methods & procedures as regards the qualification and technical specifications of the device and their implementation as indicated in 2.1 (page 15) and 2.2 (page 16), continually identified, evaluated and associated risks appropriately managed?

2.5.2 Are actions to mitigate the risks indicated in 2.5.1 (page 18), taken and their effectiveness verified?

3 Operations

3.1 User manuals of the device

3.1.1 Are there documented methods and procedures adopted to provide the instructors and relevant personnel with the operating manuals of the device?

3.1.2 Do the device manuals, as indicated in 3.1.1 (page 18), provide sufficient information to enable the instructor to operate the device throughout each session of the intended training course?







3.1.3 Do the device manuals, as indicated in 3.1.1 (page 18), provide sufficient information on the hazards, risks and the safety features and procedures related to the use of the device for all training sessions to be conducted?

3.1.4 Do the device manuals, as indicated in 3.1.1 (page 18), provide sufficient information to enable the instructors to determine the normal range of operating limitations related to use of the device?

3.1.5 Are the device manuals, as indicated in 3.1.1 (page 18), part of the organisation’s documentation and related procedures as detailed in the relevant criteria under 1.2 (page 10)?

3.1.6 Are there documented methods and procedures adopted and applied to timely review or amend the user manuals and make it available to relevant personnel?

3.1.7 Has the organisation sufficient control on the user manuals to ensure traceability of its distribution, to avoid the use of outdated versions or invalid editions and to check document integrity and applicability status?

3.2 Operational planning (annual or any similar seasonal/cyclic planning)

3.2.1 Are there documented methods and procedures adopted to plan for the activity on the device?

3.2.2 Is the continuity of planning ensured when needed (from one cycle of planning to the next: to cover any possible delayed or overlapping training activity)?







3.2.3 Is the activity needed to ensure the validation of the training sessions included in the planning (content and timing session validation see 4.2.3 (page 31) and 4.2.7 (page 31))?

3.2.4 Are the plans for the activity available to relevant persons?

3.2.5 Are the sampled previous plans and the current one for the activity on the device satisfactory?

3.2.6 Has the planned activity on the device been determined in terms of:

Hours? For the next Days/Weeks/Months?

3.2.7 Has the planned activity on the device been determined in terms of:

Total number of courses to be provided on the device?

For the next Days/Weeks/Months?

3.2.8 Are there documented methods and procedures adopted to plan for contingencies such as delayed or additional training needed on the device, remedial training, maintenance disruptions and/or qualification changes of the device?







3.3 Operational scheduling (implementation of planned activity in terms of daily, weekly, monthly or any similar continued programming of the use of the device)

3.3.1 Are there documented methods and procedures adopted for the scheduling of the activity on the device?

3.3.2 Are the methods and procedures for the operational scheduling indicated in 3.3.1 (page 21), clearly identifying the various phases of the activity related to the use of the device?

Note: The operational scheduling shall clearly indicate when the briefing, the session, the debriefing starts and ends. Possible breaks between the various phases or during the session shall be indicated in the sequencing as well as the time allocated to permit the changeover between users (instructor and trainee) leaving the device and users joining to start the next session on the same device (buffer changeover time between users shall not be considered or logged as training time).

3.3.3 Do the methods and procedures adopted for the scheduling of the activity on the device include duty time limitation and/or fatigue management considerations (see also 4.2.12 (page 33) to 4.2.15 (page 33))?

3.3.4 Are the duty time limitation schemes consistent with applicable regulation and acceptable standards?

3.3.5 Are the schedules for the activity on the device timely communicated to relevant personnel and trainee?







3.4 Session delivery

3.4.1 Are the roles and obligations of the instructors and the trainee clearly documented as regards the tasks to be accomplished during the briefings, debriefings and all along the different sessions (When to meet? Where to meet? What are the facilities to be used? What are the documents to be used? Who brings what for what purpose? Etc. …)?

3.4.2 Are the roles and obligations of the instructors and the trainee clearly documented as regards the use of the device (initial safety briefing, access to the device, policy about foods and drinks inside the device or the facilities, use of systems and equipment such as antiseptic wipes for headsets and/or oxygen masks, documents and/or checklists kept on board, flags/tags/stickers/placards for inoperative instruments, indicators or controls, etc…)?

3.4.3 Are there documented methods and procedures adopted for the minimum serviceability of the device for each session to be conducted (minimum operational and technical functionalities and lowest acceptable training capabilities)?

3.4.4 Are all involved instructors, trainees and personnel made aware of their roles and obligations as regards the serviceability of the device as indicated in 3.4.3 (page 22)?

3.4.5 Are there documented methods and procedures adopted to report technical defects and device serviceability?

3.4.6 Are all involved instructors, trainees and personnel made aware of their roles and obligations as regards the reporting about device serviceability as indicated in 3.4.5 (page 22)?







3.4.7 Are there documented methods and procedures adopted to record the activities conducted on the device (procedures for logbooks, records related to pilot training, instructor familiarisation, session validation, downtime duration, delayed training, etc. …)?

3.4.8 Are all involved instructors, trainees and personnel made aware of their roles and obligations as regards the recording of activities as indicated in 3.4.7 (page 23)?

3.4.9 Are there documented methods and procedures adopted to ensure recovery and continuity of training for the given course in case of unavailability of the device or the facilities related to its use (such as briefing / debriefing rooms, safety features …)?

3.4.10 Are there documented methods and procedures adopted to ensure business recovery and continuity of training for the given course in case of shortage of instructors (sick leave, fatigue …)?

3.5 Operational competence

3.5.1 Are there documented methods and procedures adopted to familiarise each instructor with the use of the device so that he is able to operate it according to its approved operating procedures when conducting each training session?

3.5.2 Do the methods and procedures to familiarise the instructors indicated in 3.5.1 (page 23), include the standardisation of all flight simulation instruction (ORA.ATO.210 §(b))?







3.5.3 Are the instructors familiarised with the use of the device as indicated in 3.5.1 (page 23) and 3.5.2 (page 23), trained to operate the device in compliance with the organisation’s methods and standards for each training session?

3.5.4 Is the activity needed to ensure the training and the familiarisation of the instructors using the device, as indicated in 3.5.1 (page 23), 3.5.2 (page 23) and 3.5.3 (page 24), included in the operational planning as indicated in 3.2 (page 19)?

3.5.5 Are the sampled records and data on the familiarisation of each instructor with the use of the device, as indicated in 3.5.1 (page 23), 3.5.2 (page 23) and 3.5.3 (page 24), satisfactory?

3.6 Feedback on operations

3.6.1 Are the involved instructors enabled to provide feedback on the operations (all aspects indicated in 3.1 (page 18) to 3.5 (page 23)) related to the use of the device (feedback system in place, reporting schemes …)?

3.6.2 Are the involved trainee enabled to provide feedback on the operations as indicated in 3.6.1 (page 24)?

3.6.3 Is the feedback on operations provided as described in 3.6.1 (page 24) and 3.6.2 (page 24), part of the continued suitability assessment of the device?







3.6.4 Is the feedback provided on operations as described in 3.6.1 (page 24) and 3.6.2 (page 24), effective?

Are the users informed about the opportunity to provide feedback? Is any feedback provided? Is the information collected through the feedback used? Are actions taken based on the feedback provided? Are the contributors to the feedback encouraged and informed about the outcome of their inputs?

3.7 Compliance monitoring of operations (ORA.GEN.200 §(a)(6))

3.7.1 Are all aspects of the operations related to the use of the device (as indicated in 3.1 (page 18) to 3.5 (page 23)), under compliance monitoring (compliance with regulation requirements as well as internal criteria, standards and procedures)?

3.7.2 Is compliance monitoring of operations related to the use of the device as indicated in 3.7.1 (page 25), effective?


3.8 Safety management of operations (ORA.GEN.200 §(a)(3))

3.8.1 Are the potential aviation safety hazards entailed by all aspects of the operations related to the use of the device (as indicated in 3.1 (page 18) to 3.5 (page 23)), continually identified, evaluated and associated risks appropriately managed?








4 Training

4.1 Adequacy of device for the training course

4.1.1 Has the organisation checked that the training on the device can be credited towards the intended pilot training course according to applicable aircrew regulation requirements?

4.1.2 Is the credit checking as indicated in 4.1.1 (page 26), satisfactory?

4.1.3 Are there documented methods and procedures adopted to ensure that the device adequately represents physically the simulated aircraft type/variant, class or generic model for the purpose of the training (particularly for FFS [ORA.ATO.135 (b)(3)])?

4.1.4 Is the device at present time adequately representing the simulated aircraft physically for the purpose of the training?

4.1.5 Are there documented methods and procedures adopted to ensure that the device adequately reacts as the aircraft type/variant, class or generic model would, for the purpose of the training?

4.1.6 Is the device at present time adequately reacting compared to the simulated aircraft for the purpose of the training?







4.1.7 Are there documented methods and procedures adopted to ensure that the device’s Instructor Operating Station (IOS), features, training capabilities, systems and controls dedicated to the management of the training sessions are adequate for the training to be provided?

4.1.8 Is the device at present time providing adequate session management capabilities as indicated in 4.1.7 (page 27)?







4.1.9 For the purpose of the training, has the device to simulate a specific aircraft:

Type? Variant? Class?

4.1.10 For the purpose of the training, has the device to simulate a specific aircraft engine:

Type? Variant/Model? Class?

4.1.11 For the purpose of the training, has the device to simulate a specific aircraft equipment or system:

GPWS? EGPWS? ACAS?

Reactive windshear warning? Predictive windshear warning?

HUD? Other?







4.1.12 For the purpose of the training, has the device to simulate a specific airport related environment:

RWYs? Ground mvt area layout? SIDs?

STARs? Approaches procedures? Visual procedures?

Other?

4.1.13 For the purpose of the training, has the device to simulate a specific physical environment:

Surrounding terrain? Weather conditions Surrounding traffic?

Navigations AIDS? Other?

4.1.14 Has any specific training feature or capability of the device on which is based any training session been identified (Nominal session delivery specifications: automated lesson plans, particular resets, speedup functions, repositioning capabilities, freeze functions, preloaded aircraft or weather settings, pre-set visual or flight conditions, etc. ….)?

4.1.15 Has any alternative means of delivering the training been determined so as to prevent potential negative impact on training in case the special training feature indicated in 4.1.14 (page 29) is altered or lost?







4.1.16 Has any device specific simulation biases/artefacts affecting the training been identified?

Note: No flight simulation is perfect. Simulation biases and / or artefacts are acceptable as long as they are managed properly and do not negatively affect the final outcome of the training provided.

The training organisation is responsible for the identification of any simulation bias and / or artefact that might affect the training. Some of them may have negligible impact on the training and do not need any remedial action (unrealistic ice accretion on windshield). Others might impact the training but can still be accepted if the consequences are small enough to be corrected by other training means or methods (limited realism of radio chats can easily be addressed by some additional training where the trainee is faced with real-time radio communication in real ATC environment).

In all cases, the training organisation shall identify the simulation biases and / or artefacts when initially accepting the device for the training and thereafter continually during its use. The impact on training shall be assessed and the remedial actions shall be documented and implemented. When no remedial is needed, the training organisation shall record the initial assessment made and keep it updated as this evaluation may need to be revised later on during the life cycle of the device.

4.1.17 Has the training course related to the use of the device been adjusted to counterbalance the effects of known simulation biases/artefacts as identified in 4.1.16 (page 30)?

4.1.18 Has each instructor been made aware, trained and checked to address the known simulation biases/artefacts as identified in in 4.1.16 (page 30)?







4.2 Adequacy of training course delivery on device

4.2.1 Are the standards and training objectives for each flight simulated session, to be provided using the device, determined and clearly stated (ORA.ATO.230)?

4.2.2 Are the standards and training objectives indicated in 4.2.1 (page 31) consistent with the relevant parts of the organisation’s manuals and particularly as regards their integration into the training plan with the theoretical instruction (ORA.ATO.110 (b)(2))?

4.2.3 Are there documented methods and procedures adopted to validate each training sessions on the device, (initial validation and subsequent continued suitability as needed)?

4.2.4 Have the session validations as indicated in 4.2.3 (page 31) been conducted?

4.2.5 Are the sampled training sessions validation reports and related data as indicated in 4.2.4 (page 31), satisfactory?

4.2.6 Does each session validation as indicated in 4.2.4 (page 31) adequately confirm consistency between the nominal session content and the session objectives (initial validation of training content consistency with objective)?

4.2.7 Does each session validation as indicated in 4.2.4 (page 31) adequately confirm nominal session timing adequately (timing of separate sequences of exercises i.e. nominal lesson plan timing breakdown)?







4.2.8 To provide the training course, has the total time of simulation on the device been determined?

Total hours? Total days? Other?

4.2.9 Are there documented methods and procedures adopted to determine the ability of each instructor to deliver the training on the device at the proficiency level required by the regulation and the organisation’s quality and performance criteria (for initial competence demonstration and subsequent continued proficiency as needed)?

Note: This relates to the ability of the instructor to provide training and not to its ability to “operate the simulator” as covered by the criteria under 3.5 (page 23).

4.2.10 Do the methods and procedures to familiarise the instructors indicated in 4.2.9 (page 32), include the standardisation of all flight simulation instruction (ORA.ATO.210 §(b))?

4.2.11 Are the sampled instructor’s proficiency checks and data related to the ability of delivering the training on the device as indicated in 4.2.9 (page 32) and 4.2.10 (page 32), satisfactory?







4.2.12 Are there documented methods and procedures adopted to identify possible negative effects on training resulting from instructor fatigue?

Note: High level of fatigue of an instructor may lead to the misuse of the training device while providing training. This can in turn result in shortages in pilot training and shall be considered as an aviation safety concern.

As part of the management system (ORA.GEN.200 §(3)) the organisation shall identify all the possible negative effects instructor fatigue may have on pilot training. Special attention should be given to particular conditions or combined effects such as (but not limited to) late night sessions, cumulated aircraft and simulator activity, cumulated administrative tasks and teaching, complexity of session content combined with other factors, repetitive tiring sessions, etc. …

4.2.13 Are the methods and procedures identifying the impact of instructor fatigue as indicated in 4.2.12 (page 33), adequately combined with preventive strategies?

4.2.14 Are there documented methods and procedures adopted to identify possible negative effect on training resulting from trainee’s fatigue?

4.2.15 Are the methods and procedures identifying the impact of trainee fatigue as indicated in 4.2.14 (page 33) adequately combined with preventive strategies?







4.3 Feedback on training

4.3.1 Are the involved instructors enabled to provide feedback (feedback system in place, reporting schemes …) on all aspects of the training provided on the device (as indicated in relevant parts of 4.1 (page 26) and 4.2 (page 31))?

4.3.2 Are the involved trainee enabled to provide feedback on the training as indicated in 4.3.1 (page 34)?

4.3.3 Is the feedback on the training as described in 4.3.1 (page 34) and 4.3.2 (page 34), part of the continued suitability assessment of the device?

4.3.4 Is the feedback provided on the training as described in 4.3.1 (page 34) and 4.3.2 (page 34), effective?

Are the involved persons informed about the opportunity to provide feedback? Is any feedback provided? Is the information collected through the feedback used? Are actions taken based on the feedback provided? Are the contributors to the feedback encouraged and informed about the outcome of their inputs?

4.4 Compliance monitoring of training (ORA.GEN.200 §(a)(6))

4.4.1 Are all aspects of the training provided on the device (as indicated in relevant parts of 4.1 (page 26) and 4.2 (page 31)), under compliance monitoring (compliance with regulation requirements as well as internal criteria, standards and procedures)?







4.4.2 As part of the compliance monitoring indicated in 4.4.1 (page 34), is the actual lesson content delivered during the training sessions on the device adequately monitored?

4.4.3 As part of the compliance monitoring indicated in 4.4.1 (page 34), is the actual timing of the training sessions conducted on the device adequately monitored?

4.4.4 Are there documented methods, procedures and standards adopted to determine acceptable deviations of the lessons delivered as determined in 4.4.2 (page 35) and 4.4.3 (page 35) from nominal session content and timing?

Note: Deviations from planned session content and timing can result from various unforeseen events (such as device downtime for unpredicted technical reasons), instructor performance (such as incapacity to reset the device in an unusual situation, lack of skill …) or student performance (unexpected need for more training/practice …).

Deviations from nominal session content and timing shall be monitored to ensure that the training objectives are achieved to the relevant standards adopted and that the training remains compliant with applicable regulation.

4.4.5 Is the compliance monitoring of the training provided on the device as indicated from 4.4.1 (page 34) to 4.4.4 (page 35), effective?








4.5 Safety management of training (ORA.GEN.200 §(a)(3))

4.5.1 Are the potential aviation safety hazards entailed by all aspects of the training provided on the device (as indicated in relevant parts under 4.1 (page 26) and 4.2 (page 31)), continually identified, evaluated and associated risks appropriately managed?


Use of above list:

Any “partial YES” is to be considered as a “NO”: To indicate what part of the criteria is fulfilled and what part is not the Doc Ref column (rightmost column) may provide the list of references / evidence with a “Yes” sub-list to indicate the fulfilled part and a “No” sub-list for the part not achieved.

The Doc Ref column shall indicate the training organisations’ documentation reference or the reference of the evidence/record related to the criteria on the leftmost column on same line






11 Handling the misuse use of an FSTD

11.1 Warning

THE MISUSE OF AN FSTD WHILE PROVIDING PILOT TRAINING SHALL BE CONSIDERED AS AN AVIATION SAFETY CONCERN.

11.2 Applicability

FCLOA will systematically apply the methodology indicated in 11.4 (page 38) to deal with any misuse of an FSTD when providing training under the scope of an EASA Part-ORA approval.

The misuse of an FSTD is defined as any condition where one or more of the following happened or cannot be excluded:

11.2.1 Use of an FSTD with no valid Part-ORA or EASA accepted qualification

11.2.2 Use of an FSTD outside the approved terms1 of its qualification

11.2.3 Use of an FSTD outside the scope of the ATO’s approval (typically using an FSTD with no user approval for the course provided)

11.2.4 Use of an FSTD outside the organisation’s approved procedures, instructions, conditions or methods indicated in or resulting from the organisation’s manuals

11.2.5 Use of an FSTD by insufficiently qualified personnel either because of their licences, qualifications, ratings, approvals, authorisations or any other criteria as determined by the applicable regulation or the organisation’s approved procedures, instructions, conditions or methods indicated in or resulting from the organisation’s manuals.

11.2.6 Use of an FSTD by personnel (even qualified) with insufficient ability to handle and/or operate the simulator because of any lack of specific training, preparation or readiness affecting their performance.

11.2.7 Use of an FSTD by personnel (even qualified and well trained to operate the simulator) with insufficient ability to conduct a training session, to provide simulated flight training or to achieve training objectives because of any lack of specific training, preparation, readiness or physical / mental reduced fitness affecting its performance.

11.3 Objective

The methodology indicated in 11.4 (page 38) is meant to address any aviation safety risk that may result from the misuse of an FSTD as described in 11.2 (page 37).

The assessment of the situation resulting from the misuse of an FSTD shall, as a minimum, consider the following possible implications regarding the associated aviation safety risks:

11.3.1 Negative learning (Refers to unwanted consequences of training methods, conditions or environment that develop and/or consolidate knowledge, behaviours, skills, abilities, values or preferences opposite to the training objectives.)

11.3.2 Insufficient training (Refers to partial or total failure to achieve training objectives when no negative learning has resulted)

11.3.3 Inappropriate training (Or improper training: refers to training provided under uncertainty resulting from undetermined, unclear or confusing training objectives where the effects of negative learning or insufficient training cannot be excluded)

1 The approved terms of qualification include all Part-ORA requirements that the device fulfils as stated in its qualification certificate






11.4 Methodology for risk mitigation

Any training provided under FSTD misuse and any subsequent training based or linked to the training provided under these conditions is deemed to be invalid until proven otherwise and formally confirmed by:

11.4.1 Demonstrating that no apparent or latent condition reducing aviation safety has resulted from the training under these conditions and the subsequent training based or linked to it;

11.4.2 In case any condition reducing aviation safety cannot be excluded, evaluating and taking actions to mitigate the associated risks;

11.4.3 Demonstrating that all actions taken to eliminate or mitigate the risks are effective;

11.4.4 Obtaining formal confirmation, once all above steps have been successfully concluded, that the overall outcome is accepted by the Agency






12 Formal approval of the use of an FSTD

The formal approval of the use of an FSTD is part of the ATO approval certificate (Form 143).

Each FSTD approved for a given course will be entered on the ATO approval certificate as part of the ATO’s privileges in the list of approved courses. This list is attached to the certificate starting from page 2 of Form 143

Training course Used FSTD(s), including letter code (1)

(1) as indicated on the qualification certificate






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