< Browse more articles

Transport Canada Offers Some Limited Help on an Ambiguous CRM AC

You may recall that in the Spring of this year, HAC held a teleconference of operators to receive their feedback on the confusing new Crew Resource Management Advisory Circular 700-042. The deadline to implement CRM training is September 30, 2019, and a number of our members raised concerns centred primarily on the extent of their obligation to provide training. That is, to which occupants of the aircraft does it apply? HAC made a written submission summarizing those concerns. Since then, Transport Canada has responded, twice, by email. Neither response completely contemplated the unique circumstance of our industry segment, where there is constant communication between our passengers and the flight crew members. 

HAC believes that the ambiguity in the AC will only lend itself to different interpretations by different inspectors and regions – will ultimately promote disrespect for the AC’s objectives. In some ways, HAC believes that the terms of the AC need to be tortured to apply them in a heli-specific context. Transport Canada has refused to amend the AC, but here’s a summary of what we do know, based on the terms of the AC, and their responses:

  1. The definition of “Crew Member” set out in the AC “Means a person assigned to duty in an aircraft during flight time.” It is the responsibility of the air operator to determine who should be designated as a crew member. Transport Canada claims that “all personnel, crew members who have direct contact with the flight crew during CAR 702 operations require CRM training”.  Operators will need to draw their own conclusions whether any given individual is assigned to duty during flight time, or not. Transport Canada seems to believe that anyone assigned to duty (whether or not the duty is assigned by a crew member) is a “crew member”. If, for example, a passenger is an observer in an aerial survey operation, and they have direct contact with a crew member – even if they are not assigned duties by the crew member – would be required to have CRM training.

  2. Transport Canada has also indicated that “…the operator may use a tailored approach, matching the size and scope of the operations, to deliver the contemporary CRM training specified in the Part VII Standards. For example, CRM training for forest fire personnel may be delivered during annual firefighter training. Following that CRM training specific to an air operator or specific flight, may be given during the preflight briefing to highlight any particular issue(s)”.  We know that CIFFC, for example, is discussing with HAC the potential to deliver a standardized CRM course to firefighters across the country.

  3. In response to HAC’s concern about delivering CRM training in accordance with the AC to contract pilots, Transport Canada responded as follows “The contract of employment between an employer and employee does not detract from the operator’s responsibility to ascertain the training needs of that employee and, if required, train them in accordance with their Company Operations Manual.  It is up to the operator to determine how they will schedule their personnel and tailor their CRM training matching the size and scope of the operations in order to meet the applicable CRM training Standard.”

  4. “Although it is highly recommended that some aspects of CRM are included in a passenger briefing, passengers do not require CRM training.”

  5. “Crew members are not required to carry proof of meeting the training requirements of an operator. Training information would be obtained as part of routine surveillance activities within company facilities.”

  6. Given the duplication that exists between the requirements for the Pilot Decision Making (PDM) course required for low-vis operations (set out in CASS 722.17 and CAR 723.28), and the new CRM training requirements, HAC requested that the requirement for PDM training should be withdrawn. Transport Canada has no plans to remove the requirement for PDM training, for low-vis operations.