Guidelines for FSTD User Approval - EASA · Name Validation Date ... Scenario Foreign Pilot Training Organisation Approval Process ALL ... AOC: Air Operator Certificate AReg:

European Aviation Safety Agency User Guide

Guidelines for FSTD User Approval Doc # UG.FCTOA.00005-000 Approval Date dd/mm/2014

© European Aviation Safety Agency. All rights reserved.

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Guidelines for FSTD User Approval

UG.FCTOA.00005-000

Draft: 0.2

Name Validation Date

Prepared by: Chaouki CHABBI 28/05/2014

Verified by:

Reviewed by:

Approved by:

Authorised by:





DOCUMENT CONTROL SHEET

Process Area Organisation approval

Main Process Pilot Training Organisation Approval

Scenario Foreign Pilot Training Organisation Approval

Process ALL

Main Process Owner Chaouki CHABBI

Reference documents

a) Contextual documents

Regulation (EC) 216/2008 - Regulation of European Parliament and of Council of 20 Feb. 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)1592/2002 and Directive 2004/36/EC;

Commission Regulation (EU) 1178/2011 - Commission Regulation 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, as amended.

b) Internal documents

EASA Form 143 - EASA Approved Training Organisation Certificate

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





Abbreviations/Definitions ACAS: Airborne Collision Avoidance System

AMC: Acceptable Means of Compliance

AOC: Air Operator Certificate

AReg: 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, as amended.

ATC: Air Traffic Control

ATO: Approved Training Organisation

CAT I: Category 1 Approach

CAT II: Category 2 Approach

CAT III: Category 3 Approach

EASA: European Aviation Safety Agency

EC: European Commission

EGPWS: Enhanced Ground Proximity Warning System

ETOPS: Extended-range Twin-engine Operational Performance Standard

EU: European Union

ft: feet

DH: Decision Height

FANS: Future Air Navigation System

FCL: Flight Crew Licencing

FCLOA: Flight Crew Licencing Organisation Approvals

FCTOA: Flight Crew Training Organisations Approval

FSTD: Flight Simulation Training Device

GM: Guidance Material

GPS: Global Positioning System

GPWS: Ground Proximity Warning System

HUD: Head-up Display

HUGS: Head-up Guidance System

IFR: Instrument Flight Rules

LVTO: Low Visibility Take-Off

OPS: Operational Standards

Part ORA: Annex VII of AReg

PTO: Pilot Training Organisations

RVR: Runway Visual Range

RWY: Runway

SID: Standard Instrument Departure

STAR: Standard Instrument Arrival

WX: Weather

UG: User Guides - Guidance for the implementation of regulations

Log of issues

Issue Issue date Change description

000 DD/MM/2014 • Deleted reference to JAR

• Terminology adjustments

• Review of Abbreviation Definitions





0. Introduction





Table of Contents 0.1.

0. Introduction ......................................................................................................................... 4

0.1. Table of Contents ............................................................................................................... 5

0.2. Scope ............................................................................................................................... 6

0.3. Important considerations .................................................................................................... 6

0.4. Context ............................................................................................................................. 7

0.5. Objective .......................................................................................................................... 7

1. FSTD operators compared to ATOs (FSTD users) .................................................................. 8

2. Interpretation of the “Guidance information” on an FSTD certificate ................................. 10

3. Demonstration of compliance ............................................................................................. 12

3.1. For the initial user approval ............................................................................................... 13

3.2. During the oversight phase ................................................................................................ 13

4. Criteria for the use of an FSTD for a given training course .................................................. 14

5. Handling the misuse use of an FSTD ................................................................................... 43

5.1. Warning .......................................................................................................................... 44

5.2. Applicability ..................................................................................................................... 44

5.3. Objective ........................................................................................................................ 44

5.4. Methodology for risk mitigation .......................................................................................... 45

6. Formal approval of the use of an FSTD ............................................................................... 46





Scope 0.2.

This user guide for the FSTD user approval is complementary to the requirements of Implementing Rule –

Aircrew Regulation (EU) 1178/2011 “as amended” and does not supersede or replace the information

therein documented.

Important considerations 0.3.

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 AMC1 ORA.GEN.120(a): � 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 (a) (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 GM1 ORA.FSTD.100 (u)).

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.

1 See paragraph 0 for more details





Context 0.4.

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

training objectives Part-ORA and Part-ORA/ATO

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

Accidents or incidents during training Design flaw or failure of

the simulator

Incorrect use of the simulator

during a training session

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.

Objective 0.5.

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.





1. 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.





2. 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.





3. Demonstration of compliance





The list of criteria given in paragraph 4 page 14, should be used in different ways depending on the type

of investigation and the technical aspect to be considered (i.e. documentation or implementation)

3.1. 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.

3.2. 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.





4. 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 24)

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 15)?

1.2.3 Are the sampled publications indicated in 1.2.2 (page 16), satisfactory?

1.2.4 Are the sampled publications indicated in 1.2.2 (page 16), 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

17), 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 17), satisfactory?

1.2.9 Can the integrity of document samples be checked as indicated in 1.2.7 (page 17),

satisfactorily?

1.2.10 Can the applicability of document samples be checked as indicated in 1.2.7 (page

17), 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 17) 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 16), 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 19), 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 15), 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 19), 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 17), 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 20), 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 15), 1.2 (page 16) and 1.3 (page 17), continually identified, evaluated and

associated risks appropriately managed?






1.6.2 Are actions taken to mitigate the risks indicated in 1.6.1 (page 20) 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 21)

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 21)

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 22) and 2.3.2 (page 22), effective?




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 21)

and 2.2 (page 22), 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 23), effective?






2.4.3 As a result of the compliance monitoring indicated in 2.4.1 (page 23), 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 21), 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 21) and 2.2 (page 22), continually

identified, evaluated and associated risks appropriately managed?

2.5.2 Are actions to mitigate the risks indicated in 2.5.1 (page 24), 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 24), provide sufficient

information to enable the instructor to operate the device throughout each session

of the intended training course?







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?


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 24), part of the organisation’s

documentation and related procedures as detailed in the relevant criteria under 1.2

(page 16)?

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 37) and 4.2.7

(page 38))?

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 27), 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 39) to 4.2.15 (page 39))?

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

28)?

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

and device serviceability?







obligations as regards the reporting about device serviceability as indicated in 3.4.5

(page 28)?

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. …)?


obligations as regards the recording of activities as indicated in 3.4.7 (page 29)?

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 29), 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 29) and 3.5.2 (page 30), 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 29), 3.5.2 (page 30) and

3.5.3 (page 30), included in the operational planning as indicated in 3.2 (page 25)?

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 29), 3.5.2 (page 30) and 3.5.3 (page

30), 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 24) to 3.5 (page 29)) 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 30)?






3.6.3 Is the feedback on operations provided as described in 3.6.1 (page 30) and 3.6.2

(page 30), 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 30) and 3.6.2







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 24) to 3.5 (page 29)), 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 31), 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 24) to 3.5 (page 29)),

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 32), 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 33)?






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 movement 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?

Navigation 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 35) 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 36)?

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 36)?

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 37) 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 37) been conducted?

4.2.5 Are the sampled training sessions validation reports and related data as indicated in

4.2.4 (page 37), satisfactory?






4.2.6 Does each session validation as indicated in 4.2.4 (page 37) 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 37) 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

29).

4.2.10 Do the methods and procedures to familiarise the instructors indicated in 4.2.9

(page 38), 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 38) and 4.2.10

(page 38), 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 39), 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 39) 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 32) and 4.2 (page 37))?

4.3.2 Are the involved trainee enabled to provide feedback on the training as indicated in

4.3.1 (page 40)?

4.3.3 Is the feedback on the training as described in 4.3.1 (page 40) and 4.3.2 (page

40), 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 40) and 4.3.2


Are the involved persons informed about the opportunity to provide feedback?





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 32) and 4.2 (page 37)), 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 40), 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 40), 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 41) and

4.4.3 (page 41) 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 40) to 4.4.4 (page 41), 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 32) and 4.2

(page 37)), 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





5. Handling the misuse use of an FSTD





5.1. Warning

THE MISUSE OF AN FSTD WHILE PROVIDING PILOT TRAINING SHALL BE CONSIDERED AS AN

AVIATION SAFETY CONCERN.

5.2. Applicability

FCLOA will systematically apply the methodology indicated in 5.4 (page 45) 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:

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

5.2.2. Use of an FSTD outside the approved terms1 of its qualification

5.2.3. Use of an FSTD outside the scope of the ATO’s approval (typically using an FSTD with

no user approval for the course provided)

5.2.4. Use of an FSTD outside the organisation’s approved procedures, instructions,

conditions or methods indicated in or resulting from the organisation’s manuals

5.2.5. 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.

5.2.6. 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.

5.2.7. 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.

5.3. Objective

The methodology indicated in 5.4 (page 45) is meant to address any aviation safety risk that may result

from the misuse of an FSTD as described in 5.2 (page 44).

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:

5.3.1. 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.)

5.3.2. Insufficient training

(Refers to partial or total failure to achieve training objectives when no negative

learning has resulted)

5.3.3. 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





5.4. 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:

5.4.1. 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;

5.4.2. In case any condition reducing aviation safety cannot be excluded, evaluating and

taking actions to mitigate the associated risks;

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

5.4.4. Obtaining formal confirmation, once all above steps have been successfully

concluded, that the overall outcome is accepted by the Agency





6. 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

Documents

Guidelines for FSTD User Approval - EASA · Name Validation Date ... Scenario Foreign Pilot Training Organisation Approval Process ALL ... AOC: Air Operator Certificate AReg: