RAeS 2018

“EASA OSD impact”

Impact on training, ATOs and CBTA

Captain Philip Adrian

Chief Executive Officer

MPS

Philip.Adrian@MPS.aero

MPS Mission and vision

It is MPS’ mission to be a solution partner to support unique and

innovative flight training solutions using state of the art Fixed Base

Simulators

▪ A/C fleet expansion and renewal will drive a

significant need for pilots

▪ This pilot shortage will need to be solved in a

cost effective manner without sacrificing safety

▪ Pilot shortage leads to instructor shortage

▪ The role of FBS will continue to increase with

broader adoption worldwide as an alternative to

FFS

MPS’ vision is to support this effort with

innovative FBS solutions that will assist the

expanding airline’s customer base in their

training and safety needs

Speaker Introduction

o Started as military pilot in the Royal Netherlands Air Force

o Civilian career

o Flight Instructor

o Airline Pilot (charter and scheduled services within the KLM group)

o Instructor/Examiner

o Head of Training and other airline management positions

o Boeing

o Captain and instructor on 737/777 and 787 (>13.000 hours)

o 737/737MAX Chief Technical Pilot

o Responsible for creation of OSD reports

o Chief Pilot Regulatory Affairs and Regulatory Strategy

o Regulatory

o ICAO LOCART (chair) and CBTATF (founding member)

o FAA ARCs (vice chair)

o EASA RMTs (current chair of EASA RMT.0581/0582 (UPRT) and RMT.0599 (EBT))

o Member of EASA ATPG

o Involved in creation of Certifications Specifications that form the basis for the OSD reports

o Since May 2018 Chief Executive Officer of MPS

• Because everybody does…..

➢ But nobody really understands…..

• Because everybody is affected…..

➢ But they all have a different interpretation…..

• Because it has been done by OEMs…..

➢ And they are not training professionals…..

• OSD background➢ General EU Operational Suitability Data requirements

➢ TC Holders applicability

• OSD Creation➢ CS-FCD

➢ T-Testing

• OSD Reports➢ Availability

➢ Use

• Use and interpretation at National level➢ AMC versus GM

➢ Competency Based Training under OSD

• Next steps and conclusions

EU rules and requirements

Basic Regulation 216-2008: It started with the politicians….

➢ First mention of Operational Suitability requirements on TC Holder (OSC)

➢ 6 constituents identified during the further exploration and implementation of the rule

• Flight Crew Data (FCD)

• Cabin Crew Data (CCD)

• MMEL

• Maintenance Certifying Staff (MCS)

• Simulator Data to support First of Model (SIMD)

• Other

This led to a part 21 (Certification) requirement with operational impact (EASA oversees

Certification, not operation)

o OSD was introduced by the EU Commission via BR 216/2008 to create a “level playing field” with regard to

operation and training of Flight Crew (FCD), Cabin Crew (CCD), Maintenance Certifying Staff (MCS), the MMEL

and data for “First Of Model” (FOM) simulator (SIMD).

o Compliance with OSD constituents is required for all in-production airplanes. All current in-service airplanes and

“ATC airplanes” (777 X, A330 NEO, etc.) have to comply with FCD, CCD and MMEL only due to specific

requirements excluding MCS and SIMD, for which older EU rules continue to be applicable. TC Holders who

apply for a new TC (Boeing NMA/FSA) will have to meet requirements for all 5 constituents.

For those who have a hard time sleeping:

Decision 2014/007/R of 31 January 2014, amending Acceptable Means of Compliance and Guidance Material to

Part 21 of Regulation (EU) No 748/2012

AMC & GM to Part 21 – Amendment 2 to issue 2 “Operational Suitability Data (OSD)”

Explanatory Note to Decision 2016/007/R

Acceptable means of compliance and guidance material to Part-21 for changes to OSD

o Certification Specifications – Flight Crew Data (CS-FCD) is the governing EASA Part-21 documents on how a TC

Holder creates OSD reports for the constituents. CS’s in general have 2 sections:

✓ Book 1 dealing with the specific Certification Specifications

✓ Book 2 identifying Guidance Material in support of Book 1

o CS-FCD is applicable to TC Holders and deals with requirements to be met for Operational Suitability

assessment prior to operations by a Community operator. Compliance with these CS’s are the basis for the

creation of the OSD reports that create a level playing field for operators and training organisations across the

EU.

o The OEM OSD reports serve multiple functions:

▪ They establish the Type Rating endorsement for Flight and Cabin Crew

▪ They identify credit for differences training and Previous Experience Courses (PEC) via ODR and MDR

▪ They set the minimum training requirements and identify training levels

o OSD reports for FCD and CCD use the “Box concept” to organize training requirements

✓ It identifies the Type Specific Training Areas of Special Emphasis (TASE) (Box 1)

✓ It establishes a validation course footprint (Box 2)

✓ It identifies training requirements for optional equipment and operations (Box 3 and 4)

▪ It creates credit for Common Takeoff and Landings between airplane types, as well as outlines for

Operations on more than one type or variant

The process to create the OSD FCD report is identified in the respective Certification Specifications, and for FCD,

uses T-testing for regulatory validation

oT-Testing

• Done to validate Type Specific requirements set by the manufacturer, including assessment of training level

for specific items (level A – E)

• Validates ODR and MDR requirements for T1-T3 (Differences), validates regulatory requirements for T5

(New Type Rating) through “Manufacturer’s Minimum Course”

➢T1-T3 creates related airplane Type Rating

➢T5 creates new Type Rating

• Includes standard equipment only (Base airplane to related airplane comparison, “generic ODR) and

regulatory minimum

• T-testing on airplane is the final step in the process

• T-testing also can identify Common Takeoff and Landing Clearance and Recurrent training requirements

o As the OSD reports are certified under Part 21, these are now OEM (TC Holder) documents rather than publicly

available documents via the EASA website as it used to be in “(J)OEB-times”.

o OSD-FCD report for all in-production airplane types are available for organizations that need access

➢ For non-OEM aircraft operators such as ATOs, this data will be provided after substantiation of the

need (if required)

o Not included under this requirement, and guided by different regulations, agreements and contracts:

▪ Operational documents such as AFM, FCOM, QRH, FAM etc.

▪ Simulator Data Packages

o The OSD report creates a guideline for operators, training organizations and regulators to make sure minimums

are met when operator training is approved. This is the Manufacturer’s Minimum Course (MMC)

The MMC is NOT a training course approval, but a way that the manufacturer proved compliance with

certification requirements

o As only EASA participates in the creation of the OSD report with the OEMs, there is a lack of understanding of

how the ensuing OSD report must be used. This is evident in several specific issues:

▪ Use of Manufacturing Minimum Course as the “Holy Grail”

➢ As the OSD report gets transferred from Part 21 to the Operational/Licensing side as an AMC, this

leads to a lack of understanding on application and use

➢ Freedom by local NAAs to accept alternative AMCs from ATOs and operators depending on

“Equivalent Level of Safety Findings” is not always understood

▪ Use of devices in accordance with the OSD report

➢ The OSD report is “a way” to comply, but not the only way

➢ The devices that were used for validation by the OEMs during OSD creation must not be leading for

course delivery

o The OSD report identifies devices used to VALIDATE the MMC. Use of these specific devices during training

delivery is not by itself a requirement

▪ This allows for a change in training delivery from the OSD validated course while not essentially deviating

from the OSD requirement. This is why from the OEM perspective, this has been put in Box 2, not in Box 1

▪ ATOs, operators and Regulators need to be further educated on this, as often the AMC that carries over

from the Certification Specification under Part 21 are considered as a “requirement” by NAAs

➢ This is an incorrect interpretation of the essence of the OSD report

➢ This unnecessarily complicates the training delivery, restricts innovation and adds unnecessary cost

The EASA RMT.0599 is creating a link between regulatory requirements, OSD report requirements and CBTA tasks

to use alternative training devices via ABLE (Aviation Blended Learning Environment) and CAPABLE

(Comprehensive Analysis Process for ABLE)

o The OSD report together with Appendix 9 forms the basis for Type Rating courses

▪ As the OSD report is responsible for setting training levels and validate that for “Training Areas of Special

Emphasis (TASE)” items, these can actually be used indirectly for CBTA

➢ It identifies the training via Operation Differences Requirements (ODR) and Master Difference

Requirements (MDR) tables, therefore WHAT needs to be trained, not HOW

➢ It identifies the training levels A-E, but should not require specific devices

▪ Operator specific items, optional equipment and specific operations is not incorporated in the MMC. These

items include, but are not limited to:

➢ ETOPS

➢ LOVIS

➢ RNP/PBN

Actually, the OSD report is an easy blueprint for CBTA, as all tasks are identified

either through Appendix 9 and the TASE, or through MDR and ODR tables.

These can be transferred to Competencies by training organizations

o However, Competency Based Training cannot be left just at the OEMs:

▪ Training organizations need to incorporate appropriate Task-to-Tool processes and identify Competencies

▪ Competency Based Training and Assessment needs broader implementation

➢ Any training, from licensing to recurrent to command upgrade training should use the Competencies

➢ Instructors are key in delivering CBT, and need to be trained and standardized

➢ Training needs to deliver at the end-user required level (the recently introduced EASA APS-MCC is an

example where end-users identified a gap between Licensing and Airline requirements)

▪ ICAO and IATA guidance on CBT must be incorporated in the training delivery

▪ Competencies at Type Rating do not differ from those at recurrent training, but can be assessed at different

levels

o NAAs and EASA need to standardize on OSD implementation at ATO and operator level

▪ Process for use of Alternative AMCs needs streamlining and cost reduction

▪ Further support from OEMs to revert the entire MMC into a CBT approach

➢ Malfunction clustering could become a standard part of the OSD report?

➢ Approach clustering could be next?

➢ EASA to reduce the restrictive writing of the OSD reports

➢ Training organizations and OEMs need to better interact on OSD

o Recalibration of Box-approach into appropriate level of requirements

▪ Box 1 and Box 3 remain AMC

▪ Box 2 and Box 4 become GM

o Don’t confuse OSD Certification requirements on a TC Holder with training delivery at an ATO or operator

o The OSD Minimum Manufacturer Course is sufficient to “steal an airplane” only

o OSD reports validate “A WAY” to deliver Type Rating Training, not the only way

o AMC level of Box 2 course validation needs to be reconsidered at EASA to allow ATOs and operators to innovate

➢ By moving this Box 2 validation to GM, this will be easily accomplished

o If Malfunction clustering is incorporated in the OSD report, it further supports CBTA

o More education is needed for NAAs on intentions and creation of the OSD reports

o OEMs and training organizations need to coordinate closer

All partners in this process need to further cooperate and educate each other to finally meet the intent of OSD

Captain Philip Adrian

Chief Executive Officer

MPS

Philip.Adrian@MPS.aero