Airworthiness Notices - B058, Edition 5 - 13 January 2005

Guidelines for the Introduction of Human Factors Training Requirements into the Canadian Aviation Regulations (CARS)

(This Airworthiness Notice supersedes AN B058 Edition 4 dated 27 November 2002)

Purpose

This Airworthiness Notice provides the aviation industry with information regarding the introduction of human factors training requirements into the Canadian Aviation Regulations (CARs). This edition provides confirmation of the publication of the amendment to the CARs and provides guidance regarding conformance with the regulatory requirement.

In February 2000, the CARAC Technical Committee accepted a Notice of Proposed Amendment to the CARs requiring all employees, with technical responsibilities, to have human factors training.

The motivation for this regulatory amendment is twofold:

1. The International Civil Aviation Organization (ICAO) amended Annex 6 of the ICAO Convention on Civil Aviation. The introduction of this regulation renders Canada compliant with the ICAO human factors training requirements;
    
2. There is a growing recognition that a major cause of aviation maintenance related incidents and accidents is due to human error. Given the predicted increase in air traffic in the next fifteen years, this regulation is a proactive measure designed to build awareness of the factors that contribute to these events.

Standards 573.06, 706.12 and 406.45 of the CARs.

The amendment to the CARs was published September 1, 2002 and came into effect thirty days from the date of publication. In recognition of the voluntary compliance to date, shown by the industry in meeting this requirement, organizations will have a six-month implementation period, effective from the date of publication in the CARs, to submit the amendment to their maintenance control manual (MCM) or their maintenance policy manual (MPM) in accordance with the instructions shown below.

Human factors training is a mandatory element of the maintenance training requirements as stipulated in Standards 573.06, 726.12 and 426.45 of the CARs. The regulatory requirement applies to approved maintenance organization certificate (AMOC) holders, air operator certificate (AOC) holders and flight training unit operating certificate (FTUOC) holders. All technical employees, that is anyone performing functions that are mandated by the regulations, are required to have this training. This would include personnel working directly on-aircraft, as well as personnel with off-aircraft responsibilities such as technical records.

Certificate holders impacted by this regulatory requirement should clearly detail in their maintenance policy manual (MPM) or maintenance control manual (MCM) how they intend to meet this requirement. This should include a detailed description of the course content, the method of delivery and the established time frame for training personnel affected by this requirement.

The MPM or MCM should also reflect how the company will implement any update or additional training requirements and how the company will monitor the effectiveness and currency of the training program.

In regards to the human factors training requirements for servicing personnel and personnel performing elementary work tasks, human factors training should be limited to the range of tasks the individual is required to perform. Where an operator contracts these functions to an unapproved organization, the operator has a duty to ensure the contractor is competent. That could mean checking to see if they have a suitable training program. If there is no satisfactory training program, the operator's personnel will have to exercise the necessary level of supervision. For example, a pilot may supervise the refueling of an aircraft.

Transport Canada has recently published a document titled "Human Performance Factors For Elementary Work and Servicing" to assist organization in meeting the initial Human Factors training requirements for personnel tasked with elementary work and servicing duties. This document is not intended to replace, but rather to supplement existing training such as crew resource management. The CAR 706.10(a) training requirements can be satisfied by reading this publication, which is currently available from the following Transport Canada website: http://www.tc.gc.ca/CivilAviation/maintenance/AARPE/HumanPerformance/Introduction.htm

The intent of the regulation is to provide a framework specifying the core elements necessary to meet Transport Canada’s human factors training requirements. As such, there is no specific duration of time applied to the requirement; nor is there a prescribed teaching method applied to human factors training. The extent of the required elements, as detailed in Appendix A, would indicate, however, that a reasonable period of time for initial training would be two days. This is in keeping with the industry norm for this type of training. The only exception to this would be servicing personnel and personnel performing elementary maintenance tasks on aircraft. The extent of the training required is described in the Policy section of this document.

All human factors training courses must encompass the elements detailed in the amendment to the CARs (Appendix A). Transport Canada has established a list of content objectives for human factors training; how one meets the content requirements listed in the standard and deals with the subject matter is the responsibility of the individual company. We do not advocate any one theoretical concept or subject; our objective is that the individual gains an understanding of the impact of human factors on performance degradation and measures that can be taken to optimize human performance regardless of the circumstances. Transport Canada has produced publication TP 13459¹, which can be used as a framework to build upon.

The human factors initial training requirement is to be conducted in a classroom setting. Alternate teaching methods, such as ‘on-line’ or computer based training, are not an acceptable means of regulatory compliance.

The argument against alternative methods for initial training is based on a simple premise. That is, face-to-face interaction adds immeasurably to the understanding and ability to apply the topics required by the standard. The classroom approach provides a forum to discuss and share experiences and best practices. These are benefits that cannot be achieved in an alternative learning environment.

Additional and update training requirements may be completed through alternate training methods. The intention is that this training will be required on the same basis as all other update or additional training. Additional training should be directed to the areas known to be weak, which may or may not include human factors. Where the quality system indicates a need for additional training in human factors, alternative methods of teaching may be used. Update training should provide a refresher of the initial training course and should cover any changes to the course that have occurred in the period between the initial and update phase of training. This is of course different to initial human factors training, where we require human interaction in a classroom environment.

In regards to individuals that have already taken human factors training courses, the following criteria apply when assessing currency:

1. The training course must meet the standards established in the amendment to the CARs (see Appendix A);
    
2. Where an individual has received human factors training, it must be clearly demonstrated that the organization has supported the program with the appropriate update and additional training requirements as per Standards 573.06, 726.12 and 426.45 of the CARs.

For Minster of Transport Canada

D.B. Sherritt

Director,
Aircraft Maintenance and Manufacturing

Appendix A - Amendment to the CARs

¹ TP13459 E/F: Human Performance in Aviation Maintenance Workshop can be ordered on-line at http://shop.tc.gc.ca or by telephone at 1-800-305-2059.