ORO.FC.A.245 Alternative training and qualification programme

COMPONENTS AND IMPLEMENTATION

(a)Alternative training and qualification programme (ATQP) components The ATQP should comprise the following:

(1)Documentation that details the scope and requirements of the programme, including the following:

(i)The programme should demonstrate that the operator is able to improve the training and qualification standards of flight crew to a level that exceeds the standards prescribed in ORO.FC and Subpart E of Annex V (SPA.LVO).

(ii)The operator’s training needs and established operational and training objectives.

(iii)A description of the process for designing and gaining approval for the operator’s flight crew qualification programmes. This should include quantified operational and training objectives identified by the operator’s internal monitoring programmes. External sources may also be used.

(iv)A description of how the programme will:

(A)enhance safety;

(B)improve training and qualification standards of flight crew;

(C)establish attainable training objectives;

(D)integrate CRM in all aspects of training and ensure that each flight crew member undergoes specific modular CRM training. All major topics of CRM training should be covered by distributing modular training sessions as evenly as possible over each 3-year period;

(E)develop a support and feedback process to form a self-correcting training system;

(F)institute a system of progressive evaluations of all training to enable consistent and uniform monitoring of the training undertaken by flight crew;

(G)enable the operator to be able to respond to new aeroplane technologies and changes in the operational environment;

(H)foster the use of innovative training methods and technology for flight crew instruction and the evaluation of training systems; and

(I)make efficient use of training resources, specifically to match the use of training media to the training needs.

(2)A task analysis to determine:

(i)knowledge;

(ii)required skills;

(iii)associated skill-based training; and

(iv)validated behavioural markers, where appropriate. For each aeroplane type/class to be included within the ATQP the operator should establish a systematic review that determines and defines the various tasks to be undertaken by the flight crew when operating that type/class. Data from other types/classes may also be used. The analysis should determine and describe the knowledge and skills required to complete the various tasks specific to the aeroplane type/class and/or type of operation. In addition, the analysis should identify the appropriate behavioural markers that should be exhibited. The task analysis should be suitably validated in accordance with (b)(3). The task analysis, in conjunction with the data gathering programme(s), permits the operator to establish a programme of targeted training together with the associated training objectives.

(3)Curricula. The curriculum structure and content should be determined by task analysis, and should include proficiency objectives, including when and how these objectives should be met.

(i)The training programme should have the following structure:

(A)Curriculum, specifying the following elements:

(a)Entry requirements: a list of topics and content, describing what training level will be required before start or continuation of training.

(b)Topics: a description of what will be trained during the lesson.

(c)Targets/Objectives

(1)Specific target or set of targets that have to be reached and fulfilled before the training course can be continued.

(2)Each specified target should have an associated objective that is identifiable both by the flight crew and the trainers.

(3)Each qualification event that is required by the programme should specify the training that is required to be undertaken and the required standard to be achieved.

(B)Daily lesson plan

(a)Each lesson/course/training or qualification event should have the same basic structure. The topics related to the lesson should be listed and the lesson targets should be unambiguous.

(b)Each lesson/course or training event whether classroom, CBT or simulator should specify the required topics with the relevant targets to be achieved.

(4)A specific training programme for:

(i)each aeroplane type/class within the ATQP;

(ii)instructors (class rating instructor rating/synthetic flight instructor authorisation/type rating instructor rating — CRI/SFI/TRI), and other personnel undertaking flight crew instruction; and

(iii)examiners (class rating examiner/synthetic flight examiner/type rating examiner — CRE/SFE/TRE). This should include a method for the standardisation of instructors and examiners. Personnel who perform training and checking of flight crew in an operator’s ATQP should receive the following additional training on:

(A)ATQP principles and goals;

(B)knowledge/skills/behavioural markers as learnt from task analysis;

(C)line-oriented evaluation (LOE)/LOFT scenarios to include triggers/behavioural markers/event sets/observable behaviour;

(D)qualification standards;

(E)harmonisation of assessment standards;

(F)behavioural markers and the systemic assessment of CRM;

(G)event sets and the corresponding desired knowledge/skills and behavioural markers of the flight crew;

(H)the processes that the operator has implemented to validate the training and qualification standards and the instructors part in the ATQP quality control; and

(I)line-oriented quality evaluation (LOQE).

(5)A feedback loop for the purpose of curriculum validation and refinement, and to ascertain that the programme meets its proficiency objectives.

(i)The feedback should be used as a tool to validate that the curricula are implemented as specified by the ATQP; this enables substantiation of the curriculum, and that proficiency and training objectives have been met. The feedback loop should include data from operations flight data monitoring, the advanced flight data monitoring (FDM) programme and LOE/LOQE programmes. In addition, the evaluation process should describe whether the overall targets/objectives of training are being achieved and should prescribe any corrective action that needs to be undertaken. [applicable until 31 December 2027 — ED Decision 2022/014/R]

(i)The feedback should be used as a tool to validate that the curricula are implemented as specified by the ATQP; this enables substantiation of the curriculum, and that proficiency and training objectives have been met. The feedback loop should include data from the flight data monitoring (FDM) programme and LOE/LOQE programmes. In addition, the evaluation process should describe whether the overall targets/objectives of training are being achieved and should prescribe any corrective action that needs to be undertaken. [applicable from 1 January 2028 — ED Decision 2025/020/R]

(ii)The programme’s established quality control mechanisms should at least review the following:

(A)procedures for approval of recurrent training;

(B)ATQP instructor training approvals;

(C)approval of event set(s) for LOE/LOFT;

(D)procedures for conducting LOE and LOQE.

(6)A method for the assessment of flight crew during conversion and recurrent training and checking. The assessment process should include event-based assessment as part of the LOE. The assessment method should comply with ORO.FC.230.

(i)The qualification and checking programmes should include at least the following elements:

(A)a specified structure;

(B)elements to be tested/examined;

(C)targets and/or standards to be attained;

(D)the specified technical and procedural knowledge and skills, and behavioural markers to be exhibited.

(ii)An LOE event should comprise tasks and sub-tasks performed by the crew under a specified set of conditions. Each event has one or more specific training targets/objectives, which require the performance of a specific manoeuvre, the application of procedures, or the opportunity to practise cognitive, communication or other complex skills. For each event the proficiency that is required to be achieved should be established. Each event should include a range of circumstances under which the crews’ performance is to be measured and evaluated. The conditions pertaining to each event should also be established and they may include the prevailing meteorological conditions (ceiling, visibility, wind, turbulence, etc.), the operational environment (navigation aid inoperable, etc.), and the operational contingencies (non-normal operation, etc.).

(iii)The markers specified under the operator’s ATQP should form one of the core elements in determining the required qualification standard. A typical set of markers is shown in the table below:

(iv)The topics/targets integrated into the curriculum should be measurable and progression on any training/course is only allowed if the targets are fulfilled.

(v)The assessment and the subsequent grading of the performance of flight crew members should include the following steps:

(A)Observe performance (behaviours) during the simulator session.

(B)Record details of effective and ineffective performance (behaviours) observed during the simulator session (‘record’ in this context refers to instructors taking notes).

(C)Classify observations against the set of behavioural markers and allocate the behavioural markers to each type of knowledge or skill or task, using amongst others the facilitation technique. If the operator has developed a set of competencies, it may allocate the behavioural markers to each competency.

(D)Assess and evaluate (grade): assess the performance by determining the root cause(s). Low performance would normally indicate the area of performance to be remediated in subsequent phases or modules or training sessions. Evaluate (grade) the performance by determining a grade using the methodology defined by the operator.

(7)A data monitoring/analysis programme consisting of the following:

(i)A flight data monitoring (FDM) programme, as described in AMC1 ORO.AOC.130. Data collection should reach a minimum of 60 % of all relevant flights conducted by the operator before ATQP approval is granted. This proportion may be increased as determined by the competent authority.

(ii)An advanced FDM when an extension to the ATQP is requested: an advanced FDM programme is determined by the level of integration with other safety initiatives implemented by the operator, such as the operator’s safety management system. The programme should include both systematic evaluations of data from an FDM programme and flight crew training events for the relevant crews. Data collection should reach a minimum of 80 % of all relevant flights and training conducted by the operator. This proportion may be varied as determined by the competent authority. The purpose of an FDM or advanced FDM programme for ATQP is to enable the operator to:

(A)provide data to support the programme’s implementation and justify any changes to the ATQP;

(B)establish operational and training objectives based upon an analysis of the operational environment; and

(C)monitor the effectiveness of flight crew training and qualification.

(iii)Data gathering: the data analysis should be made available to the person responsible for ATQP within the organisation. The data gathered should:

(A)include all fleets that are planned to be operated under the ATQP;

(B)include all crews trained and qualified under the ATQP;

(C)be established during the implementation phase of ATQP; and

(D)continue throughout the life of the ATQP.

(iv)Data handling: the operator should establish a procedure to ensure the confidentiality of individual flight crew members, as described by AMC1 ORO.AOC.130.

(v)The operator that has a flight data monitoring programme prior to the proposed introduction of ATQP may use relevant data from other fleets not part of the proposed ATQP. [applicable until 31 December 2027 — ED Decision 2022/014/R]

(7)An FDM programme, as specified in AMC1 ORO.AOC.130.

(i)The FDM programme should be used to:

(A)provide data to support the ATQP’s implementation and justify any changes to the ATQP;

(B)establish operational and training objectives based upon an analysis of the operational environment; and

(C)monitor the effectiveness of flight crew training and qualification.

(ii)The FDM programme should provide the person responsible for ATQP with the information they need. Subject to the procedure to prevent disclosure of crew identity (refer to point (k) of AMC1 ORO.AOC.130), the information should be sufficiently detailed to allow targeted changes to the training programme to be defined. The data gathered by the FDM programme for this purpose should:

(A)include all fleets that are planned to be operated under the ATQP;

(B)include all crews trained and qualified under the ATQP;

(C)be established during the implementation phase of ATQP; and

(D)continue throughout the life of the ATQP.

(iii)The operator should establish a procedure to ensure the confidentiality of FDM-based information transmitted to the person responsible for ATQP, which should be consistent with the procedure to prevent disclosure of crew identity specified in AMC1 ORO.AOC.130.

(iv)The operator that has a flight data monitoring programme prior to the proposed introduction of ATQP may use relevant data from other fleets not part of the proposed ATQP. [applicable from 1 January 2028 — ED Decision 2025/020/R]

(b)Implementation. The operator should develop an evaluation and implementation process, including the following stages:

(1)A safety case that demonstrates equivalency of:

(i)the revised training and qualification standards compared to the standards of ORO.FC and/or Subpart E of Annex V (SPA.LVO) prior to the introduction of ATQP; and

(ii)any new training methods implemented as part of ATQP. The safety case should encompass each phase of implementation of the programme and be applicable over the lifetime of the programme that is to be overseen. The safety case should: demonstrate the required level of safety; ensure the required safety is maintained throughout the lifetime of the programme; and minimise risk during all phases of the programme’s implementation and operation. The elements of a safety case include: planning: integrated and planned with the operation (ATQP) that is to be justified; criteria; safety-related documentation, including a safety checklist; programme of implementation to include controls and validity checks; and oversight, including review and audits. Criteria for the establishment of a safety case. The safety case should: be able to demonstrate that the required or equivalent level of safety is maintained throughout all phases of the programme; be valid to the application and the proposed operation; be adequately safe and ensure the required regulatory safety standards or approved equivalent safety standards are achieved; be applicable over the entire lifetime of the programme; demonstrate completeness and credibility of the programme; be fully documented; ensure integrity of the operation and the maintenance of the operations and training infrastructure; ensure robustness to system change; address the impact of technological advance, obsolescence and change; and address the impact of regulatory change.

(2)A task analysis, as required by (a)(2), to establish the operator’s programme of targeted training and the associated training objectives.

(3)A period of operation whilst data is collected and analysed to validate the safety case and task analysis. During this period the operator should continue to operate in accordance with ORO.FC and/or Subpart E of Annex V (SPA.LVO), as applicable. The length of this period should be determined by the competent authority.

TERMINOLOGY

(a)‘Line-oriented evaluation (LOE)’ is an evaluation methodology used in the ATQP to evaluate trainee performance, and to validate trainee proficiency. LOEs consist of flight simulator scenarios that are developed by the operator in accordance with a methodology approved as part of the ATQP. The LOE should be realistic and include appropriate weather scenarios and, in addition, should fall within an acceptable range of difficulty. The LOE should include the use of validated event sets to provide the basis for event-based assessment.

(b)‘Line-oriented quality evaluation (LOQE)’ is one of the tools used to help evaluate the overall performance of an operation. LOQEs consist of line flights that are observed by appropriately qualified operator personnel to provide feedback to validate the ATQP. The LOQE should be designed to look at those elements of the operation that are unable to be monitored by FDM or Advanced FDM programmes.

(c)‘Skill-based training’ requires the identification of specific knowledge and skills. The required knowledge and skills are identified within an ATQP as part of a task analysis and are used to provide targeted training.

(d)‘Event-based assessment’ is the assessment of flight crew to provide assurance that the required knowledge and skills have been acquired. This is achieved within an LOE. Feedback to the flight crew is an integral part of event-based assessment.

(e)Safety case means a documented body of evidence that provides a demonstrable and valid justification that the ATQP is adequately safe for the given type of operation.

EVIDENCE-BASED RECURRENT TRAINING AND CHECKING OF FLIGHT CREW CONDUCTED IN FLIGHT SIMULATION TRAINING DEVICES (FSTDs) It is possible to implement EBT in accordance with ICAO Doc 9995 in the framework of an approved alternative training and qualification programme (ATQP). GM1 ORO.FC.230(a);(b);(f) may be used to guide the operator towards EBT according to ORO.FC.A.245 of Commission Regulation (EU) No 965/2012. An operator holding approval for ATQP and wishing to implement EBT may use the guidance material in GM1 ORO.FC.230(a);(b);(f) for the conduct of the Licence Proficiency Check, or where the Licence Proficiency Check and Operator Proficiency Check are combined. For this purpose, the evaluation phase is equivalent to the line-oriented evaluation (LOE) described in ORO.FC.A.245(d).

BEHAVIOURAL MARKERS AND OBSERVABLE BEHAVIOURS — ATQP & EBT

(b)Behavioural markers in ATQP are observable behaviours that contribute to superior or substandard performance within a flight (including pre-flight and post-flight duties).

(c)A good behavioural marker:

(1)describes a specific, observable behaviour, not an attitude or personality trait, with clear definition (enactment of skills or knowledge is shown in behaviour);

(2)has demonstrated a causal relationship to performance outcome, without necessarily being present in all situations, and with its appropriateness possibly depending on context;

(3)uses simple phraseology; and

(4)describes a clear concept.

(d)The characteristics of good behavioural marker systems are:

(1)validity: in relation to performance outcome;

(2)reliability: instructor or examiner concordance (inter-rater reliability), internal consistency;

(3)sensitivity: in relation to levels of performance;

(4)transparency: the pilots receiving the training or checking understand the performance criteria against which they are being rated; availability of reliability and validity data;

(5)usability: easy to train, simple framework, easy to understand, domain-appropriate language, sensitive to rater (i.e. examiner, instructor) workload, easy to observe;

(6)ability to provide a focus for training goals and needs; and

(7)minimal overlap between components.

(e)For EBT mixed implementation, the operator may refer to the Annex I definitions of ‘behaviour’ and ‘observable behaviour’ which include the concept of behavioural marker in ATQP. In other words, the EBT OBs may be used as behavioural markers under ATQP.

OPERATOR EXPERIENCE The appropriate experience should be at least 2 years’ continuous operation.

AMC1 ORO.FC.A.245(d);(e)(2) Alternative training and qualification programme

COMBINATION OF CHECKS

(a)The LOE may be undertaken with other ATQP training. The operator should ensure that training and checking are clearly distinguished and described in the operations manual.

(b)The line check may be combined with a line-oriented quality evaluation (LOQE).

(c)Complementary CRM assessment The CRM assessment should take place in a line-oriented flight scenario (LOFT, LOE or lineoriented section of the OPC) of an FSTD session. This assessment complements the CRM assessment taking place during the line check /LOQE, but it is not part of the line check / LOQE.

LINE CHECK IN MIXED FLEET OPERATION UNDER ATQP The extension of validity for the line check is intended for single fleet operation. For mixed fleet operation, the operator needs to observe the provisions in the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012. Usually the operational suitability data refers to one line check per year in alternate aircraft types.

ATQP PROGRAMME — FSTD The FSTD qualification level should be adequate to complete proficiency checks; therefore, the ATQP programme should be conducted in a full-flight simulator (FFS) level C or D.