Checklist conundrum offers no easy answers
One lesson to be learned from the July 31, 2008, crash of a Hawker 800 in Owatonna, Minn., according to the NTSB, is that trying to initiate a go-around late in the landing roll might not be a good idea. But one factor that the NTSB highlighted in its conclusions about that accident points out a more significant issue, “lack of checklist discipline throughout the descent and approach phases of the flight.”
In highlighting checklist discipline, the NTSB identified a subtle issue that has frustrated operators and training providers for many years: the FAA’s requirement that pilots use approved checklists during training sessions. The checklists that are approved are those that the training centers such as FlightSafety International, SimuFlite and SimCom have had approved under their 14CFR Part 142 training certificates. The FAA allows operators to modify checklists to fit their particular operation, but operators cannot use their own modified checklists during training. The result is that pilots training at third-party training companies must use approved checklists rather than their own, which could create a safety issue. “We’re normalizing deviance,” said David Bjellos, corporate pilot and president of Daedalus Aviation Services, during a presentation at the NBAA/Flight Safety Foundation Corporate Aviation Safety Seminar in April.
Checklist Consistency in Training
The NTSB is concerned about this deviance, too, and one of its recommendations to the FAA after the Owatonna accident specifically addressed the issue: “Require principal operations inspectors of Part 135 and 91 Subpart K [fractional] operators to ensure that pilots use the same checklists in operations that they used during training for normal, abnormal and emergency conditions.”
It would be easier if everyone involved–airlines, charter operators, Part 91 operators and so on–would simply use the original equipment manufacturers’ (OEMs’) checklist and leave it at that. But as Bjellos pointed out, OEM checklists aren’t always ideal for a particular operation. Airlines modify checklists to fit their way of operating. And some checklist items might not apply and need to be removed, while others need to be added due to aircraft modifications or changes in procedures.
Part 91 operators can create their own checklists without formal FAA approval, while commercial operators and fractional operators must have their checklists approved or accepted by the FAA. But because training companies’ hands are tied by Part 142, there arises the problem of one checklist being used during training and another during normal flight operations.
To train at a Part 142 training center with a non-OEM checklist, a customer would have to obtain a letter of no objection (LONO) from the FAA. In a response to a query from Bjellos, the FAA noted, “When using a curriculum in a Part 142 training center, non-certified [Part 91] operators must follow and complete FAA procedures required to replace the center’s approved checklist with the operator’s checklist. Operators must also ensure the center’s personnel are trained on differences.”
Neither FlightSafety nor SimuFlite responded to AIN’s questions about the issue of LONOs and customized checklists. A SimCom spokesperson told AIN that it hasn’t “had an opportunity to work with a customer through this process,” which seems to indicate that operators and pilots are simply going along with the use of OEM checklists during training. “We would gladly provide assistance and guidance to our customers through this regulatory process,” the spokesperson stated.
With regard to the use of custom checklists during training, SimCom added, “Checklist modifications that enhance the overall safety of an operator/flight department are a positive for our industry. However, since aircraft certification is based on the manufacturer’s flight data, limitations and procedures, approval for checklist variations needs to come from either the people who build it or the people who approve it.” SimCom does have Part 135 customers that use modified and FAA-approved checklists during training.
While it is hard to quantify the benefits of training with the checklists used during flight operations, there is one example of checklist integration that has been part of a dramatic improvement in safety. When the FAA issued a special FAR for mandatory training in the Mitsubishi MU-2 in February 2008, it also required that all pilots use the Mitsubishi factory checklist or an FAA-accepted checklist. Since the SFAR was issued (some training under the SFAR requirements began before the rule became final in February 2009), the number of MU-2 accidents has dropped significantly.
In a response to the NTSB recommendation for consistent checklist use during training and normal operations, the FAA sent this, dated June 10, 2011: “From J. Randolph Babbitt, Administrator: The FAA agrees that the same checklists used in operations should also be used during training. We will review existing policy guidance on outsourced training provided to inspectors and training center program managers to determine if additional guidance or a change in policy is necessary. I will keep the Board informed of the FAA’s progress on this safety recommendation, and I will provide an update by July 2012.”