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CRM


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6 hours ago, J-Rock said:

Here is a copy paste of the new standard.

"An air operator shall provide Crew Resource Management Training (CRM) to flight crew, flight attendants, dispatchers/flight followers, ground crew and maintenance personnel, as applicable, in accordance with paragraphs (a) and (b) of this subsection."

Notice it never mentions "crew member", it only mentions "flight crew". Very big difference(See CARS Part I Subpart 1). AC 700-042 also mentions that the intent is for persons employed by the operator, so that rules out fire fighters falling under the "ground crew" requirement as well.

Just my opinion...

Ya, you might be right. Nice one. I like how they opened with the definition of CRM and it clearly states 'crew members', however, we only need to be concerned with what comes after the word "shall" which is flight crew, like you pointed out.

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Another aspect of this issue is regarding the 18 month timeline. 

In section 5.1 of AC 700-042 there is the statement that "Operators (702, 703 and 704) have 18 months from the date of publication of the official Standard to implement CRM training."

The standard is not yet in force.  This will happen effective 2019/01/31. As per this information:

https://www.tc.gc.ca/eng/civilaviation/regserv/cars/list-amendments-standards-not-yet-force.html  (last modified: 2018-04-03)

So how can the publication of an Advisory Circular that speaks to a standard that is not official until Jan 31, 2019 be anything but for information purposes only?  When the Advisory Circular was published in 2017, the standard was not official (and still isn't) and at that time there was no information as to when it would be.

Another perspective from earlier this year:

https://www.trainingport.net/pending-canadian-contemporary-crm-requirements-commercial-ops/

I put forward that the logical answer is that the 18 month compliance timeline for 702, 703 & 704 should start January 31, 2019 when the standard actually comes into force.  But I'm not putting any money on whether that idea is shared by the TC powers-that-be.

 

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18 months from the date of publication. Not 18 months from when standard comes into force. The January 31, 2019 is 18 months after the standard was published to the CARS  (although hidden in the "standards not yet in force" section that no one had ever heard of before, but yes it was published there almost 18 months ago). 

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From: Thibault, Stéphanie On Behalf Of Sincennes, Robert
Sent: Wednesday, November 21, 2018 3:10 PM
To: DL OTT OMC <DLOTTOMC@tc.gc.ca>; DL OTT AAR Input <DLOTTAARInput@tc.gc.ca>; 'exec@nata-yzf.ca' <exec@nata-yzf.ca>; 'Fred Jones' <fred.jones@h-a-c.ca>; jmckenna@atac.ca;info@airlinecouncil.capatlafleur@gmail.com
Subject: CREW RESOURCE MANAGEMENT (CRM) --- GESTION DES RESSOURCES D'ÉQUIPAGE (CRM)

 

Le texte en français suit l’anglais

The French text follows the English

*************************************

 

It has come to our attention that some operators have not yet submitted their CRM training program to TCCA for validation or completed the required training in order to meet the January 31, 2019 deadline.

 

  • It is imperative that operators are informed that once the CRM training program has been submitted to TCCA they can immediately begin training and must be compliant by January 31, 2019.

 

  • If a deficiency is found with a submitted CRM training program during the validation process, TCCA will inform the operator of the deficiency but this shall not invalidate training already completed or prevent the training from being completed.

 

  • It is paramount that the CRM training be delivered; any shortcoming can be addressed at a later date.

 

Please be advised that the process listed above is only applicable for the implementation of an operators CRM training in order to meet the January 31st, 2019 deadline.

 

It would be appreciated if you could share this message with all your members companies. The key message to operators is to submit their CRM training program and start training their personnel.

 

Thank you,

 

Robert Sincennes, P.Eng.

Director, Standards Branch

Directeur, Normes

Tel: 613-991-2738   cell: 613-859-2796   facsimile / télécopieur : 613-952-3298

Internet: robert.sincennes@tc.gc.ca
Transport Canada | Transports Canada
330 Sparks St
Ottawa (Ontario) K1A 0N5

Government of Canada | Gouvernement du Canada

 

 

-------------------------------------------------------------------------------------------------------------------

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In light of the current 702 & 703 TC regulations looming, thought you might be interested in a viable solution for your operations  to be in compliance by the January 31, 2019 deadline.  I realize this is going to be a daunting task for many, many operators and feel this is an option you might want to investigate.
 
QualaTech Aero Consulting Ltd., has been diligently working on a template where 90 to 95% of the material has been gathered and addressed to fit the TC format for submission, COM amendment etc., the 5 to 10% inputs on your behalf will help you to take ownership of the document and be able to interface with TC on a knowledge basis. Keith at QualaTech produces quality material.
 
Contact Keith: QualaTech Aero Consulting Ltd. – 250-213-5025 – k.green@qualatech.ca – for availability and pricing.
 
Hope this is of help with your company compliance status.
 
Good Luck and all the best for 2019
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While his post does appear to be advertising, it's on topic. So I personally dont get my panties in a knot.

Perhaps pilots/engineers should refrain from posting their hours/ratings and skills, because that too is shilling their "business"

So relating my position to this CRM training, I rarely if ever now have to do a maintenance flight, is there a requirement that I must  comply should one of these rare moments arrive that I need to? 

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3 hours ago, GrayHorizons said:

While his post does appear to be advertising, it's on topic. So I personally dont get my panties in a knot.

Perhaps pilots/engineers should refrain from posting their hours/ratings and skills, because that too is shilling their "business"

So relating my position to this CRM training, I rarely if ever now have to do a maintenance flight, is there a requirement that I must  comply should one of these rare moments arrive that I need to? 

And where have you seen anybody doing that outside of the employment section of this forum?

 

Yes, you have to do the CRM. Even asking the questions means you haven't read any of it.

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