Century CRM, LLC

CRM for Part 135 Operators Re: Docket No. FAA-2009-0023; Notice No. 09-02 Crew Resource Management Training for Crewmembers in Part 135 Operations As a fully FAA-certified provider of both single-pilot and crew resource management training seminars, Century CRM, LLC supports adoption of the NPRM with regards to CRM training for Part 135 operations. We would like to offer the following comments and suggested changes to the proposed rule: ? While we applaud the direction of this rulemaking, we feel the scope is inadequate. As noted in a recent NTSB study, up to 80% of accidents are currently attributed to human error (CRM deficiencies). Traditional training budgets focus 100% of their resources on addressing only the other 20% of the accident causes (technical/mechanical). CRM and human factors training are a crucial area of flight safety. We cannot afford to inadequately address them by minimizing the requirements. ? As both FAA and industry representatives to the first international CRM symposium hosted by Embry-Riddle Aeronautical University all agreed: CRM must be taught in the classroom and evaluated in the simulator/aircraft. While we feel that a LOFT scenario is valuable in evaluating CRM performance, it is an inadequate method for CRM instruction. ? The NPRM guidelines of 4 hours for initial and 2 hours for recurrent training are wholly inadequate. Effectively addressing all of the topics laid out in AC 120-51E requires more time. Our FAA-certified courses, which incorporate not only all of the AC 120-51E areas, but also cover the United Kingdom?s CAA CAP-737 and Transport Canada?s CRM guidelines, require 14 hours of instruction. Covering the AC 120-51E topics in sufficient depth and scope will require a full day at a minimum. ? The rating criteria used by Part 135 auditing agencies currently favor operators who provide CRM training for their crews. This can have a positive impact on insurance risk assessment, making the training even more cost-effective and partially offsetting implementation costs. The NTSB has put mandatory CRM training on its Top 10 list for the past several years. Commercial operators in 183 countries are currently required to have it. Given the recent high visibility that the U.S. aviation industry is contending with, we feel that the FAA cannot afford to delay implementation of this proven safety training.