Recommendation A16-09

Assesssment of the response to Aviation Safety Recommendation A16-09

Instrument flight currency requirements

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Background

On 31 May 2013, at approximately 0011 Eastern Daylight Time, the Sikorsky S-76A helicopter (registration C-GIMY, serial number 760055), operated as Lifeflight 8, departed at night from Runway 06 at the Moosonee Airport, Ontario, on a visual flight rules flight to the Attawapiskat Airport, Ontario, with 2 pilots and 2 paramedics on board. As the helicopter climbed through 300 feet above the ground toward its planned cruising altitude of 1000 feet above sea level, the pilot flying commenced a left-hand turn toward the Attawapiskat Airport, approximately 119 nautical miles to the northwest of the Moosonee Airport. Twenty-three seconds later, the helicopter impacted trees and then struck the ground in an area of dense bush and swampy terrain. The aircraft was destroyed by impact forces and the ensuing post-crash fire. The helicopter's satellite tracking system reported a takeoff message and then went inactive. The search-and-rescue satellite system did not detect a signal from the emergency locator transmitter (ELT). At approximately 0543, a search-and-rescue aircraft located the crash site approximately 1 nautical mile northeast of Runway 06, and deployed search-and-rescue technicians. However, there were no survivors.

The Board concluded its investigation and released report A13H0001 on 15 June 2016.

TSB Recommendation A16-09 (June 2016)

As seen in this occurrence, 2 pilots lacking instrument flying proficiency departed for a night visual flight rules (VFR) flight in conditions that required the use of instrument flying skills because the cultural and/or ambient lighting needed to maintain visual reference to the surface was lacking. Although both pilots had met the instrument flight currency requirements in the Canadian Aviation Regulations (CARs), once the aircraft passed the end of the runway lights necessitating transition to flight by reference to instruments, an excessive bank angle and rate of descent developed, which were not recognized by the crew at an altitude that permitted recovery.

Under the current regulations, instrument-rated pilots may go up to 12 months following their instrument ride before they are required to conduct any actual or simulated instrument flying. After 12 months, the regulations require pilots to have completed 6 hours of instrument flying, including 6 instrument approaches during the previous 6 months to maintain their instrument qualification (the 6/6/6 requirement). Many of these instrument-rated pilots do not routinely conduct instrument flight training or operations to maintain a reasonable degree of instrument flying proficiency. As a result, pilots who have had little to no instrument flying experience for 12 months may legally be called upon to carry out, and may accept, a challenging instrument flight without recent practice in the skills essential to the safe conduct of an instrument flight.

As identified in Transport Canada's (TC) Instrument Procedures manual, instrument flight is a skill that requires "careful training, constant practice and a methodical approach." As for any other skill, repetition is essential to prevent erosion of a pilot's instrument flying skill. As explained above, the instrument currency requirements allow for an extended period (i.e., up to 12 months) to lapse before a pilot is required to complete any type of instrument flight. In contrast, there are a number of semi-annual currency requirements in the CARs, such as takeoffs and landings, which a pilot must complete in order to remain current for operational duty. A similar semi-annual requirement also exists for instrument flight; however, it only applies after the first 12 months following the issuing or renewal of an instrument rating. TC does not impose the 6/6/6  instrument currency requirement during the first 12 months. In the United States, the Federal Aviation Regulations (FARs) paragraph 61.57(c) specifies semi-annual instrument currency requirements that must be met before a pilot can act as pilot-in-command under instrument flight rules or in weather conditions less than the minimums prescribed for visual flight rules only.

The instrument recency requirements in the CARs do not provide adequate assurance that an instrument-rated pilot will possess an acceptable level of proficiency to ensure the safe conduct of a flight in challenging instrument meteorological conditions. As a result, pilots may conduct flights in challenging instrument meteorological or dark night conditions without the level of instrument flying proficiency required to maintain safe flight operations.

Therefore, the Board recommended that

The Department of Transport establish instrument currency requirements that ensure instrument flying proficiency is maintained by instrument-rated pilots, who may operate in conditions requiring instrument proficiency.
TSB Recommendation A16-09

Transport Canada's response to Recommendation A16-09 (September 2016)

Transport Canada agrees with this recommendation.

TC plans to address this recommendation via a regulatory amendment and will engage the aviation community on the subject in summer 2017.

Transport Canada update (December 2016)

Transport Canada will be conducting an internal assessment on this issue, with input from many different areas within [the] Civil Aviation [Directorate]. A recommendation will be brought to senior management for approval and the aviation community will then be consulted through a Preliminary Issue & Consultation Assessment (PICA) form in the fall of 2017. Comments received through the PICA will be considered while drafting the Notice of Proposed Amendments (NPA).

Board assessment of Transport Canada's response to Recommendation A16-09 (December 2016)

The Board is pleased that TC plans to address this recommendation via a regulatory amendment. The Board is optimistic that the amendment will significantly reduce or eliminate the safety deficiency associated with this recommendation. However, until the regulatory amendment is published, it is impossible to determine whether or not the safety deficiency will be adequately addressed.

Therefore, the response to Recommendation A16-09 is assessed as Satisfactory Intent.

Next TSB action

The TSB will monitor the progress of TC's actions to mitigate the risks associated with the safety deficiency identified in Recommendation A16-09.

This deficiency file is Active.