Crewmember Training Reduction during unrest

Date:         08 Dec 96 04:12:40 
From:         "Peter Mchugh" <PMCHUGH@mail.hq.faa.gov>
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Since the list dispensed with the distracters attached to the thread
on the 5/25/94 HBAT 94-10 which deals with training time reductions
related to various periods of corporate (airline) uncertainty
including "labor unrest, bankruptcy or other newsworthy periods of
stress" it is perhaps time to expose another perspective on the
content/intent of the HBAT.

1.  Provisions for reducing the numbers of hours of required training
are contained in FAR 121.405 which does not stipulate the minimum
number of hours to which a program can be reduced.  The HBAT therefore
is not the basis for making reductions, but rather the vehicle by
which such reductions are limited (no less than 32 hours) during
periods of increased public scrutiny of any particular carrier.

2.  The HBAT provides a number of "protections"....including

   a)  Restriction in the number of hours of training given at a
single period...to include requiring "breaks" (lunch, etc) for
students.

   b)  Requires review of proposed reductions by FAA Headquarters to
assure that local pressures won't unnecessarily influence inspectors
into making unwise reductions.

3.  The HBAT also provides for increases in training times
beyond the minimums where indicated for safety reasons.


There doesn't seem to be any language in the HBAT that supports the
view that "fluff" exists in approved training programs, or that the
HBAT is a mechanism to facilitate replacement of flight crews during
"periods of unrest".  Rather, the HBAT seems focused and effective in
assuring that safety levels are maintained.  'Course, you might ask,
"what else would you expect from an FAA lurker?"

Cheers