Must the time for all training at the behest of the operator be entered in the schedule of the crew members and recorded?
Answer
To any training at the behest of the operator regardless of the method (e-learning1) or self-study or otherwise) that an aircrew member is assigned to by the operator the following applies:
- It is a duty and the time spent on training task constitutes a duty period.
- It cannot be considered a rest period or a day free of all duty or an annual leave period (ORO.FTL.105).
E-learning1 or self-study may be included as a single duty period in the CM roster with start and end times or assigned as a number of hours to be used over certain time (week(s) or month(s)), by the crew member to study the training material, in parts or at once, at the crew member discretion.
When assigning a number of hours, the operator should notify the crew member concerned in advance, specifying the allocated hours and time period for completion of the training. The training methods described above should comply with all daily or cumulative duty limits and rest requirements of Commission Regulation (EU) No 965/2012 and of Council Directive 2000/79/EC of 27 November 2000 (WTD), considering the period allocated for completion2. The policy and description on how these training methods are managed should be clearly documented in the operations manual (OM). As part of their shared responsibilities with regard to crew fatigue, the crew members should manage their time and tasks considering other assigned duties and rest requirements as per ORO.FTL.115 (b).
As part of their shared responsibilities with regard to crew fatigue, the operator should ensure that the training duties are assigned in a way that enables crew members to fulfil their flight duties to a satisfactory level of safety under all circumstances. The operator should in particular provide rest periods of sufficient time prior to the next flight duty/duties and an adequate number of hours and period of time to enable a successful fulfilment.
1 ICAO Circular 356 definition: E-Learning – is the delivery of a learning, training or education programme by electronic means.
2 ORO.FTL.205; ORO.FTL.210; ORO.FTL.235; CS FTL.1.235; WTD Annex Clause 8 & 9.