Conflict of interest - instructor/examiner

The Aircrew Regulation requires that conflict of interest be avoided, meaning that the trainer/instructor who provided any topic of the initial training course should not act as examiner. What about small operators / cabin crew training organisations employing only one ground instructor, for example to cover dangerous goods or aero-medical aspects and first aid? Would it be acceptable if, for example, the written examination (test) on a particular topic would be corrected by the Training Manager according to enclosed key test? Would EASA recommend any other acceptable solution?

Reference: Regulation (EU) No 1178/2011 on Aircrew

In the Annex to ED Decision 2012/006/R, AMC1 ARA.CC.200(b)(2) clarifies that in such cases, the operator/training organisation shall establish appropriate procedures to avoid situations that could lead to conflict of interest, e.g. where an instructor/trainer has to check/evaluate the proficiency of the trainee/student he/she has taught/trained.

The qualifications of instructors/trainers, as well as of examiners, are not defined at EU level, and remain to be defined by each Member State. At the same time, the particular context of the concerned operator/training organisations is also known by the competent authority.

Therefore, only the competent authorities may assess, on a case by case basis, when approving the training and checking programmes of the operators/training organisations established in their territory, whether the procedures established can ensure that the objective of the rule is met, i.e. to minimise as far as possible the risk of conflict of interest, and possible undue side effects on the evaluation of the trainee/student.

“AMC1 ARA.CC.200(b)(2) Approval of organisations to provide cabin crew training or to issue cabin crew attestations 

For any element being examined for the issue of a cabin crew attestation as required in Part CC, the person who delivered the associated training or instruction should not also conduct the examination. However, if the organisation has appropriate procedures in place to avoid conflict of interest regarding the conduct of the examination and/or the results, this restriction need not apply.”


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