Methods of Delivering Ground Training in Part VII and Subpart 604

April 16th 2020

In response to the challenges associated with the novel coronavirus (COVID-19), particularly with respect to personal distancing, isolation measures and travel restrictions, Canadian air operators have been consulting with Transport Canada Civil Aviation (TCCA) to explore options to deliver ground training that go beyond the traditional classroom. This communique provides general guidance on this topic to alleviate any misunderstandings that may exist regarding acceptable methods of delivering training.  

The Training Standard contained in the Commercial Air Service Standard (CASS) was written in an era when training was predominately delivered in a traditional classroom. However, advances in digital technology now support distance learning through the delivery of information and training using virtual and computer-based means. Distance learning offers substantial efficiencies and, in many cases, delivers an equal or better learning experience. Many Canadian air operators are leveraging distance learning to a varying degree to deliver ground training.

To this end, a revision to the CASS to address distance learning is admittedly overdue and will be addressed during the recently announced initiative to modernize training and checking. In the interim, the guidance below is offered to help structure and promote the standardization of the delivery of training through distance learning. It is understood that a wider margin of flexibility on the delivery of distance learning may be required while we collectively manage the disruptions associated with COVID-19.

Guiding principles for the delivery of training through distance learning are as follows:

  • For most subject areas in training, the CASS does not impose a requirement to deliver ground / theory training in a physical classroom or in-person.
  • Distance learning is an acceptable alternative to traditional classroom training, when appropriate, if the learning experience and effectiveness is equal or better.
  • Common distance learning methods typically include e-learning, home study, self-guided training, virtual classroom, distributed training, computer-based training (CBT), or web-based training (WBT). 
  • Air operators that incorporate distance learning in their training program must be able to demonstrate to TCCA that the method used is structured, monitored and delivers effective training, as determined by a performance-based analysis. This is aligned with the CASS requirement to acquire TCCA approval for a company training program, which includes consideration of proposed training aids and training facilities.  
  • The suitability and effectiveness of distance learning must be measured against performance metrics such as assessing the average ground training hours that students allocate to subjects, average pass–fail test rates, median scores, student feedback and average pass–fail rates for flight checks and other practical evaluations.
  • As a minimum, distance learning must offer the student: reasonable access to an instructor when clarification or assistance is required, confirmation of performance, correct answers for incorrect responses, and the timely monitoring of results that triggers instructor follow-up as necessary.  

The above information is not applicable to the delivery of ‘practical’ ground training such as the practical elements of Emergency Procedures training that requires in-person participation and the physical handling of devices or equipment. It is acknowledged that ongoing challenges associated with COVID-19 are, in some cases, limiting or preventing the conduct of practical training. This situation will be closely monitored and may eventually warrant consideration of an alternative means of compliance for some aspects of practical training.   

Lastly, industry is seeking clarification on acceptable methods of delivering Crew Resource Management (CRM) training, particularly with respect to establishing a classroom setting. Section 6.6 in Advisory Circular (AC) 700-042 speaks to the various methods of delivering CRM training, including options for distance learning. A classroom setting can be achieved through physical presence, or through virtual or audio means; that said, operators must ensure learning objectives are met regardless of the delivery method.

An air operator should leverage the various methods to deliver ground training in a manner that is relevant to the size and scope of their operation and compatible with operational and logistical constraints. The end result could resemble a program that incorporates the completion of some modules through self-directed learning, while other modules could be completed in a physical, virtual or audio classroom setting. The responsibility rests with the air operator to demonstrate to TCCA that their approach to ground training is effective and meets the standard in the CASS.  

In summary, modern technology offers many avenues to deliver effective training. The unprecedented disruptions and constraints we are currently encountering will necessitate the delivery of training in creative ways, while ensuring there is no reduction in the quality and effectiveness of training.

Sincerely,

“Original signed by”

Robert Sincennes
Director, Standards Branch
Civil Aviation