13. A proposal to improve aviation safety

Manufacturers have to make assumptions about line pilot training, skills, and the qualifications that are supposed to defend those skills when making design decisions, writing their documentation, and performing their safety analyses. But today, there’s no end-to-end continuity from those assumptions to end-user line pilot training. Training is usually provided by the carrier (either in-house or outsourced) and approved by the carrier’s local regulator, and the manufacturer has no way of knowing whether that training meets all of the design and safety analysis assumptions.

Between 2013 and 2022, I count 14 hull losses just in the Boeing fleet in which unexpected pilot actions were either causal or contributing. In only four cases was anything wrong with the airplane, and most of those fourteen accidents involved pilots with more than 10,000 hours. During that time, there were no hull losses due to systems or structures failures that the pilots couldn’t mitigate. And Boeing is not alone - there have been similar accidents in the fleets of other manufacturers. I believe that the discontinuity from manufacturer assumptions to line pilot training is the biggest threat to aviation safety because it underlies the vast majority of accidents.

The US Aircraft Certification, Safety, and Accountability Act (ACSAA) requires the FAA to validate the pilot assumptions used in design and certification, and of course the FAA flows this requirement to the manufacturers. There are only two ways to do this: either gather enough information from the worldwide fleet to detect emerging training and skill gaps before they cause accidents, or make sure those gaps don’t emerge in the first place. The second is far more practical and effective.

To do this, I propose that manufacturers provide operators (airlines) and their local regulators lists of the critical training assumptions or requirements that support the design safety analyses. Regulators around the world must then commit to enforce those requirements. Thus, when an operator requests approval for a training program that omits training that the manufacturer assumes or deems to be critical, the regulator can consult the list and deny that request. In other words, the manufacturers should tell the industry what their expectations are, and the industry should make sure those expectations are met.