Unintended Consequences of Training
The law of unintended consequences is when a planned strategy fails. Sometimes an unintended consequence is winning the jackpot and mostly celebrated as flukes, but when a tragedy strikes, it is bad luck or murphy’s law.
Training is to perform in harmony
The Safety Management System (SMS) regulations requires that there is a process in place for ensuring that personnel are trained and competent to perform their duties, that there are training requirements for the person managing the safety management system and for personnel assigned duties under the safety management system, and a method to determine the adequacy of training required. These training requirements are required for all personnel, including the Accountable Executive (AE).
Conventional wisdom is that the only two requirements, roles, responsibilities, or duties for the AE is to support the SMS with human and financial resources. An SMS is ineffective and without an excuse if an AE remains untrained to comprehend their responsibility for operations or activities authorized under the certificate and accountable on behalf of the certificate holder for meeting the requirements of the regulations.
Training of the AE becomes a vital task for the SMS to be effective. An effective system is a system that is successful in producing a desired or intended result or outcome, and when the AE remains untrained, the intended result is not produced. In larger organizations, the AE, who also in most cases is the President and CEO, may receive limited training in lieu of relying on a third-party confidential adviser to the AE, in the same manner as the organization rely on accountants, lawyers or janitorial services for effectiveness. With no minimum personnel requirement to operate with an SMS, the AE of a small organization may be the same person who is managing the SMS. However, in larger organization, and when relying on a confidential adviser to the AE, the responsibility and accountability of the accountable executive are not affected by the appointment of a person to manage the safety management system.
No person within an SMS enterprise is required to hold an “SMS license” to qualify for their positions under the SMS. A pilot needs to hold a pilot’s license, a mechanic needs to hold a mechanic’s license, with the only exception that an airport manager (APM) is not required to hold an APM license. Licenses are governed by standards that a person must meet to qualify for the license held, and to maintain the license. Requirement for SMS training is determined by the SMS manager, who establishes training requirements for the person managing the safety management system and for personnel assigned duties under the safety management system. The accountable executive approves by their responsibility for meeting the requirements of the regulations their own third-party training supplier, or internal training personnel.
There are several purposes for training, some of which are to conform to regulatory compliance, it is to ensure indoctrination training, it is to learn new skills, it is refresher training, it is specialty training, or targeted training. Training takes form of theoretical training in a classroom setting, and as practical on-the-job (OJT) training, and concludes with a written, or practical competency test. A test also serves several purposes. One purpose is simply to pass the test. This is often accomplished by answering correctly one of multiple answers. A multiple-choice test is mere a test-taking skill, since there is no oversight of what process the candidate applied to answer questions correctly. Generally speaking, there are five methods, or processes to answer a multiple-choice test correctly. One method is by comprehending the subject, while another method is trained capability to select the correct answer by taking practice-tests with same or similar scenarios prior to the final test. Other methods are to answer correctly by elimination, answer correctly by keywords or answer correctly by multiple test-tries. Unless the subject comprehension method is applied, it is impossible to determine the adequacy of the training required as it relates to the candidate’s retention of SMS technical knowledge and subject matter. A practical test to verify quality of the OJT is not subject to the candidate’s test taking method but is subject to the examiner’s opinions. Both theoretical and practical tests have flaws, and both are unreliable as the only means to assess a candidate’s skills and the instructor’s ability to convey information to instill learning.
|Unintended consequences occurs when human factors become unacceptable|
Training of personnel is a specialty skill, it is a learned skill and it is an ongoing development skill. When it comes to using an untrained instructor to train other personnel, the instructor may resist to be moved out of their comfort zone and unable to train the new person to the expected comprehension level. peaking in front of a group of people is also one of the biggest fear a person has. An exceptional skilled and dependable person may not always be the best choice as the instructor to train new personnel, since their tasks in the past had been on their own development and improvement, and not on improving someone else. For a person with exceptional skills and knowledge, it may also become frustrating to accept that others still have a distance to go before they have reached the same level of ambition to achieve.
Another potential issue with assigning training tasks to a person who does not hold a position to train as a regular trainer is that there is often not enough time to do so adequately. In preparation for training an instructor needs to do research, design a training schedule, and develop target specific training to conform to an SMS enterprise’s safety policy and training objectives. There are SMS enterprises, both large and small, that believe training is busy-time, or waste of time since their personnel was already trained. In addition, refresher training that is not a part of a regulatory requirement may discourage and not allowed during regular working hours. When an SMS enterprise, or a person in a leadership position does not seek or take advantage of all training opportunities available to their personnel, an employee’s skills become stale.
Training in form of trivia may be just as effective than mandated, scheduled or required training. Trivia training does not include a competency test but is a self-evaluation of skills. Learning is a process to improve a just culture and does not necessarily need to be of technical knowledge or competency skill. Several years ago, when it was allowed to smoke in the airplane, a young flight instructor did the instructor flight test with an inspector who would smoke during the flight test.
Later that day, the new instructor learned that the smoking was a distraction tool to learn how an instructor would respond to non-standard issues, or a special-cause variation. In addition, the final determination if the new instructor was fit, was for the flight test examiner to place the airplane in an inverted spin to learn how the candidate would react to a situation that a student could easily put an airplane into. These two tests were not a part of the flight test curriculum but was a part of the whole picture to assess if a new instructor was ready or not to take on students, and as an oversight system to assess reactions to a special cause variation.
Unexpected consequences of training occurs when training is viewed as having reached the final qualification standard, it is when oversight becomes incidental to an activity, rather than viewed as a tool to accept imperfection in human behavior.