Flying an airplane is not quite like riding a bike.  Pilot proficiency depends in large part on practice, and when skills become rusty, small mistakes can lead to catastrophic results.  The dramatic decrease in air travel during the COVID-19 pandemic has grounded pilots across the globe, and as highlighted recently by CNN and the Los Angeles Times, the transition back to the cockpit has been turbulent for some pilots. 

According to CNN, a review of aviation incident data tracked by a federal database revealed over two dozen recent reports of flight mistakes that were attributed, at least in part, to skills not being as sharp following pandemic-related leave.  Reported pilot mishaps included performing a landing without permission from air traffic controllers, lining up to land on the wrong runway, and misuse of aircraft systems and instruments.  In a separate incident in September at Kualanamu International Airport in Indonesia, a passenger jet temporarily swerved off the runway during landing.  The Indonesian transportation safety authority’s investigation report observed that the pilot had flown less than three hours in the 90 days prior to the flight, and called for guidance to address challenges in maintaining pilot proficiency and recent experience during the pandemic.

Federal regulatory standards for maintaining proficiency

Steve Dickson, Administrator of the Federal Aviation Administration (FAA), recently warned of pandemic-induced safety risks created by the global pandemic and proposed enhanced industry oversight as a possible measure to curb the risks.  The FAA sets minimum “currency” standards to manage the safety risks posed by diminished proficiency from inactivity.  Under current regulations, to be eligible to fly a passenger jet, a pilot must have carried out at least three takeoffs and three landings in a comparable aircraft or FAA-approved flight simulator in the past 90 days.  Additional standards apply to specific flying conditions – for pilots in command of passenger aircraft at night, the landings must have been to a full stop at night; pilots operating in poor visibility conditions are required to have performed and logged at least six instrument approaches (i.e., landing primarily by reference to instruments, rather than by outside visual references) in the past six months. 

The FAA provided limited additional grace periods for pilots unable to meet certain of its training, currency, and testing requirements during the pandemic, further highlighting the tension between the logistical limitations of COVID-19 and essential air safety parameters. 

Safety risk mitigation strategies for air operators 

As these novel COVID-19-related risks continue to come into focus, and in light of possible enhanced federal oversight in this space, air operators must reassess their individual risk profiles and adjust policies and procedures to effectively mitigate new and shifting risks.  This includes taking steps to account for the heightened risk of proficiency degradation in pilots returning from pandemic-related leave.  While each company’s approach should be informed by its unique risk profile, we set out below several recommendations for air operators to consider as they work to define a path forward.

  • Educate returning pilots about the particular risk of pandemic-related skill deterioration.  The conditions brought about by the pandemic are largely unprecedented, and some pilots may falsely believe that their skills and training will quickly return when they reenter the cockpit.  By encouraging greater self-awareness about their potential weaknesses, pilots will be less vulnerable to judgement-clouding false confidence and better prepared to manage the challenges they will face when returning to work.

  • Identify and plan for obstacles that may interfere with pilot re-training and re-certification.  Pre-pandemic approaches to training and practice were not designed to accommodate the unique circumstances triggered by COVID-19 – training facilities, instructors, and simulators are likely to face significantly increased demand as more pilots return to work, and access to these resources will be further constrained by social distancing and other safety protocols.  Be sure to build these delays into your operational plan, and consider opportunities for interim training and education while pilots are still at home.  Whether this involves investing in at-home flight simulation software or online training, making existing training materials available outside of a formal training setting, or providing low-tech resources like flashcards or instrument diagrams, steps taken to help pilots maintain proficiency while at home can help lower safety risks when they return to work.

  • Recognize that FAA minimum currency requirements might not be an accurate indicator of pilot proficiency or preparedness to return to the cockpit post-pandemic.  In light of the heightened risk of skill degradation, consider re-evaluating your procedures for assessing and clearing pilots for flight, and if warranted, impose more robust internal re-certification requirements.  In addition to assessing pilots’ technical skills, be aware of the unique COVID-19-related stressors that may have an impact on returning pilots’ focus, confidence, and stamina.  Pilot evaluations should take these factors into account, and processes should be set up to ensure that mental health resources are available and accessible to pilots who are preparing to return to work.

  • Consider whether temporary risk mitigation measures are needed.  If your pandemic risk assessment reveals areas of potential concern, pre-pandemic policies may need to be adjusted.  Temporary measures such as operating limitations for difficult flying conditions, enhanced safety thresholds, or more specific conditions around crew composition could provide a critical safety net in the period of transition following the shutdown.

  • Most importantly, take this opportunity to comprehensively review and update Safety Management Systems and company policies.  Consider whether additional adjustments are needed to address new and changing risks, and continue to reassess these topics as conditions evolve.

The fact remains that flying is and will remain the safest mode of transportation.  According to the latest International Air Transport Association statistics in its 2019 safety report, the aviation industry’s safety performance has continuously improved in recent years and the accident rate was the lowest it had ever been prior to the pandemic.  However, while we anticipate clearer skies and a strong return of pilot proficiencies after the pandemic, the sector has never before faced a crisis of such a lasting duration.  As a result, the industry must take steps to ensure its workforce is ready to meet pent-up passenger demand as soon as the threat of the pandemic subsides.