Information regarding the UK Qualification of a Flight Simulation Training Device (FFS and FTD)
This page describes the qualification process for Full Flight Simulators and for Flight Training Devices only. Refer also to the page on Flight and Navigation Procedures Trainers if applicable.
A Qualification Certificate is granted to a FSTD that has been successfully evaluated by the CAA for compliance with the relevant regulatory requirements.
The CAA issues qualifications in accordance with EC Regulation 216/2008 and the ‘Aircrew Regulation’ EU 1178/2011 as amended by EU 290/2012.
The Aircrew Regulation consists of a number of “Articles” of which Articles 10 and 11 contain the primary information related to the qualification of FSTDs. These articles refer to two Annexes:
Annex VI: Authority Requirements for Aircrew (Part ARA)
Part ARA with its associated AMCs & GMs defines the administrative and procedural requirements to be complied with by the Competent Authorities (such as the UK CAA) for the conduct of evaluations and the issue of Qualification Certificates.
Annex VII: Organisation Requirements for Aircrew (Part ORA)
Part ORA with its associated AMCs & GMs defines the requirements to be complied with by the FSTD Operator for the qualification and operation of FSTDs. This part includes the requirements for a Management System, Safety Management System and a Compliance Monitoring System. This Part also includes information explaining who the Competent Authority is.
The “Competent Authority” is responsible for the qualification and oversight of a FSTD. The regulations (Part ORA ORA.GEN.105) define who the “Competent Authority” is.
The UK CAA is the Competent Authority only for FSTDs located in the UK and operated by companies who have their ' principle place of business' in the UK or FSTDs in other EU Member states where the FSTD Operator has their principle place of business in the UK.
EASA is the Competent Authority for all FSTDs located outside EU Member States and FSTDs located in EU Member states (including the UK) where the FSTD Operator’s principle place of business is in a non-EU country.
Part-ARA (ARA.GEN.105 20) defines the principal place of business as follows:
'Principle place of business' means the head office or registered office of the organisation within which the principal financial functions and operational control of the activities referred to in this Regulation are exercised’.
The current regulatory technical standard used by the CAA for the qualification of all FSTDs is CS-FSTD. There are two individual codes of requirements. CS-FSTD A is applicable to aeroplane simulations and CS-FSTD H is applicable to helicopter simulations.
FSTDs are subject to an initial evaluation leading to a ‘qualification’ and are then evaluated recurrently on an annual basis. A Qualification Certificate is issued when the CAA is satisfied that the device, together with the Compliance Monitoring System supporting its operation, meets the requirements of Part ORA.FSTD.101 and Part ORA.FSTD.210. A Qualification Certificate is issued with an unlimited duration, it has no expiry date.
FSTD Initial Qualification
1. Where EASA is the Competent Authority an application shall be made to EASA using Form 129
(The UK CAA is the Competent Authority only for FSTDs located in the UK and operated by companies who have their ‘principle place of business’ in the UK or FSTDs in other EU Member states where the FSTD Operator has their principle place of business in the UK)
2. Where the UK CAA is the Competent Authority an application shall be made to the UK CAA using CAA Form SRG 2198
(EASA is the Competent Authority for all FSTDs located outside EU Member States and FSTDs located in EU Member states (including the UK) where the FSTD Operator’s principle place of business is in a non-EU country)
The UK Initial Qualification Process
Following receipt of an acceptable application the dates and programme will be agreed for the initial evaluation. The applicant must submit a Qualification Test Guide (QTG) to the CAA for review. Unless otherwise agreed with the CAA the QTG must be submitted not less than 30 days prior to the evaluation date. (Refer to ORA.FSTD.200, AMC1 ORA.FSTD.200 and GM1 ORA.FSTD.200: Application for FSTD Qualification).
There is no standard format for a QTG but it must reflect the requirements of the relevant part of CS-FSTD and be acceptable to the CAA.
Note: The QTG, when approved, will become the Master Qualification Test Guide (MQTG) which is a key document for both the initial FSTD qualification and subsequent FSTD recurrent evaluations.
The Simulator Technical Inspector (STI) will review the submitted QTG and provide comments to the applicant prior to the evaluation.
To gain a qualification the FSTD is evaluated at its place of operation by an evaluation team consisting of, as a minimum, a Technical Inspector (TI) and a Flight Crew Standards Inspector or a Flight Operations Training Inspector (FI). The initial evaluation will normally take a minimum of three days to determine whether the requirements of CS-FSTD have been met.
At the conclusion of the evaluation the CAA will, if satisfied that compliance with CS-FSTD has been demonstrated, issue a “provisional” evaluation report to allow training to commence without delay. The report will include any restrictions or limitations that are deemed appropriate.
The results of the evaluation are subject to an internal review by the CAA and a final evaluation report together with the formal Qualification Certificate is sent to the Operator of the device. The CAA reserves the right to make changes to the evaluation report or ultimately the qualification of the device during this review phase.
Part of the initial evaluation will be to establish that the FSTD is managed in accordance with a Compliance Monitoring System that meets the requirements of Part ORA.FSTD.100 and its supporting AMCs & GMs.
FSTDs can allow for more than one aircraft model or variant to be represented by a single device. For evaluation purposes, where each variant requires a different aerodynamic model and QTG, they will be treated as separate devices.
Multiple engine or avionic fits will normally be included in a single evaluation.
The Aircrew Regulation has requirements for a Management System and a Compliance Monitoring System (CMS). The Management System must include a Safety Management System (SMS) to consider aviation safety hazards and the management of any associated risks.
Many FSTDs are operated by Approved Training Organisations (ATOs). It is expected that the CMS and SMS will be integrated into an overall Management System for such Organisations. The regulations do allow for the operation of FSTDs by non-approved Organisations. Such Organisations also have to demonstrate an appropriate Management System, SMS and CMS.
Compliance Monitoring System
The availability and acceptability of a Compliance Monitoring System (CMS) must be demonstrated as part of, or concurrent with, the initial qualification, as it is a requirement of Part ORA for the qualification of a FSTD. If the FSTD Operator already has a CMS under which other qualified devices are managed, it is normally accepted for the purposes of the initial evaluation.
A FSTD Operator is required to establish and operate the CMS which must comply with Part ORA.FSTD.100 and its supporting AMCs & GMs. The main elements of the CMS are explained in the AMCs & GMs.
The CMS is also subject to oversight by carrying out a periodic audit normally every two years. For FSTD Operators with a single device this would usually be combined with the recurrent evaluation.
The CAA offers CMS and Evaluator Training courses; further information should be sought from CAA International (CAAi).
UK CAA Revalidation of a FSTD Qualification (Recurrent Qualification)
A FSTD Qualification Certificate is of unlimited duration. However, the device is subject to an annual revalidation of the qualification (a recurrent evaluation) by the CAA in order to continue using it for accredited flight training. An evaluation of the device for this purpose is undertaken by a team consisting of a TI and a FI and is normally carried out in one day.
At the conclusion of the evaluation the CAA will issue a “provisional” evaluation report.
The results of the evaluation are subject to an internal review by the CAA and a final evaluation report, together with the formal Qualification Certificate (only if amended), is sent to the Operator of the device. The CAA reserves the right to make changes to the evaluation report or the qualification of the device during this review phase.
An application for revalidation of the qualification is required in advance of the planned evaluation date. A revalidation can be carried out up to 60 days prior to the end of the 12-month recurrent evaluation period. It is the responsibility of the FSTD operator to apply (using form SRG 2198) well within these time scales in order to ensure compliance with the regulation.
The Special Evaluation
A special evaluation of a FSTD may be required by the CAA in some circumstances, for example following a significant update or upgrade, relocation or a return to service after deactivation, or possibly due to known poor performance of the device over a period of time.
Special evaluations are tailored to the issue that has driven the decision to evaluate and may include an additional QTG review as well as a subjective evaluation.
During a FSTD evaluation it may be found that deficiencies in the device give rise to restrictions or limitations on its use for the full range of training, testing or checking tasks for which it might otherwise be used.
Restrictions or Limitations will be shown in the Evaluation Report and the non-expiring Qualification Certificate will be reissued specifying the Restriction or Limitation.
Such restrictions will remain in place until the CAA is satisfied that the issues that gave rise to the restriction or limitation have been addressed. The non-expiring Qualification Certificate will be amended to reflect any subsequent relaxation of Restrictions or Limitations.
Changes made to a FSTD
A FSTD, during its service life, may be purchased by another Operator, relocated or modified, updated or upgraded (change of qualification level). Any significant changes to a device should be notified to FSTD Standards.
All such changes may affect the qualification of the FSTD and any associated User Approval(s) and so a review of the relevant QTG amendment(s) and an evaluation may be required before any new qualification or approval documents are issued. A Special Evaluation would be undertaken in this case.
Specific Airfields (Category C Clearance Airfields)
The classification of an airfield as ‘Category C’ comes from the requirements of EU-OPS (reference EU-OPS 1.975) concerning Route and Aerodrome Competence for pilots. It is the responsibility of the Aircraft Operator (AOC holder) to comply with EU-OPS.
Where a FSTD is to be used for any training and checking for operations at a Category C airfield an assessment of the FSTD for that specific purpose is required to demonstrate compliance with EU-OPS and allow training into the specific airfield carried out on that FSTD to be certified by the Aircraft Operator. Consequently, it is the Aircraft Operator who is responsible for complying with the regulation and it needs to have a process to assess the device and record the training carried out to establish Category C aerodrome competence.
An Aircraft Operator may define a process as part of the AOC approval based on an independent assessment of the device. Such a process would be reviewed and accepted as part of the ongoing CAA oversight of the AOC approval.
The approval of Category C airfields on FSTDs is no longer a CAA responsibility but it is recognised that many AOC Operators may not currently have appropriate procedures in place for the assessment of FSTDs for specific purposes in relation to Category C airfields.
The CAA offers a service to industry for the review and assessment of airfields classified as ‘Category C’ on request. This will normally involve an evaluation by a CAA Training Inspector to verify that the visual model, terrain model, navigation aids and operation of the FSTD are adequate to support the User’s training needs.
Application for approval of a Category C airfield may be made to FSTD Standards. This service is subject to a fee as defined in the published CAA Scheme of Charges - Personnel Licensing.
Bilateral Arrangements between the UK and the USA for the Qualification of Flight Simulators
In October 2005 the CAA and the FAA signed a new Simulator Implementation Procedure (SIP) to the US/UK Bilateral Aviation Safety Agreement. However with the EU regulations for the qualification of FSTDs becoming effective in April 2012 individual NAAs are not permitted to have a sole arrangement with the FAA. An EASA / FAA BASA / SIP is being considered but until such time that it becomes effective the process is being applied as follows.
The SIP defines a process for the acceptance of device qualification and includes special conditions to cover the differences between the CAA and the FAA FSTD technical requirements. The use of the BASA-SIP allows the FAA to issue a qualification or allow the use of a device qualified by the CAA for accredited training.
Any level B, C or D Full Flight Simulator qualified to a minimum of JAR-STD 1A (amendment 2) located in the UK is eligible to be considered for qualification under the SIP.
Further information is available on the FAA National Simulator Programme web pages.
UK FSTD Operators requiring a BASA-SIP evaluation by the CAA must obtain the agreement of the FAA prior to making an application to the CAA. Following evaluation, normally concurrent with the routine recurrent evaluation, the CAA will issue a BASA-SIP report upon which the FAA will base their acceptance of the FSTD.
This service is subject to a fee as defined in the published CAA Scheme of Charges - Personnel Licensing.
FSTD Extended Qualification - Validity of FSTD Qualification
(See EU 290/2012 Part ORA.FSTD.225 (b) - often referred to as ‘Self-Evaluation’).
The CAA may grant an extended FSTD recurrent evaluation time scale for a period of up to 36 months in accordance with Part ORA. Requests to permit extended qualification are considered on an individual basis, subject to the conditions of the above-referenced Part ORA being established in relation to:
The CAA will agree which devices can be subject to the self-evaluation process and reserves the right to perform FSTD evaluations whenever it deems necessary.
Applying for UK CAA Qualification or Revalidation of a Qualification of a FSTD
For an initial qualification an application must be submitted a minimum of three months prior to the intended date of operation. Applications for revalidation should be submitted as early as possible but no later than 60 days prior to the end of the 12-month recurrent evaluation period. It is the responsibility of the FSTD operator to apply (using form SRG 2198) well within these time scales in order to ensure compliance with the regulation.