The Charter Pilot Asked to Operate Without a Current AROC
A charter operator has a pilot, Tomas, whose AROC was issued four years ago. The operator's records show the certificate but no record of any recent competency check or refresher. Tomas has been flying mostly non-radio-intensive scenic flights and has not used controlled airspace for eighteen months. A last-minute charter requires him to enter Class C airspace and communicate with approach and tower. The operations manager says the AROC is "still valid, so he's fine" and asks you, the safety manager, to sign off the flight. Tomas himself admits he feels rusty on phraseology and has never used a conditional clearance in a radar environment.
1. Analyse the issues around the currency of Tomas's authorisation and his operational competence, distinguishing between the validity of the certificate and the operator's obligations.
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There are two separate questions: whether the AROC remains valid, and whether Tomas is competent to exercise the privileges it confers on this flight.
On validity, an AROC is generally issued without a fixed expiry, but that does not mean it can be used indefinitely without any demonstration of continuing competence. The operator should check the conditions attached to the authorisation and any requirements for ongoing competency or recency. The absence of a recent competency check in the records is a red flag that must be resolved, not assumed away.
On operational competence, Tomas has not used controlled airspace for eighteen months, feels rusty on phraseology, and has no recent experience of conditional clearances in a radar environment. Certificate validity does not equal operational readiness. The operator has an obligation to ensure that a pilot exercising radio privileges is competent to do so, particularly when the flight involves Class C airspace and interaction with approach and tower.
The operations manager's reasoning - "still valid, so he's fine" - is insufficient. A valid certificate is a necessary but not sufficient condition for signing off the flight.
2. Recommend what should happen before the flight is authorised, and what the operator should put in place for the future.
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Before authorisation:
Verify the authorisation: Confirm the current status of Tomas's AROC and any conditions or recency requirements attached to it.
Assess competence: Conduct a structured check of his radiotelephony competence, covering controlled airspace phraseology, readback of clearances and conditional clearances. This could be a simulator session or a supervised flight with an appropriately qualified check pilot.
Decide on the flight: If the check is satisfactory, the flight may proceed with appropriate supervision or a buddy arrangement for the first sector. If not, the flight should not proceed until remedial training is complete.
For the future, the operator should:
- Maintain a register of radio operator authorisations with review dates.
- Schedule periodic competency checks or refresher training, especially after long periods away from controlled airspace.
- Include radio competence in the operator's safety management system, with a clear process for last-minute crewing decisions.
- Document the decision and its rationale so the operator can demonstrate due diligence.