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FAA Secret: Part 91 Pilots Set Their Safety Standard!

Some GA pilots have the mistaken impression that our Friendly Aviation Association regulates safety under part 91. Nope. For GA, the FAA only draws the line you should never cross and implores pilots to “make good choices.” They actively *promote* safety elsewhere. There is a lot of freedom here (and plenty of rope to hang yourself). If you just “follow the rules” under CFR 91, you may find yourself in hazardous conditions – the regs are not safety guidelines! Every pilot must specify their own personal margin above the FAA minimums.

The FAA only actively regulates safety for the airlines and charter, where paying customers are a risk. (And the safety contrast is pretty stunning in the graph below). Fun, freedom and flexibility rule GA flying; the 91 regs. are only “legal limits.” The FAA leaves most of the safety decisions to the pilot. So how’s that working out for us?

The first critical step for safety improvement is to understand the FAA minimums are definitely not “operating recommendations! Each individual pilot must choose their personal “safety margin” above the minimums to assure long life and happiness. This “margin” is also what every applicant must demonstrate on ACS flight tests to earn a certificate. Aviation has a lot of “freedom and  fun” but the consequences of careless blundering are severe.

1) Class G airspace weather minimums;  1 sm and clear of clouds.

If you are a safety-minded pilot these legal minimums have very limited application. This *might* work for a slow single on a short leg to a well-known airfield (in non-hazardous terrain). Anything else would be crazy. Educators must make this point loud and clear to all pilots as well as emphasizing PIC responsibility for safety. Some applicants on flight tests specify 3 miles as their enroute visibility on cross counties. Obviously these pilots have never flown very far “VFR” in these conditions.

2) Zero/Zero IFR take-offs (and approaches).

Though part 121 and 135 have very extensive (and complex) safety limits in all operations, but the FAA is very permissive under part 91; “go for it!” The FAA is again trusting the pilot to use good judgement  here and specify their own safe margin. CFR 91.175 specifies pilot “flight visibility” when landing under  IFR and a pilot can proceed to 100 ft above touchdown with just the lights…wow! (some IFR applicants express their readiness for this challenge even on test day). That is why risk-management is such an important part of pilot training and testing. How is GA doing with this “FAA trust?”

3) Pass/Fail Pilot Training/testing with limited recurrency: “perfection is not the standard!”

A pilot earning an FAA certificate may be a “solid 70%” but they become a pilot. Nothing corrects the missing 30% abilities to 100% and future training to improve are entirely voluntary (and rare). The ACS test is a “sampling” and does not require demonstration of critical skills (crosswind landings) or test vital pilot knowledge like self-fueling, grass runways, tiedown, etc.

4) Recurrency: “One hour ground one hour flight”

The FAA mandates an annual inspection for every GA aircraft flying which often takes days or weeks to return a plane to type-certificated standards. A pilot, by contrast, could potentially  get a very brief 2 hour review every *two* years to stay “legally current.” Who thinks this would be enough to return to a high state of proficiency equal to the FAA test standards?

Similarly, the FAA issues ADs for deficiencies discovered in aircraft. Can we (please) issue a “pilot AD” for crosswind landings? Take-off and landing with wind are responsible for 80% of accidents!  If any pilot need a syllabus for what to work on to stay proficient? Look here.

The “Safety Solution” for pilots (see the fatal rate above) is risk management and strategic decision-making. This often involves being honest with ourselves about abilities and saying “no” to flights that we (and the family) want to take; a difficult task. Aviation is a high consequence activity and most of the risk-management tools come from the military. P-A-V-E came directly from “Man-Machine-Mission and the 3P (Perceive-Process-Perform) is a variation on Col. John Boyd’s O-O-D-A (Observe-Orient-Decide-Act). We are basically trying not to end up dead, and any wise and caring pilot should dig deeper into risk management.

This should be the “core subject” for all instructional events too: “these are the skills we are working on today” AND “why are they important for safety?” Fly safely out there (and often)!


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Author: David St. George

SAFE Director, Master CFI (12X), FAA DPE, ATP (ME/SE) Currently jet charter captain.

2 thoughts on “FAA Secret: Part 91 Pilots Set Their Safety Standard!”

    1. I should have taken the numbers off the vertical axis since only the ratio really matters here. (I think I clipped this from the AOPA FIRC, but will search out the source for you). This otherwise could be one day, a week or a year…the ratio is consistently repeatable for any time period. Our GA accident rate is atrocious when compared with 135 charter or 121 airline operations.
      Admittedly, GA operates in a more challenging (and largely unregulated) environment, with fewer resources (as blog points out). But significant improvement could be realized with better pilot training (initial and recurrent).

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