Yes, sir. I certainly agree, but I'd again like to warn the committee that it is important that the ICAO standards give considerable leeway to states in terms of implementation. They are generic because we need to take into consideration the different possibilities and constraints of an audience and membership that go from states with resources, such as the U.S. and Canada, to Montenegro. These are very generic standards. There is leeway for states to implement these standards in ways that are appropriate to their resources and limitations.
Furthermore, this is a word of caution regarding the audits. You might end up with a different file because you've done better than the standards.
I'll give this committee one specific example. Annex 6 clearly indicates that flight crew members should undergo periodic training every six months. The Federal Aviation Administration devised a program, which is called the advanced qualification program. It is a state-of-the-art training system that allows airlines in very controlled environments to have their crews trained once a year. It is a superior system, and it's so complex and sophisticated that it has only been implemented in a few carriers within the United States.
But the fact remains that those carriers cycle their flight crews through the training system once a year, not twice, as annex 6 imposes. Even when the system is superior, in the audit of the FAA, it was marked as a difference.
Not meeting standards does not necessarily mean substandard performance. It simply means you're not ticking a box.
