I was once in Miami and a friend shared a story. He works in a Repair Station there that performs maintenance on aircraft, and has frequent FAA visits. It seems one day an FAA Inspector expressed concerns to him that he had doubts some Repair Station Technicians and Inspectors could competently comprehend English as contained in Quality and Maintenance Manuals. The person responded; “Then why did you issue them A&P and Repairman Certificates?” It is, after all, the FAA’s responsibility to determine such competency before issuing the certificates. I’d caution at this point to resist the temptation to think this is an example of Inspector bias or variation in interpretation of regulations…it is not.
In most parts of the world, English is the international language of aviation. Flight Deck instruments are in English, as are flight manuals and maintenance instructions. The process of communication is very fragile and subject to varying levels of understanding at the slightest nuance of expression or interpretation. We all know of person’s who speak English as their primary and only language, yet we can’t quite understand them; Yogi Berra and Leo Gorcey of the Bowery Boys (http://en.wikipedia.org/wiki/Leo_Gorcey) comes to mind, both of whom easily massacre the English language in expressing themselves. Fortunately neither turned wrenches or yokes.
The FAA has an Advisory Circular 60-28A titled “English Language Skill Standards Required by 14 CFR Parts 61, 63, and 65”, and it makes proper reference to the efforts of the International Civil Aviation Organisation (ICAO) to establish a basis for evaluating English language skills, and has 6 levels of Proficiency. Level 1 being “Pre-Elementary” and 6 “Expert”. The acceptable minimum level of proficiency is 4 “Operational”.
To establish a person’s proficiency level, they are evaluated in 6 areas: Pronunciation, Structure, Vocabulary, Fluency, Comprehension, and Interactions.
For example, at “Operational” Level 4, “Fluency” would mean”
“Produces stretches of language at an appropriate tempo. There may be occasional loss of fluency on transition from rehearsed or formulaic speech to spontaneous interaction, but this does not present effective communication. Can make limited use of discourse markers or connectors. Fillers are not distracting.”
The more you peel back the layers of ICAO’s efforts, the more you’ll be impressed with the science it brings. More than that, whether an employer, the FAA, or any other CAA, the ICAO literature brings a level of standardisation that when followed, levels the playing field.
So, you ask, how do I administer a test? According to AC 60-28A:
“If deemed necessary by the examiner and/or the ASI in order to assist the determination of the applicant’s English language proficiency, the examiner will require the applicant to read a section of a technical manual. After completing this step, the examiner will require the applicant to write and explain his or her interpretation of the reading. An appropriate technical manual in this sense means an Airplane Flight Manual (AFM), a maintenance manual, or any other publication appropriate for the certificate or desired rating.”
It could be that easy.
For pilots we all understand that there can be no compromise in this process, but what about certain maintenance technicians? It turns out there is some latitude. According to AC 60-28A:
“(3) Mechanics and Repairmen. Eligibility requirements contained in §§ 65.71(a)(2) and 65.101(a)(6) require an applicant for a Mechanic or a Repairman Certificate and associated ratings to be able to read, write, speak, and understand the English language. An applicant who does not meet this requirement (Royboy’s underline), and who is employed outside of the United States by a U.S. air carrier, will have his or her certificate endorsed, “Valid only outside the United States.””
Although there are some in the aviation community who would question why a person who failed the English test should be granted a certificate as reflected by this Regulation, and yes it is an FAR, I have to say I support it wholeheartedly, and it’s based on my own experiences. I recall one example I had when working for a major airline many years ago. I was doing a Quality Station Audit of our operation in Mexico City and spent a couple of days with the line maintenance staff consisting of all Mexicans, very few of which spoke passable English. I was very impressed with their technical acumen and compliance with published maintenance manual procedures. I quickly learned from this and other experiences that I should not judge a technician’s technical competence based on his inability to express himself precisely in English.
On the other hand I have to hand it to air traffic controllers who deal with international traffic. I’ve heard a lot of exchanges that left me scratching my head as to what was said. That’s another good reason for the expansion of pilot-controller text messaging that is slowly gaining operational implementation; it called CPDLC-Controller-Pilot Data Link Communications. These text messages don’t have heavy accents, slang, or intonations. Neat, huh?
So what’s your opinion about this stuff? Leave a comment on this web site. You can do so anonymously if desired.
Over ‘n out
Roy “Royboy” Resto
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