Risk Management? Really?

Is the Emperor Naked? It Sure Looks That Way

The illusion here is based on the FAA’s belief that student pilots can be taught risk management skills. Learning to manage risk, however, requires prerequisite knowledge that student pilots typically do not have, nor is that knowledge typically available in any FAA document. So why does the FAA think that student pilots can be taught to manage risk? Why does the FAA sees clothes where I see a nudist? Let’s find out.

The dictionary defines risk as exposure to the chance of injury or loss. The key word here is chance. Risk management assumes that you know the chance—the probability—that an event might occur. For student pilots (or any low time pilot), event probability (risk) is extremely difficult (if not impossible) to evaluate, much less look up in some database that does not exist. It requires a background in statistical analysis or extensive aviation experience from which probability assessments might be intuited.

Keep in mind that NASA used risk assessment to identify the risks associated with flying the space shuttle. Their engineers, mathematicians and statisticians concluded that there was a 1 in 100 chance of losing a shuttle on every flight. Now that’s "authentic" risk assessment. Clearly this isn’t something that student pilots (or low-time pilots) are capable of doing. Most likely, these individuals don’t have the statistical knowledge to make these assessments (assuming the data are even available to use in making these assessments) nor do they have the working substitute for this knowledge known as “aviation experience” with which to make risk assessments. If you can’t assess the risk, you can’t manage the risk (unless you simply don’t fly... and what fun is that?).

Nevertheless, a fundamental feature of the FAA’s Risk Management Handbook is the Risk Assessment Matrix (shown below). This chart requires knowing the probability (i.e., likelihood) that an event might occur, and its severity should it occur. It also requires that you know what risk level is acceptable to you. Yet, the FAA never defines the "likelihood" values on the left vertical axis of their matrix. For instance, if the severity of an event is "catastrophic" but "improbable," it's listed in the green or "medium" risk category. So why is that airline pilots avoid areas of red on their radar screens (red areas have a 2% chance of destructive turbulence)? It seems as if a 2% chance of something happening falls close to the "improbable" range of likelihood, doesn't it? One might think so. Yet, airline pilots who see red colored radar returns on their radar screen avoid the area with a passion despite the event falling into the green or "medium" risk range on the FAA's matrix. So how can we talk about risk management when we can't speak with any precision about the risks we're willing to take?



The fact is that the FAA can't offer numerical "likelihood" values because they don't know what these values are for any given situation. Said another way, the FAA wants you to assess then manage risk, but they can't tell you what an acceptable risk is (outside one that falls into the right, bottom corner of the risk matrix). Can we really expect students (or low time pilots) to possess this knowledge and make these calculations? This seems unreasonable to me. Except for the extreme ranges of risk, the FAA's idea of risk assessment relies on vague impressions, incalculable assumptions and a great deal of wishful thinking.

The ironic thing, however, is that the FAA agrees with my assessment despite promoting the "fantasy" that risk management skill is within the skill range of a low-time aviator. Take a look at the following excerpt from Page 1-5 through 1-6 of its Risk Management Handbook (FAA-H-8083-2):

Managing Risks - Excerpt
"Risk is the degree of uncertainty. An examination of risk management yields many definitions, but it is a practical approach to managing uncertainty. Risk assessment is a quantitative value assigned to a task, action, or event.... Take the use of improper hardware on a homebuilt aircraft for construction. Although one can easily see both the hazard is high and the severity is extreme, it does take the person who is using those bolts to recognize the risk. Otherwise, as is in many cases, the [risk assessment matrix] chart is used after the fact.... Therefore, risk management is the method used to control, eliminate, or reduce the hazard within parameters of acceptability. Risk management is unique to each and every individual, since there are no two people exactly alike in skills, knowledge, training, and abilities. An acceptable level of risk to one pilot may not necessarily be the same to another pilot...."

ROD MACHADO'S INSTRUMENT PILOT'S AUDIOBOOK (MP3S ON DVD OR DOWNLOAD)On the other hand, what if we speak in terms of hazards instead of a risk? A hazard is defined as a danger or a peril. It’s something concrete that students can be taught to identify and avoid. Calculating probability is not required here because a hazard is not a data point on a risk assessment matrix. You don’t need to be a tai “chi-squared” master to recognize danger.

Hazard avoidance is precisely what good pilots do. They visually avoid thunderstorm cells by a minimum of 20 miles. They avoid flying into known icing conditions in an airplane not certified for flight into known icing conditions. Sure, they might climb or descend through an area of ice, but only if they know that they can quickly move into conditions not conducive to ice formation. They know their personal crosswind limits and avoid landing when those limits will be exceeded. There's no calculation or probability assessment taking place here (at least not as the FAA defines it). Good pilots think in terms of hazard avoidance; good instructors teach in terms of hazard avoidance.

Once again the FAA agrees with me on this point despite pretending that inexperienced pilots can actually assess risk. Take a look at the following excerpt from Page 17-4 of the FAA's Pilot Handbook of Aeronautical Knowledge (FAA-H-8083-25A).

Hazard and Risk - Excerpt
"Two defining elements of ADM are hazard and risk. Hazard is a real or perceived condition, event, or circumstance that a pilot encounters. When faced with a hazard, the pilot makes an assessment of that hazard based upon various factors. The pilot assigns a value to the potential impact of the hazard, which qualifies the pilot’s assessment of the hazard—risk. 

Therefore, risk is an assessment of the single or cumulative hazard facing a pilot; however, different pilots see hazards differently. For example, the pilot arrives to preflight and discovers a small, blunt type nick in the leading edge at the middle of the aircraft’s prop.... The seasoned pilot may see the nick as a low risk. He realizes this type of nick diffuses stress over a large area, is located in the strongest portion of the propeller, and based on experience, he doesn’t expect it to propagate a crack which can lead to high risk problems. He does not cancel his flight. The inexperienced pilot may see the nick as a high risk factor because he is unsure of the affect the nick will have on the prop’s operation and he has been told that damage to a prop could cause a catastrophic failure. This assessment leads him to cancel his flight." 

Student pilots are fully capable of avoiding in-flight hazards with a little training. All that’s needed is for their instructors to help them identify these hazards in specific and general terms.

Specific hazards are sometimes defined by the limitations placed on a student by the instructor or by the Federal Aviation Regulations. An instructor might inform his or her students not to fly when the direct crosswind component exceeds a specific value, when the flight visibility is less than three miles and when the flight cannot be made with visual reference to the surface, to name a few. Instructors can add as many additional items to the specific hazards list as necessary to ensure their student’s safety.

General hazards are best described in the succinct and condensed literary packages known as aviation aphorisms. These are wisdom-packed, hazard-avoidance lessons that students can easily remember. Here are just a few examples.

There’s nothing more useless than the altitude above you and the runway behind you. Takeoffs are optional but landings are mandatory. The only time you have too much fuel is when you’re on fire. The probability of survival is equal to the angle of arrival. Learn from the mistakes of others because you won’t live long enough to make all of them yourself. And so on.

These aphorisms are powerful behavior modifiers that can help student pilots make better decisions aloft and they have nothing to do with risk assessment. So fill your student’s noggin with these general, poetry-like quips of flying wisdom, along with your own specific warnings of hazards.

At this point you’re probably asking, What’s the downside to speaking in terms of risk management at the student pilot level? There are three important reasons not to pretend you’re teaching students to assess risk when they’re not.

First, students can’t manage risk unless they can assess it. Since they’re unlikely to have the skill to do this, they’re more likely to proffer a guess, instead. To the student pilot, risk assessment is guess assessment.

Second, an incorrect guess might result in the student making a poor decision while feeling confident of the outcome. There’s no upside to guessing wrong then feeling you’ve chosen wisely.

Third, while highly experienced pilots can assess probabilities based on their experience, they typically don’t do this. Instead, they reduce their mental workload by identifying and avoiding areas of known danger. As a general rule, very little (if any) probability calculation takes place inside a pilot’s noggin. When an airline captain sees red on her airborne radar screen, she’s not thinking, “Let’s see, red represents an area of 40 to 50 dBZs of radar reflectivity which is statistically associated with a 2% of destructive turbulence so I’m going to avoid that area.” Instead, she sees a hazard (a red colored echo) and avoids all contiguous echoes associated with that hazard by at least 20 nautical miles.

If you’re a flight instructor and want to offer a practical lesson for your students, teach them to avoid hazards. Don’t teach them something that’s not practical for them to do. Leave probability assessment for the professional mathematicians. Avoid the illusion; embrace the practical.

In the meantime, if you see nice looking outfit for sale, I know an emperor who needs one.

(This article originally appeared in AOPA Flight Training magazine.)

By Rod Machado | | CFI Resource Center, Learning to Fly | 4 comments
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  • Jim Davis - October 01, 2016

    Good talking to you today at lunch in Prescott, AZ. I mentioned a story I had for you so it is attached. The story with my student happened during the 1970’s. Check it out and let me know what I should have done or what you would have done in ole Stevers case! Also let me know if you find that letter a pilot wrote when applying to an airline and he gave an example of how good a pilot he was because he had made several “wire strikes” and never wrecked a plane – or something like that! Here’s my story of one of my students.

    Student Pilot Problems

    Flight Instructor Log: Oct 1974, Van Nuys Airport, California. Flight instructors always have stories about some of their students, especially the primary students working on their private license. Some of these stories are funny and some are really disconcerting and do qualify for the famous question – “why did you do that?”

    One particular student named Steve was a very smart cookie regarding his chosen profession which was mechanical engineering. I know this because I hired him at the company where I worked and knew of his work and his performance reviews. But somehow his brainpower did not seem to translate well into the world of flying.

    An example is when we went on his first dual cross-country. Steve had already soloed and could fly the plane sufficiently well. Steve laid out the flight plan requested and charted a course of 270 degrees from Van Nuys, California, the departure airport. After we departed the pattern Steve settled on a course of 240 degrees and busily began to look for our first check point now less than 10 minutes away. I ask him what our course was and he replied, “ 270.”

    The visibility was great and I could see the checkpoint slipping off to our right while Steve was peering over the nose of the Cessna 150 looking directly ahead. He was 30 degrees off course! So I began my questioning hoping this would be a good teaching moment when he realized his error.

    Steve directed my attention ahead and pronounced the first checkpoint as confirmed. Uhmmm… I let it go because I was interested in what he was going to tell me about the next checkpoint and when was he going to discover his 30-degree navigational error. We continued to get further and further off course. I asked him three times about his course and told him to “look around, not just directly ahead.” He never picked up on the problem. I wondered how long it would take for him to make the discovery. Very interesting look into human behavior!

    Another 10 minutes passed and Steve identified the second checkpoint and I challenged him. He could not show me where all three of the identifiers on the ground that would confirm his proclamation. I waited. We trundled along in our trusty Cessna on 240 degrees drifting further and further from our intended course of 270 degrees. Finally, I could take it no more and ask him where the third check point was since it was a large lake and could be seen from a great distance even on a bad day! In fact, I had it in sight directly off our right wing and could see the lake from the time we achieved our cruise altitude. Ole Stever seemed puzzled. He could not find any body of water over the nose of the aircraft where he thought it should be! I asked him why he was not looking around and only focusing on what was straight ahead. When he could not figure it out, I closely questioned him about his planned course and why he was following a different course. He could still not figure out his dilemma. He was an engineer and knew how numbers worked, or so I thought!

    Steve said he did not know why he was following 240 degrees! Finally, I directed his attention directly off our right wing and ask him what that great big body of water was doing over there when it was supposed to be below us! I explained his navigational error and figured he was taking it all in and learning. But was he? Where was his head? This is a smart guy. What was he thinking while we were flying his first cross-country flight? Maybe he was trying to solve some mathematical equation in his selected profession. I don’t know but his math was sure off that day and he refused to look around! Even my questions did not seem to bring him back into the cockpit! Ole Stever had no rebuttal, no questions, no comments…Steve sat there saying very little but did turn the plane toward the lake and we got back on course.

    The story doesn’t stop here; it’s only the prelude to the greater mystery! That particular flight continued with the rest being routine once we got back on course. He passed the rest of my questions regarding the flight and did fine. The flight was over a triangular course of a hundred miles or so and went according to plan.

    As Steve’s flight training continued there were a number of small items that seemed to escape his attention. He passed his private written exam, did all of the cross country flights and got back home all right. He performed his air work and maneuvers in good order and seemed to be learning well. This always makes a flight instructor feel good!

    Sometimes during a lesson Steve didn’t seem to quite have it together but responded well to the instruction and was now doing everything by the book. Towards the end of five months working with Steve mainly on weekends, and enough flying hours for his license, the company was going to transfer him to another state. Steve wanted to take the check ride and get his private license. We doubled up on his lessons for a few weeks and I had to agree with him because it seemed like it was a now or never situation. Steve was leaving the state. I was a little nervous about the sign off but I could not figure out why. What the heck! Steve had learned and now it was time for the big test.

    Steve could fly the plane fine but something bothered me. I could not put my finger on any specific problem other than what we have already talked about. His solo cross-country’s worked out so maybe I was not being realistic. I signed him off for his check ride with the FAA just days before his transfer to the east coast. Steve should make it okay if he just stayed alert and kept his mind on what he was doing. That may have been too much to ask!

    The FAA examiner was a woman and known to be hard on private check rides. But Steve was very smart. You must remember that he had his Bachelors in Mechanical Engineering! He had good performance reviews of his professional work and he could fly the plane well. Steve would pull it off but I did keep my fingers crossed.

    The day came and Steve’s oral exam went well and he did his cross-country flight plan satisfactorily. As the story goes, according to Steve, he stepped into the Cessna 150 and taxied out with the examiner and did the run up just fine. His flight plan called for a course of 270 degrees from the Van Nuys airport (remember the problems from before?). I even told Steve that the flight plan would probably take them west of the airport and away from the congested city until the Examiner felt the student was competent in cross country navigation. The beginning of the flight plan was the exact same as our very first cross country flight during his training. We had trained in this exact manner! Steve would be covering old ground…but it was not to be, it only got worse!

    At any rate, ole Stever departed the pattern under the Examiner’s close eye and took up a heading of 090 degrees instead of 270 degrees to begin his cross-country flight! He established himself on the 090 radial and then made the discovery of his error within a minute or two so he explained to the examiner that he was supposed to be going the opposite direction – 270 degrees as he had planned on the ground some 30 minutes earlier! He began the turn to 270 degrees and the examiner said, “Take us back to the airport.” The check ride was over. Steve had flunked the test.

    What’s with Steve’s brain? Guess he could not focus on only the flying problems at hand but had so much else on his mind with his job, the upcoming move and the like. He just couldn’t compartmentalize and think of the immediate problem at hand. Like the course of 270 degrees! Maybe he was setting a course for the east coast where he was soon to move! What makes people do what ole Stever did? Maybe a dyslexic problem of some sort? Should he even be a pilot? I don’t know but what I do know is that several days later Steve transferred to the east coast with the company and I no longer had to worry about signing him off for his private pilot’s license. Steve was gone but not forgotten.

    But wait, the story is not over! Guess what happened to ole Stever as reported to me by one of his good friends some months after his failed check ride?

    Steve found another CFI back in upstate New York and continued his training. The new instructor signed him off for another solo cross-country back in the lush, green countryside of northern New York State in the early summer of that year. His instructor told him that his destination airport had “green buildings and hangers and you will recognize it,” or some words to that effect. Of course Steve would!

    Unfortunately, the instructor did not yet realize whom he was dealing with! On the surface, ole Stever put forth a good image and seemed competent. Something I already knew. Anyway, Steve got started and took off on his solo cross-country under a new instructor’s sign off.

    As Steve thought he was approaching the airport, he called the tower and reported five miles out with the current airport weather and information. The tower acknowledged Steve’s call but stated that they did not have him in sight but cleared him to land since there was no other traffic. Then Steve thought to “confirm” the fact that the airport did contain a number of green buildings on its property! Really good information to confirm when you already had that information! I don’t suppose he wanted to check out the runway! I bet that may have been the first time that type of information had been requested from the tower! Anyway, they confirmed that fact for Steve. The airport had all green buildings! Good, no problem….yet!

    As the story goes, Steve saw “green buildings” and setup his landing. As mentioned, Steve was given permission to land since there was no traffic at the airport but the tower told Steve that they still “did not have him in sight” when he reported approaching the field.

    Steve landed very nicely in a farmer’s field that had a barn and several other out buildings painted green! Steve shut down his engine and walked up to the farmer and asked him if this was the airport! This is a true story told to me second hand! The farmer told him the airport was about five miles “that- a- way” and pointed the direction. The old farmer probably never knew what a real service he was providing for ole Steve! Pointing the way that is! Really glad he did that otherwise ole Stever may have ended up somewhere else. Who knows what lurks in the minds of confused student pilots! I understood that Steve did get airborne again and completed the flight. Don’t know what the tower said to him upon his actual arrival to their field.

    I lost touch with Steve and not sure if he ever got his private license. If he did, I hope he just flies locally! Later I heard that he moved to Texas so if ole Stever did get his license and you happen to live in Texas, watch out and try to help this lad find the airport!

  • Andy Foster - April 17, 2016

    Nobody’s arguing against teaching student pilots about risk and hazards; it is as essential as any other piece of the skill set we teach them. The discussion is about what approach is the most valid. Most people are overconfident in their assessments about likelihood and also consequence, including engineers and safety professionals who deal with risk on a day to day basis. What I believe Rod is pointing out ( and what I talk about more on my one blog) is whether a simpler approach of hazard avoidance is better. I certainly think it is, and as Rod points out, it’s what most pilots do.

  • Pat K - April 07, 2016

    Based off the learning principle of “what is leaned first is learned best,” it seems introducing the concept of risk management to a beginning student has value. Every flight has both common as well as varying hazards. Risk management is advocating that the student “investigates” the hazards prior each flight. Of course, the beginning student’s awareness of what are the risk is low. Each flight will subsequently build on that awareness. I am not aware of any data that supports a lower accident rate from initially teaching this method; however, I do not see any negative consequences resulting from it. When we start teaching a flight student, we don’t initially teach just stick then rudder. Similarly, we should not teach hazards then risk management. Like stick and rudder, they are fundamentally intertwined.

  • Andy Foster - March 17, 2016


    I fully agree with you on this. I’m a Light Sport CFI; but more importantly, I’ve worked in manned spaceflight safety for close to two decades (and most of my experience has been with the shuttle program) and had been wrestling with this issue for some time until I saw your article (You beat me to the punch writing about it!). This is ON TARGET! The process described was developed for managing risk at the program level, and as you pointed out, the judgement of likelihood and consequence both must be rigorous (and even NASA programs struggle with it at times) and is best served when supported by “quantitative” analysis (like PRA). At the pilot level, especially the student pilot level, it’s a lot more practical and wise to simply avoid any risks you can and go home to fly another day.

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