Multi flight test-SE GA

[Bede]

I recently instructed for a multi rating, having not done so for many years. Something came up on the debrief and I'd like your thoughts. For background, I hold a class 1 instructor rating, instructed full time 25 years ago, and have since been flying turboprop and jet aircraft.

On a SE GA, I've always (since I flew piston twins anyway), reduced flaps to takeoff setting, raised the gear and then raised the flaps up. This is standard for all the turboprops and jets that I've flown. The rationale for this is because raising the flaps all at once will cause the aircraft to sink. I taught my student this and this is what he did on the ride.

The student got a 2 because the examiner said that the flaps need to be raised all at once. The AFM does say "reduce drag as soon as possible".

What are other multi instructors teaching for this? Any thoughts?

[digits_]

Is this the exercise where you are approaching with a single engine and then need to go around? In that case most AFMs only call for full flap when landing is assured. I *think* on most ME rides, the examiner is supposed to give you a go-around before that point.
If you are approaching single engine, then you should manage your speed so there never will be a significant sinking when raising the flaps.

If it's an 'unexpected' engine failure that happened during a go around, then the basic mantra to clean up asap would apply, so whatever flaps were out, would get raised immediately. That's how I did it 8 years ago.

//Edit: Seems like the multi engine flight test guide uses the second scenario I described. It's definitely a grey area. I'd guess that for most piston twins the differences in optimal climb speeds are so small that it's more important to get the drag removed asap. A bit sucky to get a 2 for that reason, as the AFM isn't super clear either.

//Edit 2: Flight instructor guide says to raise the flaps right away, unless otherwise specificied in the AFM.
https://tc.canada.ca/sites/default/file ... 11575e.pdf
Page 36-37

[Big Pistons Forever]

I checked the POH for the Seneca 2, Seminole, and Duchess and all specify "flaps up" for the single engine go around. Therefore I think not fully raising the flaps is a major error and a mark of 2 is appropriate, if it were one of these types.

I would also suggest that terminology is important. The normal "take off" flap setting for all of the light twins I am of aware of is zero. Transport category aircraft will always take off with flaps deployed and may have more than one flap setting available depending on a variety of factors. When you are saying initially raise the flaps to the takeoff setting what you are really saying is raise then to the approach flap setting.

On a bit of a tangent

A personal pet peeve is the preponderance of made up FTU procedures I see in flight schools, many directly contrary to the POH/AFM think it is very important that students at all levels know what is in the POH and follow its directions.

One of my favorite flight test questions is "what is the minimum engine oil level ? The instant answer is 5 quarts. So I then ask where does that number come from ? The answer is usually "it what the school or instructor told me". I then ask what does the POH say? About 80% of the time they can't find it and I have to show them. I find this disturbing because you shouldn't depend on what some guy told you for important information you should be able to verify it in the appropriate publication.

end of rant

[7ECA]

I checked the POH for the Seneca 2, Seminole, and Duchess and all specify "flaps up" for the single engine go around. Therefore I think not fully raising the flaps is a major error and a mark of 2 is appropriate, if it were one of these types.

The Secena III also says under the Amplified Emergency Procedures section, One-Engine Inoperative Landing:

"Complete the Engine Securing Procedure. The landing gear should not be extended and the wing flaps should not be lowered until certain of making the field.

Maintain additional altitude and speed during approach, keeping in mind that landing should be made right the first time and that a go-around should be avoided if at all possible.

Establish a final approach speed of 90 KIAS and use wing flaps as required."

Under the following section: One Engine Inoperative-Go Around:

NOTE

A one engine inoperative go-around should be avoided if at all possible.

Further in the description it notes to "Retract the flaps and landing gear."

If you go to the Normal Procedures Section: Go Around:

Full takeoff power, both engines. (40 in Hg. maximum manifold pressure). Establish positive climb at 85 KIAS.

Gear - UP
Flaps - retract slowly...

It stands to reason, that if on a normal balked landing, if the POH states to retract the flaps "slowly" or in stages if you prefer then you probably shouldn't just slam the flaps to UP on a single-engine go around either.

[Bede]

A personal pet peeve is the preponderance of made up FTU procedures I see in flight schools, many directly contrary to the POH/AFM think it is very important that students at all levels know what is in the POH and follow its directions.

Yes, good point. We were discussing similar just the other day. Point of discussion: is there a point in time where the AFM guidance becomes stale and modern common sense starts taking over? For example, the original Piper Cub POH had the "10 commandments of safe flying" that included things like, "THOU SHALT NOT PERFORM AEROBATICS AT LOW ALTITUDES" and "THOU SHALT MAINTAIN THY SPEED LEST THE EARTH ARISE AND SMITE THEE". Is this really as governing as something written in a modern Cessna POH? Another example (I forget which type) discussed how it's perfectly safe to fly through thunder storms as long as you keep the wings level and ride it out.

[DanWEC]

I think it's important to know the type in this case, as it might be a case of what's best practice compared to what's written in the POH vs what criteria the examiner using to assess.

For example, for the PA44, normal takeoff is no flaps, and in both the engine fail/securing and SE GA sections of the POH it states, in order: Flaps...retract. Then, Gear...retract. In the amplified procedures for SE GA the relevant part of the paragraph states "Retract the flaps and gear".

This differs from the PA34, and many every other aircraft as well. To me, it's counterintuitive and doesn't seem like the best practice, but that's how it's written, and I suppose it depends on the wing, power, flap system (manual/electric) etc. Possibly even because of the slight yaw resistance that the open gear doors provide.

[goldeneagle]

It does depend a lot on the aircraft, in particular, what type of flaps it has. Take the case of a C-421, they are split flaps, provide drag, do not provide any lift. That's completely different than something like the Seneca with a Robertson stol kit I flew many years ago, which has full span fowler flaps that provide a truckload of lift, and not as much drag. With that sucker, for a short field takeoff, you use 40 degrees of flap, and with a load on, uses about the same amount of runway as a super cub.

So to the original post, you say retract the flaps to the takeoff setting, then the rest later, that implies the aircraft was not a typical light twin used for training, ie a duchess or such, they use 0 flap for takeoff, at least they did back in the 80's when I was instructing on them.

What kind of aircraft was used for that test ?

Another example of 'know your aircraft'. I was taken aback at FliteSafety when they taught us to leave the gear down until clear of the obstacle with the 421 in the engine failure takeoff scenario. Turns out, they were right. Selecting gear up causes the doors to all open, and that creates a crapload of drag. As the instructor put it, if you aren't going to clear that obstacle with the gear down, you absolutely are not going to clear it with the doors open and gear in transit.

[Big Pistons Forever]

A personal pet peeve is the preponderance of made up FTU procedures I see in flight schools, many directly contrary to the POH/AFM think it is very important that students at all levels know what is in the POH and follow its directions.

Yes, good point. We were discussing similar just the other day. Point of discussion: is there a point in time where the AFM guidance becomes stale and modern common sense starts taking over? For example, the original Piper Cub POH had the "10 commandments of safe flying" that included things like, "THOU SHALT NOT PERFORM AEROBATICS AT LOW ALTITUDES" and "THOU SHALT MAINTAIN THY SPEED LEST THE EARTH ARISE AND SMITE THEE". Is this really as governing as something written in a modern Cessna POH? Another example (I forget which type) discussed how it's perfectly safe to fly through thunder storms as long as you keep the wings level and ride it out.

Looking back at my post I think it was unnecessarily blunt and thus worked against what I was trying to articulate. I am personally becoming quite frustrated at FTU-isms that at best are lazy and at worst are negative training which probably contributed to my disrespectful reply. With respect to your question re flap retraction as a PE my expectation is that the candidate conform to the procedures in the POH. So if the POH says flaps up then I expect that the candidate will retract the flaps all the way up and not in stages. If it were not safe to do so then I would expect the POH to say that, like for example the expanded emergency procedures for the single engine go around in the Piper Navajo or even the Cessna 172 balked landing procedure. None of the common ME trainers have this requirement AFAIK.

That being said as an examiner if the candidate wishes to deviate from a POH procedure I will ask them to explain their reasoning why the procedure or action is desirable and take that into consideration. A good example is many POH's tell you to reset circuit breakers for electrical systems emergencies. If a candidate refused to consider a reset while actioning the emergency checklist do that and explained it was contrary to TSB and TC recommendations than I would be quite happy to approve that deviation from the emergency checklist for obvious reasons.

As a generalization an explanation that references procedures for another airplane particularly a more complex one will generally be unpersuasive. I am evaluating their performance flying the test airplane and only the test airplane. My personal experience for this class of airplanes is that following the POH procedure works the best with the caveat that the manually operated flaps on the Piper products needs to move in a slow deliberate manner not slammed up.

[Bede]

Absolutely agree on the "FTU-isms". But there can also be "PE-isms". Case in point: flight test candidates expected to memorize emergency checklists. Obviously there are memory items. But, if a student didn't use a normal procedures checklist, that would be graded as a 1. However, when it's even more critical that items don't get missed, some examiners expect the student to work from memory for the emergency checklist. Seems backwards IMO.

[7ECA]

As a generalization an explanation that references procedures for another airplane particularly a more complex one will generally be unpersuasive. I am evaluating their performance flying the test airplane and only the test airplane. My personal experience for this class of airplanes is that following the POH procedure works the best with the caveat that the manually operated flaps on the Piper products needs to move in a slow deliberate manner not slammed up.

As previously posted the Seneca III single-engine balked landing procedure says flaps UP. But, the two-engine balked landing says flaps retract slowly...

So while I appreciate the idea that there can be caveats, your previous posts made it seem as though it was the POH procedure or a 1 will be assessed.

Also...

Absolutely agree on the "FTU-isms". But there can also be "PE-isms". Case in point: flight test candidates expected to memorize emergency checklists. Obviously there are memory items. But, if a student didn't use a normal procedures checklist, that would be graded as a 1. However, when it's even more critical that items don't get missed, some examiners expect the student to work from memory for the emergency checklist. Seems backwards IMO.

I recall in the run up to my ME flight test, being told that the examiner "preferred" candidates to have the emergency procedures memorized. During the actual in-flight portion of the test I referenced the emergency checklist (or at least got it out) to cover off the non-memory items which was met with minimal resistance. But, on the ground afterwards I was quizzed on a few "emergencies" and rattled off the procedures. I was then asked if these were memory items, or if I had memorized the checklist - to which I explained that I had memorized the emergency procedures but would reference the checklist to ensure all items had been covered that were not denoted as memory items. I was then asked to confirm via the checklist that I had correctly recalled the procedure for whatever hypothetical emergency was properly completed - which it was, and was assessed a 3 by the examiner for not referencing the checklist on a non-memory item emergency. Damned if you do, damned if you don't.

[Big Pistons Forever]

There is no doubt that standardization among PE's is a problem and that is on TC. Emergency checklists are particularly challenging. One thing I really like about the new build Cessna's is that the memory items in the emergency checklist are bolded so that there is no doubt about what should be memorized and what should not be. I will mark down candidates, especially CPL candidates if they perform non memory items by memory before consulting the written checklist.

The problem with Piper checklists is that they they just list the emergency actions without differentiating them them. One local school requires the candidates to memorize the engine fail checklist the the cause checks and the feathering and engine shutdown checks which is 28 items for the Piper twin trainer they operate.

Personally I think that is a very poor practice but I will not penalize them because there is no clear POH direction on checklist use. It doesn't help that all the popular twin trainers were built in the 1970's or early 1980's and their POH's predate all modern checklist human factors research.

That being said candidates still have to know what emergency checklists exists. I have had several ME rating flight tests where I gave a system failure and the candidate did not know there was an emergency checklist for it.

[Big Pistons Forever]

As previously posted the Seneca III single-engine balked landing procedure says flaps UP. But, the two-engine balked landing says flaps retract slowly..

Sigh. What does "slowly" mean. Another massively unhelpful Piper POH That being said if the flight test airplane was a Seneca 1 (4200 lbs MGTOW ) and the candidate is following a procedure for the Seneca 3 (4750 MGTOW) I would ask the question on whether the weight difference has resulted in a change of procedure which also may be due to the fact that the Seneca 3 flaps are larger and are electrically powered versus the manual Johnson bar on the Seneca 1. In that particular case however I would be reluctant to mark a candidate down given that they are different versions of the same model and would instead bring up the issue with the instructor and CFI. If the reason given is because that's what you do on a Beech 1900 as happened on one ride I did than the conversation is not going to go as well.

[digits_]

I will mark down candidates, especially CPL candidates if they perform non memory items by memory before consulting the written checklist.

Based on what? The flight test guide doesn't seem to prohibit it. It doesn't specifically allow it, but it does say this:

Throughout the flight test, the candidate is evaluated on the use of an appropriate checklist. Proper use
is dependent on the specific task being evaluated. The situation may be such that the use of the written
checklist, while accomplishing the elements of an “Aim”, would be either unsafe or impractical. Certain
elements may be executed by memory. In this case, a review of the checklist will be carried out after the
elements have been accomplished.

Flying a twin engine airplane without autopilot single crew would make a good case that it can be quite impractical to dig up the checklist for an emergency and it might be better to deal with it first from memory, and then when time allows it, get the checklist to verify if you forgot anything.

The flight test guide mentions in a lot of spots certain actions that must be done from memory, but doesn't prohibit you from doing everything from memory before consulting a checklist.

I don't know of any commercial pilot flying light aircraft single pilot who will take a checklist as a first response to any emergency. You're likely flying by hand, with pax in the back, possibly low level or in the vicinity of clouds. You'll try to deal with the emergency, and if all else fails, you'll take the checklist to see if you forgot something.

[Big Pistons Forever]

I don't know of any commercial pilot flying light aircraft single pilot who will take a checklist as a first response to any emergency. You're likely flying by hand, with pax in the back, possibly low level or in the vicinity of clouds. You'll try to deal with the emergency, and if all else fails, you'll take the checklist to see if you forgot something.

Well that would be me. There are many procedures in POH's and AFM's that do not have memory items because instant action isn't required and fast hands can make the situation worse. Electrical malfunctions are a good example where conducting the checklist items in the right order can be vital to properly address the failure.

[digits_]

Let's take this c172 sp as an example: https://wayman.edu/files/C172S-G1000-POH.pdf

It is relatively modern, and has bold memory items. I think that meets your criteria?

Note that none of the emergency landing checklists have memory items. Are you truly going to mark down a CPL student because he doesn't use the checklist before deciding he needs flaps for landing?

Or when he evacuates before taking the checklist when his engine catches fire during start?

When there's smoke in the cockpit after you've extinguished the fire, you'll breathe in the smoke and take the checklist before opening the vents again? Assuming you can even find and read the checklist.

Electric trim runaway: you can't release the disconnect button until you run the checklist. Better hope you can find the correct page with one hand.

Passing out from carbon monoxide? Can't open the window until you run the checklist...

So please allow me to ask again: based on what guidance in the flight test guide would you dock points?

[7ECA]

As previously posted the Seneca III single-engine balked landing procedure says flaps UP. But, the two-engine balked landing says flaps retract slowly..

Sigh. What does "slowly" mean. Another massively unhelpful Piper POH That being said if the flight test airplane was a Seneca 1 (4200 lbs MGTOW ) and the candidate is following a procedure for the Seneca 3 (4750 MGTOW) I would ask the question on whether the weight difference has resulted in a change of procedure which also may be due to the fact that the Seneca 3 flaps are larger and are electrically powered versus the manual Johnson bar on the Seneca 1. In that particular case however I would be reluctant to mark a candidate down given that they are different versions of the same model and would instead bring up the issue with the instructor and CFI. If the reason given is because that's what you do on a Beech 1900 as happened on one ride I did than the conversation is not going to go as well.

The Seneca III that I flew during my rating had manual flaps, but later models did indeed have electrically operated flaps. Depends on the aeroplane. Having said that, I think you're arguing semantics when it comes to what "slowly" refers to in relation to retraction of manual flaps. The manual flap Seneca III had four flap positions, UP, 10°, 25°, and 40°. As I recall, 40° was generally only used for short field landings, but in the event you've got everything hanging out and need to go around you wouldn't just slam the handle "down" and hope for the best. So hug the detents and maintain a positive rate. I'd be less concerned during a two-engine balked landing for obvious reasons about flap retraction, but simulated or actual single-engine ops you really should raise the flaps SLOWLY. Mind you, if you're going to follow the POH to the letter, Piper advises against single-engine balked landings...

I mean, it's not really any different than in a C172 R where if you've got 30° hanging out, and if you flip the lever to 0°/UP versus selecting 20°/10° the transit time is still "slow". And yet, many models of the 172 state to retract the flaps in "stages", or on application of power in a balked landing to retract to 20° and then raise to 10°...

[CpnCrunch]

Sigh. What does "slowly" mean. Another massively unhelpful Piper POH

I assume it means in stages, not all at once.

I just checked the Seminole POH, and it just says "flaps up". However, when training at Victoria Flying Club they have their own specific procedures to follow for every multi engine flight test procedure, which basically tell you precisely how you're meant to do the item. For the single engine go around it says (from their 2021 procedures):

- Pitch aircraft to climbing attitude while advancing the throttles to full power
- Retract Flap to 25 degree
- When positive rate of climb is established, retract landing gear (minimum 88 KIAS)
- Retract Flap to 0 deg.
- At 400' AGL or safe altitude, reduce to climb power and continue with normal climb procedure.

[Big Pistons Forever]

Digits

How do you teach the use of the emergency checklist on a C172S ?

[digits_]

Digits

How do you teach the use of the emergency checklist on a C172S ?

Perform memory items from memory, you're allowed to perform the other actions from memory as well, but you need to verify it with the checklist once you're done and if still possible (eg, plane didn't burn down)

I notice you seem to avoid answering my question: "Based on what guidance in the flight test guide would you dock points for performing checklist items from memory assuming they get verified with a checklist later on?"
I think it's a very fair question to ask from an examiner.

[Big Pistons Forever]

If the emergency had a checklist with no memory actions and the candidate memory performed all the actions in the same order as the checklist and actioned any notes (eg for C 172 the note on the electrical power system malfunction for the low volt light) and then verified that all actions had been performed by consulting the checklist, I would mark the exercise as a 3. If all actions were performed by memory and actions were missed or performed out of order before consulting the checklist and then corrected and If the missing out out of order action did not pose a flight safety hazard a 2, otherwise a 1. If there was a missing action that was not corrected after being performed by memory and after consulting the checklist a 1.

Modern human factors research has shown that memorized actions are the most likely to be missed or performed incorrectly. Memory checks should only be used for time sensitive actions during critical phases of flights. With respect to the C 172 the student could be told to memorize every single action of every check which in total is about 110 items. Personally my experience has been that this is difficult for students to do and they are unlikely to remember them all in 6 months But it is more likely they will remember the 27 bolded items which covers the really important and time sensitive actions required to deal with a significant emergency.

I follow this up with the checklist protocol which is now pretty much considered the best practice for checklist use

1) Know what checklist what emergency checklists are in the POH, so that if there is no checklist for what is happening you won't waste time looking for one that isn't there

2) Commit the memory items to memory

3) When using a checklist with memory items, complete the memory items by memory and then consult he checklist starting at the top and confirming all the memory items were completed and then continue with any non memory items on the checklist

4) For emergencies where the checklist has no memory items go to straight to the checklist and perform the actions detailed on it

Finally I emphasize the importance of flying the airplane first. The memory actions should stabilize the immediate danger to the airplane so the airplane needs to be in a stable flight path and clear of terrain obstacles before getting any checklist out. I will also note that there are things that can happen that don't have an associated checklist and in those circumstances the student will have to use their systems knowledge to come up with a reasonable plan of action.

[digits_]

If the emergency had a checklist with no memory actions and the candidate memory performed all the actions in the same order as the checklist and actioned any notes (eg for C 172 the note on the electrical power system malfunction for the low volt light) and then verified that all actions had been performed by consulting the checklist, I would mark the exercise as a 3.

Does that mean that they can't get a 4? Why not? What guidance/error/mistake are they making according to the flight test guide?

Modern human factors research has shown that memorized actions are the most likely to be missed or performed incorrectly. Memory checks should only be used for time sensitive actions during critical phases of flights.

Was that research done single pilot or multi crew? That's a huge difference.

With respect to the C 172 the student could be told to memorize every single action of every check which in total is about 110 items. Personally my experience has been that this is difficult for students to do and they are unlikely to remember them all in 6 months But it is more likely they will remember the 27 bolded items which covers the really important and time sensitive actions required to deal with a significant emergency.

Nobody is telling students have to memorize all checklists. You mentioned you were penalizing if they execute the checklist from memory if they happened to know it. That's a big difference.

I follow this up with the checklist protocol which is now pretty much considered the best practice for checklist use

1) Know what checklist what emergency checklists are in the POH, so that if there is no checklist for what is happening you won't waste time looking for one that isn't there

2) Commit the memory items to memory

3) When using a checklist with memory items, complete the memory items by memory and then consult he checklist starting at the top and confirming all the memory items were completed and then continue with any non memory items on the checklist

4) For emergencies where the checklist has no memory items go to straight to the checklist and perform the actions detailed on it

Finally I emphasize the importance of flying the airplane first. The memory actions should stabilize the immediate danger to the airplane so the airplane needs to be in a stable flight path and clear of terrain obstacles before getting any checklist out. I will also note that there are things that can happen that don't have an associated checklist and in those circumstances the student will have to use their systems knowledge to come up with a reasonable plan of action.

That might all be true or be a good idea, but it's not specified in the flight test guide. You have to admit it's starting to look like you're applying 2 standards:
1) You don't like it when FTUs make up their own procedures, however
2) You penalize candidates for not following your logic with respects to checklists, even though what they are doing is not violating the flight test guide(s). Which means that the candidate's score will depend on the examiner that shows up. That's on you, not on them.

[Big Pistons Forever]

The test guide requires the candidate to complete the emergencies actions correctly. If they don't they they get a 2 or 1 depending on the severity of the consequences of the mistake. If they they immediately launch into the actions of an emergency checklist even though the check has no memory items and gets all the actions right and follows up going through the checklist they get a 3. They don't get a 4 because IMO as an examiner safety margins were reduced. Since the check has no immediate action requirements because it has no memory items the candidate is less likely to make a mistake if they start with the checklist rather than relying on the checklist assuming there are no other factors which would require precipitate action. It is not unsafe but it is not as safe as it could be therefore a 3.

I know nothing I am going to say will make you happy but I have a question for you. Checklist protocols have changed dramatically since since I started flying commercially in the mid 1980's. They are informed by significant human factors research. One consistent finding is the challenges of doing emergency actions by memory hence the wide spread adoption of a checklist protocol that dictates actioning emergency check lists that have no memory items by going directly to the checklist. Do think in a situation where there is no immediate risk it is better to action an emergency checklist with no memory actions by memory followed by reviewing the checklist after the actions have been completed or going directly to the checklist and completing the actions and why ?

Flight instructors have a choice. They can expose students to modern flight safety concepts or not. I think they should but that at the end of day I as a PE can't make them however I am empowered to make decisions on the safety of any part of a flight test which will often have a level of subjectivity.
If a candidate truly feels that they should have gotten a 4 instead of 3 in the circumstance I described above they can complain to TC. If they got a 2 or 1 then they made a major or critical error which involved a objective failure to correctly complete a checklist. Again they can complain but I am confident that I have adequate objective grounds for the mark.

[digits_]

They don't get a 4 because IMO as an examiner safety margins were reduced.

Then you should have given them a 1... That's the only score according to the flight test guide appropriate for reduced safety margins.

I know nothing I am going to say will make you happy

There are a lot of things you could say that would make me happy. Something along the lines of "I admit it seems a bit hypocritical to complain about inconsistent FTU sops while I myself penalize students for not doing things my way" or "Yes, in basic trainers it might sometimes be counterproductive to force checklist usage"

but I have a question for you. Checklist protocols have changed dramatically since since I started flying commercially in the mid 1980's. They are informed by significant human factors research. One consistent finding is the challenges of doing emergency actions by memory hence the wide spread adoption of a checklist protocol that dictates actioning emergency check lists that have no memory items by going directly to the checklist. Do think in a situation where there is no immediate risk it is better to action an emergency checklist with no memory actions by memory followed by reviewing the checklist after the actions have been completed or going directly to the checklist and completing the actions and why ?

In a multi crew environment, I do not disagree with you. In a single pilot environment it might be very impractical and downright silly to go through checklists if you know all you have to do is flip one switch. Especially in single engine trainers, there is very little, if anything, that you can screw up that can't be undone.

I am not aware of any substantial research that has focused on single pilot checklist management. It's a completely different environment than a 2 crew cockpit. You need to fly the plane first. You simply can not be as attentive when reading and interpreting a checklist as in a two crew environment where the other pilot is flying.

Going back to my 172 list of emergencies above. can you truly say it would be less safe to complete those items without a checklist?

Flight instructors have a choice. They can expose students to modern flight safety concepts or not. I think they should but that at the end of day I as a PE can't make them however I am empowered to make decisions on the safety of any part of a flight test which will often have a level of subjectivity.

Subjectivity, fine, but here you're making a conscious black and white decision. The student is following a checklist strategy that is implied to be allowed by the flight test guide, but not up to your interpretation of a safe flight.

Here's the thing though: I can guarantee you that the FTU sneaking some B1900 sops into a seminole training will have the same good intentions at heart and truly believe they are safer.