Originally Posted by
AvSec
I don't think the FAA or the regs observe terms like "Captain" and "F/O".
The regs use terms like PIC and although your contract equates PIC with captain, the regs do not. Ability to " Hold captain" and "Seniority" are not conditions of regulatory compliance.
Correct, the regulation does not state "captain" it states that a simulator check airman must complete all the training required to "serve as pilot in command...in operations under this part
(121)".
FAR 121.412 also states that simulator instructors must have completed the same training. The only difference in 121.411 (c), which covers simulator check airmen, and 121.412 (c), which covers simulator instructors, is the requirement in 121.411 (c) for a simulator check airman be approved by the administrator (ie. the Check Airman Letter from the POI).
Still have not found a way around this other than using a 142 certificate to conduct training, either by using a separate training entity all together, or by creating a separate training division that has a 142 certificate like Delta has with Delta Global Services; or by using medically disqualified/past age 65 pilots, who participate in the Line Observation Program. Neither of these are the case with this airline. Most checking events and all recurrent training events are conducted by first officers who have not completed upgrade training (IOE & Fed Ride).