Originally Posted by
Blueskies21
That's the best argument I've seen to support block vs flight.... you're absolutely correct 121.436 a.3 itself says "hours" which fully supports your argument. However 121.436 c says "(c) For the purpose of satisfying the flight hour requirement in paragraph (a)(3) of this section, a pilot may credit 500 hours of military flight time obtained as pilot in command of a multiengine turbine-powered, fixed-wing airplane in an operation requiring more than one pilot." There's no other hour requirement in (a)(3) except the 1000 hrs, so I think we're forced to conclude that must be a flight hour requirement.
You're also correct as far as I know about there not being a block hour limit in 121 or 117 but I'd still be careful about logging more than 9 hours a day in my logbook because I'm not real interested in having a block hour vs flight hour discussion in an interview. As we all know, block hour logging has been the standard but we didn't have a good way to track flight hours, now we do.
"The company tracked aircraft movement for legality, for consistency I have always logged aircraft block time, this was also the company approved method of logging."
It's pretty easy to explain. Of course, if you log time by the leg the chances of anyone adding up daily flight time in the first place to see what it added up to is between slim and none.
I log by the 1/10th of the hour for my logbook, but legality is done by the minute since that is available. Thus when I was limited to 10 hrs in a day earlier in my career, I have days with more than 10 hrs as measured the 10th, but under 600 minutes so still legal.
If you're still caught up in this legality question, you need to get an actual FAA response. You could also ask the company if the FAA has signed off on this method (if it's in the FOM the FAA has signed off on it and that is the legally expected method of logging). What will be more likely to get you in trouble is changing how you log time based on how it suites you (IE, log by block until you approach 9 hours in a day and then logging movement because you are afraid of having more than 9 hrs in the logbook).
If the FAA has signed off on a method, regardless of how you like to interpret the regulations, you are legally able to use it.