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F/Os as 121 sim check airmen?

FAR 121.411 states that check airmen (simulator) in an FAR 121 training program must meet the following qualifications:

(1) Holds the airman certificates and ratings, except medical certificate, required to serve as a pilot in command, a flight engineer, or a flight navigator, as applicable, in operations under this part;
(2) Has satisfactorily completed the appropriate training phases for the airplane, including recurrent training, that are required to serve as a pilot in command, flight engineer, or flight navigator in operations under this part;
(3) Has satisfactorily completed the appropriate proficiency or competency checks that are required to serve as a pilot in command, flight engineer, or flight navigator in operations under this part;
(4) Has satisfactorily completed the applicable training requirements of § 121.413; and
(5) Has been approved by the Administrator for the check airman (simulator) duties involved.

The way I read it a simulator check airman must:
1) Have an ATP and valid type rating.
2) Completed upgrade training, captain IOE and captain line check.
3) Have a regular captain PC.
4) Completed the academic requirements of FAR 121.413
5) Be approved as a check airman by FAA.

So is my interpretation correct? Does number 2 mean something different than I am reading? Can a POI approve a simulator check airman who has not completed captain IOE and a captain line check?

The reason I ask is there is a relatively new FAR 121 airline that is using first officers as simulator check airmen to conduct captain PC events. These are first officers who have not undergone captain upgrade. They are not contract instructors under an FAR 142 program, nor are they exempted under the age 65 or medical exemptions. To me this does not seem to jive with FAR 121.411.

Thanks for any input.

If you can get the POI to sign your OPSPEC, you can do all kinds of weird things.

But I'm not sure why the FAA would approve something like that. I've seen street-hire sim instructors do checkrides, but they all went through captain training when hired.

Are you sure they didn't attend upgrade training even though they can't hold CA by seniority?

Quote:

Originally Posted by rickair7777 (Post 1288688)

Yes, 100% sure they did not go through upgrade training. They are not contract instructors, they are not part of a 142 program, and they do not participate in the age 65/medical waiver Line Observation Program. Those to me seem to be the only exemptions to the above mentioned requirements.

Can a POI waive those requirements? Surely there are limits on what a POI can approve/waive.

Quote:

Originally Posted by pilatusguy (Post 1288724)

I don't know what the internal policy limits are for the POI's discretion on OPSPECs...at some point presumably he has to ask Washington. Maybe there is precedent for this somewhere else?

Are they actually giving PC's, or just sim training? There's generally a lower bar for trainers vs. checkers.

Quote:

Originally Posted by rickair7777 (Post 1288794)

They are giving PCs, both recurrent and for captain upgrades (captains are type rated as new-hires). They are also conducting captain upgrade sim training.

PS- I guess part of the reason I am asking is to see if there is precedent for this. I have seen FOs as sim instructors, but never as sim check airmen. Not at any airline I have been employed by, and I cannot find examples when asking friends at various other airlines as well.

I am thinking if this was okay, every airline would do because it is cheaper to pay FOs than it is captains.

It doesn't smell right to me either.

Quote:

Originally Posted by pilatusguy (Post 1288662)

So is my interpretation correct? Does number 2 mean something different than I am reading? Can a POI approve a simulator check airman who has not completed captain IOE and a captain line check?

The reason I ask is there is a relatively new FAR 121 airline that is using first officers as simulator check airmen to conduct captain PC events. These are first officers who have not undergone captain upgrade. They are not contract instructors under an FAR 142 program, nor are they exempted under the age 65 or medical exemptions. To me this does not seem to jive with FAR 121.411.

Thanks for any input.

Do you know for a fact they haven't gone through a captains course and had a fed check?

Even though they are FOs by seniority and bid status, airlines do run instructors through to qualify.

Quote:

Originally Posted by pilatusguy (Post 1288662)

The reason I ask is there is a relatively new FAR 121 airline that is using first officers as simulator check airmen to conduct captain PC events. These are first officers who have not undergone captain upgrade. They are not contract instructors under an FAR 142 program, nor are they exempted under the age 65 or medical exemptions. To me this does not seem to jive with FAR 121.411.

Thanks for any input.

Just curious, but you say "new airline". Could these FO's that are instructors be part of an initial cadre program? My previous company added both a new operating certificate as well as an aircraft type. Initial Cadre pilots are afforded a whole slew of exemptions. As far as the FAA is concerned, seniority doesn't matter. It's simply what the operator gets past the inspector;

Quote:

3-1427 APPROVAL OF INITIAL CADRE CHECK AIRMEN. During the early phases of establishing a check airman program, initial cadre check airmen are required. Initial check airman candidates must first become fully qualified as flight crewmembers and then be trained, evaluated, and approved as check airmen. Because the regulatory language of parts 121 and 135 does not address a training process for initial cadre check airman, this handbook provides guidance. This process that follows is valuable for startup operations for at least two reasons:
• It is a practical way to initiate and build a check airman program; and • It takes advantage of proving flights, when the operator/applicant is under close FAA
scrutiny—with desirable effects on the check airman program.
A. Letter of Request from Operator. The overseeing inspector must arrange with the operator/applicant to approve one or more likely check airman candidates to form an initial cadre of temporary check airmen. The operator/applicant will submit a letter of request, as described earlier in this section. This letter comprises the request for initial cadre check airmen and a description of the training that they will undergo.
B. Letter of Approval. The POI must approve the candidates using procedures described earlier in this section. Usually initial cadre check airmen are approved to function as check airman—all checks or check FE, so that they may conduct all types of checks and supervise Operating Experience (OE) during the period that the startup operation is beginning. The initial cadre check airman letter of approval is a temporary approval, to be replaced with a permanent letter of approval after the check airman is fully qualified. The initial cadre check airman letter must contain a statement similar to the following:
(Name) is approved as an initial cadre check airman to function as a check airman—all checks or as a check FE for the purpose of initiating operations with the (type of aircraft) for (name or operator). This approval expires on (expiration date).
3-1428 TRAINING, CERTIFICATION, AND QUALIFICATION—STARTUP. The operator must provide a full qualification process for its initial cadre check airmen.
7 UNCONTROLLED COPY WHEN DOWNLOADED Check with FSIMS to verify current version before using
3/11/09 8900.1 CHG 9
A. Initial Training and Certification. The operator must first arrange to have initial cadre check airmen trained and appropriately certificated for their cockpit duty positions. The operator may provide the training by contracting with a manufacturer, with another operator of the same 14 CFR operating part, or with properly qualified individuals. An inspector or an aircrew program designee designated examiner may certificate the initial cadre airmen, provided that the examiner is employed by a U.S. air carrier operator.
B. GainingProficiencyasInstructors.Aftertheinitialtra iningandcertification, initial cadre check airmen must become proficient in the operator’s proposed training program by instructing each other, or in the case of a single initial cadre check airman, by self-training. During this training, an operator may arrange for a pilot from the manufacturer, from another operator, or from another source to act as the safety pilot or instructor pilot.
C. Proficiency and Competency Checks. After the first initial cadre check airmen have become proficient as instructors, they may then begin the training and checking of other initial cadre check airmen in accordance with the operator’s initially approved flight training and qualification curriculum segments. Each check must be observed by an FAA inspector who holds the appropriate airman’s certificate, and the appropriate type rating, when applicable. If the inspector determines that the performance of an initial cadre check airman conducting a certain check is satisfactory, the inspector will recommend to the overseeing inspector that the airman be approved as a check airman for that type of check. One initial cadre check airman may check another, with the process repeated until each candidate has been approved as a check airman or has been terminated from the program. If only one person is being considered to be the initial cadre check airman, an inspector will observe that person conducting a check of another airman. If the candidate’s performance is satisfactory, the inspector must recommend to the POI that the candidate be removed from temporary status and approved for full-time check airman duty with the operator.
D. OE.
1) Initial cadre check airmen will be permitted to acquire OE flight hours on any flight that can be credited toward the proving-test flight-hour requirement (including training flights, ferry flights, and representative en route proving flights). OE flight hours may be accrued by initial cadre check airmen while they are:
• • • •
Conducting aircraft checks; Overseeing the OE of other airmen, Being checked, or Acquiring OE under the supervision of other initial cadre check airmen.
2) Initial cadre check airmen must receive a line check and conduct a line check during an en route proving flight or a ferry flight. The same process (above) will apply: one initial cadre check airman line checks another while being observed by an FAA inspector. If the airman’s performance is satisfactory, the inspector may recommend that the person be removed from temporary status and approved for full-time duty as a check airman for the operator. If there is only one initial cadre check airman, then the FAA inspector will conduct the line check.

I met United FO on the commute home who said he used to be a sim instructor.

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.

Quote:

Originally Posted by AvSec (Post 1305922)

I think that's true of nautical regs as well. The person in ultimate charge of a vessel is the "Master", even though usually referred to as "Captain".

Quote:

Originally Posted by pilatusguy (Post 1288863)

They are giving PCs, both recurrent and for captain upgrades (captains are type rated as new-hires). They are also conducting captain upgrade sim training.

I won't claim to be an expert by any stretch of the imagination and I've seen some strange things in aviation but in my 18+ years in a major airline 121 training environment, I've never heard of a First Officer giving PC's, recurrent and Captain upgrades.

United used Pilot Instructors (PI's) who were mostly F/O's by seniority, for sim training but they did NOT give check rides, type rides or PC's. They all had to go through a Captain's qualification, type ride and maintain a Captain's qualification during their stint "in the fleet" as a PI.

In other carriers, I've never heard of the scenario you mentioned.

Sounds very "fishy" to me.

G'Luck Mate

Quote:

Originally Posted by xjtguy (Post 1289192)

They are not part of the initial cadre program.

Quote:

Originally Posted by AvSec (Post 1305922)

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).

Long story short on this - the basic question is what training is required to serve as PIC in operations under part 121. From FAA legal - PICs under 121 operations are required to have completed all upgrade ground training, flight training and upgrade IOE. Sounds like this is not legal.

Quote:

Originally Posted by Phantom Flyer (Post 1307518)

Agreed..they all go through the entire Captain upgrade program to include IOE and a line check. They do not give MV or LOE rides. Just your basic sim sessions and FTD's.

I know for a fact that 4 current part 121 regional carriers are using former Comair pilots as check airmen.
I know that some of these pilots are FOs at these airlines, not contract or management pilots. I do not know about all of them.
These pilots bring many thousands of PIC hours to their new airlines in the exact aircraft they were flying at Comair.
Many of them were check airmen at Comair. Some were instructor pilots and some with just vast experience in the CRJ.
Could any of these be the pilots you are referencing?

New part 121? Or maybe a 121 airline already that is branching into new areas?

F/Os as 121 sim check airmen?

At my airline FOs are sim check airmen, but they must have completed the upgrade training. In fact all of the instructors who are FOs have completed upgrade training, including the LOE. They have NOT completed upgrade IOE or line check, but I'm not convinced that is required by the reg for simulator check airmen. Clearly it is for line check airmen.

In any case, since holding captain is merely a function of seniority (not experience or merit) then I'm not sure why it would matter if they are an FO or captain. You want the best men for the job, not the most senior men for the job.

At my airline we do have F/O sim check airmen as you call them. To be one you have to go thru the Captains course all the way thru IOE and the Final line check and activated. You are then required to pass a line check in the left seat every year and CQ check ride in the sim as a Captain. They are restricted by The company to only do CMV 1&2 currently but are signed by the FAA to do CLOE's also. They fly the line as FOs but can fly in the left seat if flying with another dual seat qualified pilot usually a LCA. They cannot make a Captain that requies a different FAA sign off.

Quote:

Originally Posted by HIFLYR (Post 1828788)

In the sense of this discussion they are not FOs, they are captains in every regulatory aspect. Where they happen to fall on the seniority list and what they get paid is irrelevant to the FAA.

Just answered a question as to FOs as sim check guys and yes sometimes they are.

Quote:

Originally Posted by Phantom Flyer View Post
I won't claim to be an expert by any stretch of the imagination and I've seen some strange things in aviation but in my 18+ years in a major airline 121 training environment, I've never heard of a First Officer giving PC's, recurrent and Captain upgrades.

United used Pilot Instructors (PI's) who were mostly F/O's by seniority, for sim training but they did NOT give check rides, type rides or PC's. They all had to go through a Captain's qualification, type ride and maintain a Captain's qualification during their stint "in the fleet" as a PI.

In other carriers, I've never heard of the scenario you mentioned.

Sounds very "fishy" to me.

G'Luck Mate

Phantom, your statement annotated in red is incorrect. Even under the old UAL system we had Type B PI's. Those are PI's who are examiner qualified. I was a type B PI and I can assure you that I have given multiple hundreds of "check rides" as in MV's for both trasition and PC crews and hundreds of transition PV's and hundreds of day 1 and day 2 PC's as well; See below.

Quote:

Agreed..they all go through the entire Captain upgrade program to include IOE and a line check. They do not give MV or LOE rides. Just your basic sim sessions and FTD's.

Gupboy,

In regards to the airline I fly for and legally speaking are absolutely 100% incorrect in your statement above.

I was a 777 PI for 6 years and am currently back in the building as a 76T/756 FI/E ( same thing different name now, as a Type B, PI).

An FI/E (Flight Instructor/Evaluator) can in fact give a PC and they do in fact administer PV's and MV's and requal 1,2,3 and landing requal. The ONLY check rides we can't administer by company rules are LOE's and type rides.

But as a matter of fact once you are Type B (FI/E, or check airmen qualified) the FAA considers you a designated examiner on that airplane. And in fact you are perfectly legal to administer type rides on that airplane type and I have done so for several airlines on a contract basis.

The FAA, as mentioned previously does not care what your seniority can hold at your airline. Once you are type rated you are legal to act as PIC and once you go through the proper training and take an FAA administered examiner's check ride you are legal to instruct and give type ratings on your specific airframe. It generally takes a new flight instructor about 18 months of instructing to become a full MV qualified examiner.

I hope this clears up the confusion a bit.

I'm a sim check airman at my company. I'm a line FO, but I've been through the upgrade sim training and type ride. I have not done upgrade IOE and I cannot fly in the left seat in the aircraft, though I can sit left seat for a sim event. (Seat support.)

So yes, it does happen. It actually seems fairly common.

Quote:

Originally Posted by Southerner (Post 1829409)

Been a long time since I was on here, and sorry to resurrect an old thread. But I thought I'd add some closure to this since I just re-read all this.

The personnel in question were only given a PC in the left seat. They did not go through the upgrade training program, neither upgrade ground school nor the upgrade simulator training. Just a normal PC, but given with them in the left seat. They were not given any OE or line training in the left seat either. I did consult with FAA legal about this, starting with an regional FAA legal office, and finally ending with the head FAA legal office in DC. After about six month of investigation, the FAA responded with: the intent of FAR 121.411/121.412 is that simulator instructors and simulator check airmen fully complete an airline's upgrade training program, and be fully qualified as captains. However the FAA does grant significant leeway to the operator's individual POI and their discretion about waiving certain aspects of the regulation in order to qualify people as instructors and check airmen. In short, "these are the rules, but since we made the rules, we can bend the rules".