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F/Os as 121 sim check airmen?

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F/Os as 121 sim check airmen?

Old 11-06-2012, 05:54 PM
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Default 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.
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Old 11-06-2012, 07:52 PM
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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?
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Old 11-06-2012, 10:18 PM
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Originally Posted by rickair7777 View Post
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?
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.
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Old 11-07-2012, 06:47 AM
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Originally Posted by pilatusguy View Post
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.
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.
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Old 11-07-2012, 09:11 AM
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Originally Posted by rickair7777 View Post
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.
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.
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Old 11-07-2012, 09:15 AM
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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.
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Old 11-07-2012, 10:26 AM
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It doesn't smell right to me either.
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Old 11-07-2012, 07:32 PM
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Originally Posted by pilatusguy View Post
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.
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Old 11-07-2012, 08:18 PM
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Originally Posted by pilatusguy View Post
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;

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.

Last edited by xjtguy; 11-07-2012 at 08:30 PM.
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Old 12-05-2012, 08:46 PM
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I met United FO on the commute home who said he used to be a sim instructor.
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