About OML and OSL restrictions

[Alda]

Hi gals and guys !

I have been reading the PPrune forums since a few years, but this is the 1st time I post in a thread here so I guess I have to present myself before explaining the problem.

I am a French CPL pilot, with all the blessed sacraments and a valid class 1 since 2007. Last year I have been diagnosed a problem, which cause me to get my class 1 refused for three months. Now, I got my licence back with an OML restriction to my class 1, and an OSL restriction to the class 2. This is probably permanent restriction, even if I am not sick nor have any symptoms. I have total normal life and can do sports. (they used the umbrella rule, I mean the precautionary principle :*).

I read all the OML subjects in this forum, but find only partial answers to my questions so I'm trying to find some more help.

I have some relative experience, but nearly zero hours in real JAR25 multicrew operating : five years and 450H as FAF combat system officer on fighter jet, and about 550H doing some aerial work, instruction and my training courses.

Considering all that I invested (training for CPL-IR/MCC, FI, time, money, etc.), and of course a 20 year's passion, would it be realistic to believe I can fly again and get paid for this ? I obviously can't work anymore in solo crew jobs nor in instructing since the condition are very restrictive for an ATO to employ me.

Also I have been recently refused to an airline selection because of the OML restriction : this german airline doctor told us that the airline must have a third pilot to get me flying with my restriction, which I do not understand. OML only require a second fully qualified pilot, so this 2d pilot could be the TRI captain during the AEL, couldn't he ?
Is it a german rule which is more restrictive than the Aircrew, or did I misinterpretated the part MED statements ?

Thank you for reading this "pavé", any information or advice would be appreciated since I'm feeling lost in what decision to take.

I am open to constructive critics so feel free to post if it's pertinent.

Cheers

[Chris Opperman]

The crucial missing part in this post is the reason why a multicrew restriction was placed on your license. Without that information no-one can discuss the issue.

[cavortingcheetah]

Why should the underlying problem be relevant unless advice is sought on the possible success of an appeal? There are many reasons for an OML restriction to a Class 1 medical but possibly and of much more concern, is the imposition of an OSL to a Class 2 medical. That surely means that not only is the applicant license type restricted by virtue of medical certificate (CPL/ATPL) but also that the applicant cannot hold an Instrument Rating which, afaik, requires an unrestricted Class 2 medical.
http://www.caa.co.uk/docs/1859/20080926LimitationGuidanceV6.pdf

[Alda]

I don't think the information is relevant Chris but I can answer in private if you want.
And cavortingcheetah, I have my IR.Mep which is current.
From what I understood from a private message, there's no more restriction in Germany with OML than in any other country, so I guess that the airline just don't want to be bothered with a restricted pilot...

[cavortingcheetah]

Yes indeed, further burrowing reveals no apparent requirement for an unrestricted Class 2.
https://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=1303

[wondering]

@Alda,

I reckon if the airline has a choice of suitable applicants they won´t bother with someone who has a restriction. Do you mind sharing the airlines name?

Good luck with your next applications.

[Sygyzy]

To clarify 'wondering's' post a little further, and your first.

If you are accepted by an airline for training, normally you start with a safety pilot and after a few sectors he's not required and it'll just be you and the training captain. In your case they would have to keep the safety with you until you're checked out/cleared to operate on your own due to your OML restriction - I believe this is what the doctor was referring to. This is all extra cost to the airline when they have many (hundreds of) licensed pilots banging at their door with no restrictions.

Also if they already have another OML (who may have a temporary restriction but whose been with them for sometime) this is likely to create a roster/crewing headache that they'd rather not have.

I think that you're between a rock and a hard place and to convince an airline to spend more than they have to is going to be an uphill struggle. :sad:

[Denti]

Interesting, why would an OML restricted pilot need a safety FO for the whole training? Yes, he may operate only as qualified FO or with a qualified FO, however once the correct license and type in said license is issued he is deemed qualified, isn't he? And the rating is entered into the license after the completion of ZFT or base training.

The rostering issues exist, but they are usually a non issue in sufficient large airlines.

[Narrow Runway]

An OML is an OML, is an OML ad infinitum.

It doesn't matter what it relates to. All are treated the same:

In essence, you won't be able to act as a single pilot for reward. In addition, you won't be able to fly with other people who have an OML in commercial ops. Also, you won't be able to fly with over 60's.

So, quite restrictive.

I have an OML, seeing as I had a rare cancer. This has been cured. But, I have an OML and the UK CAA won't remove it. Period.

Airlines can and do reject on the basis of OML's. It is a hassle for crewing to have to work around you, due to the reasons given above.

I have not been able to apply to easyJet because of it. I have been rejected in the Middle East because of it. Take your pick, it is just another means to filter applicants.

My advice; you won't get into big airlines with an OML (generally speaking, but not always). I'd aim for smaller airlines with a personal touch in HR, or the corporate aviation arena......

[wondering]

I wonder when this two OML´s not flying together will be scraped. What are the chances (even for two OML´s with the same condition) becoming incapacitated on the same flight? Considering EASA medical standards are now more in line with FAA standards and with the FAA having thousands of special issuance medicals with relevant experience on file for years, I guess very close to 0. But, what do I know? Flying in EASA land must be so much safer than on the other side of the pond :}

[maxed-out]

I have a question regarding OML too. UK CAA scenario only.

What would happen to someone with a current unrestricted class 1 and a current Single Pilot Multi Engine IR that subsequently gets an OML. Would they then be allowed to do a Multi pilot Type Rating or does the OML invalidate the the SP-MEIR and thus preclude entry onto a Type rating?

Cheers.

Mods, I'm happy to move this to another section if needed.

[Denti]

Also, you won't be able to fly with over 60's.

Do you have a source for that? It isn't handled like that over here, nobody cares about age in regards to OML. Just the two OML cannot fly together rule is used and that is not a big issue with single digit number of OMLs in well over 1000 pilots in my company.

[Alda]

If you are accepted by an airline for training, normally you start with a safety pilot and after a few sectors he's not required and it'll just be you and the training captain. In your case they would have to keep the safety with you until you're checked out/cleared to operate on your own due to your OML restriction - I believe this is what the doctor was referring to.

@Sygyzy : That is precisely the type of information I am searching for. You are maybe talking about the same thing as this doctor. Do you have any ideas where could I find references about that ? I believed that with the type rating I would be considered as "qualified".

@Denti : It brings us to your answer :

Interesting, why would an OML restricted pilot need a safety FO for the whole training? Yes, he may operate only as qualified FO or with a qualified FO, however once the correct license and type in said license is issued he is deemed qualified, isn't he? And the rating is entered into the license after the completion of ZFT or base training.

So that is really what I would like to know. I'm into emails and phone exchanges since 2 weeks with the french DGAC Medical pole and the main Aemc, but I have no answer yet as a lot of people are on holidays...

Is the line check is mandatory before getting fully "qualified", regarding the OML definition in the part MED ? Or does the end of the type rating and base training would be sufficent ?

For your information, here are the quotes from the Aircrew part-MED.B.001 : SUBPART B, REQUIREMENTS FOR PILOT MEDICAL CERTIFICATES, SECTION 1, General, from 25.11.2011 (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ%3AL%3A2011%3A311%3A0001%3A0193%3AEN%3AP DF)
MED.B.001 Limitations to medical certificates

(d) Operational limitation codes

(1) Operational multi-pilot limitation (OML — Class 1 only)

(i) When the holder of a CPL, ATPL or MPL does not fully meet the requirements for a Class 1 medical certificate and has been referred to the licensing authority, it shall be assessed whether the medical certificate may be issued with an OML ‘valid only as or with qualified co-pilot’. This assessment shall be performed by the licensing authority.

(ii) The holder of a medical certificate with an OML shall only operate an aircraft in multi-pilot operations when the other pilot is fully qualified on the relevant type of aircraft, is not subject to an OML and has not attained
the age of 60 years.

(iii) The OML for Class 1 medical certificates may only be imposed and removed by the licensing authority.

(2) Operational Safety Pilot Limitation (OSL — Class 2 and LAPL privileges)

(i) The holder of a medical certificate with an OSL limitation shall only operate an aircraft if another pilot fully qualified to act as pilot-in-command on the relevant class or type of aircraft is carried on board, the aircraft is fitted with dual controls and the other pilot occupies a seat at the controls.

(ii) The OSL for Class 2 medical certificates may be imposed or removed by an AeMC or AME in consultation with the licensing authority.


Here are the quotes from the Acceptable Means of Compliance
and Guidance Material to Part-MED1 (EASA) : (http://easa.europa.eu/system/files/dfu/AMC%20and%20GM%20on%20the%20medical%20certification%20of%20p ilots%20and%20medical%20fitness%20of%20cabin%20crew.pdf)
GM1 MED.B.001 Limitation codes

OML: Valid only as or with qualified co-pilot
This applies to crew members who do not meet the medical requirements for single crew operations, but are fit for multi-crew operations. Applicable to class 1 medical certificates only.

OSL : Valid only with safety pilot and in aircraft with dual controls
The safety pilot is qualified as PIC on the class/type of aircraft and rated for the flight conditions. He/she occupies a control seat, is aware of the type(s) of possible incapacity that the pilot whose medical certificate has been issued with this limitation may suffer and is prepared to take over the aircraft controls during flight. Applicable to class 2 and LAPL medical
certificates only.

@Narrow Runway : Thanks for your point of view.

@maxed-out : Your question is interesting since I am obviously in this case. I don't know if this is an issue.

Many thanks guys for participating.

Cheers

[cavortingcheetah]

http://www.caa.co.uk/docs/1859/20080926LimitationGuidanceV6.pdf

Page 3 refers?

[Narrow Runway]

Yes, I have a source, UK CAA. My licensing body.

[Denti]

@Alda, thanks, that helps.

@Narrow Runway, sadly the UK CAA in quite a few cases still deviates from the common european rules and therefore a text source, preferably in EU legislation rather than in UK CAA opinion, helps quite a lot more.

[mudcity]

Trying to establish the meaning of 'qualified co-pilot' for someone flying with an OML restriction.
Can a TRI with an OML restriction -UK licence- conduct line training on a type such as B737 with a f/o under training without a safety pilot ? I.e. Does qualified mean have completed type rating or completed line training as well ?

[cavortingcheetah]

MED.B.001 (d) (1) (ii)
“The holder of a medical certificate with an OML shall only operate an aircraft in multi-pilot operations when the other pilot is fully qualified on the relevant type of aircraft, is not subject to an OML and has not attained the age of 60 years.”
i.e. we lost the argument – 2 pilots with OML
limitation cannot operate together EASA industry briefings

From here:

http://www.caa.co.uk/docs/620/20120426EASASymposiaFlightCrewMedicalRequirements.pdf

Dr Nigel Dowdall is the medical #1.

[Tova]

I wonder if somebody has an answer to the question that maxed-out has asked before, as i am in this situation :

quote :" I have a question regarding OML too. UK CAA scenario only.
What would happen to someone with a current unrestricted class 1 and a current Single Pilot Multi Engine IR that subsequently gets an OML. Would they then be allowed to do a Multi pilot Type Rating or does the OML invalidate the the SP-MEIR and thus preclude entry onto a Type rating?"


Thus I'm flying multi-pilot operations on a single pilot certified helicopter and recently got an OML restriction, can the SP endorsement stay on the license or does it need to be replaced by a MP endorsement? :confused:

Thanks for the advice!