EASA PPL(H) OSD R22 & 44

[boffo]

On a recent Flight Instructor seminar, we were informed that since last December, it is now a requirement that a student NOT be sent solo (in a 22 or a 44) until he/she has at least 20 hrs dual. This number apparently comes from Robinson - it's in the Operational Suitability data published on their website.

I'm finding it difficult to discover exactly which bit of EASA or CAA "law" makes this compulsory. There is some reference to it when discussing Type Ratings, but I teach PPL(H) at an RF, not an ATO.

Anyone any ideas?

If you have, please could you let me have the reference(s)?

Most Kind,
Boffo

[memories of px]

ring dorothy pooley in shoreham

[staticsource]

It's not a requirement. It's a recommendation by CAA/EASA/OSD, sooooo if you are unfortunate to have an accident with a solo student and he only has, say, 15hrs they may ask some awkward questions.

I suppose it's about risk mitigation and YOU reducing risk to as low as possible.

References:

OSD
SFAR 73
AIC P066/2013

Hope this helps 👍

[hueyracer]

The OSD are recommendations....we must make sure that they never become requirements-otherwise the rotary industry in Europe will be dead.

No one can afford a 20 or 35 hours minimum type rating course.....

[BillieBob]

The OSD are recommendations

Not quite, the OEB reports were recommendations but the OSD is not. From the Robinson OSD, for example:

In accordance with Commission Regulation (EU) No 69/2014 of 27 Jan 2014, the Operational Suitability Data contained in this document are identified as follows:
[M] .Mandatory Operational Suitability Data, bearing the status of rule (see GM No 3 to 21A.15(d))
[AMC] Non-mandatory Operational Suitability Data, bearing the status of Acceptable Means of Compliance (see GM No 3 to 21A.15(d))

The requirements for pre-solo experience and instructor qualification are both marked [M]

No one can afford a 20 or 35 hours minimum type rating course

The requirement for 20 hours before solo applies only to pilots who do not hold a licence (i.e. it applies to PPL students not to the type rating).