Twiglet1
ORO.FTL.105 says person is a crew member or passenger….if not a passenger the crew member will remain an operating crew member all flight and even rest counts in full as FDP ( as you said) but then but also says and for purpose of ORO FTL.210( which is referring to monthly and yearly limits.
bottom line is what is purpose of having limits if we can relabel it and say for example all flying above 20,000 fleet doesn’t count-
now we can schedule someone 2000 hours per year
they may have 5 star service but they are 1 star on safety when it comes to fatigue