I know this is an old thread but I’ve been debating some of these questions recently and viewing the overlap between employment law and aviation regulations and struggling to see how airlines are able to legally charge for Type Ratings that include the non-delegable OCC components and are run to company SOPs! It seems very much like cost shifting, disguised employment and debt bondage to me.
I also noted the mention of safety throughout the thread and thought this recent article in the guardian may be of interest if any one revisits this thread.
https://www.theguardian.com/global/2...es-study-warns
One has to ask how safe is it for a pilot who is in masses of debt to be expected to call fatigued when required even though they know their pay will be heavily deducted on a disguised 0 hour Line Training Contract.