Faire d'Income
May I commend you on your obvious intelligence: a tangible grasp of Leo's arguments indicates your comprehension of English, yet, your prejudices and raging belief that your opinion, not fact, please note, holds any water when you are patently incapable of validating your claims, does let you down somewhat.
You claimed that my statement about Ryanair being subject to audits and SAFA inspections was
. If that isn't is a clear, concise statement of your much vaunted opinion, perhaps you have had the opportunity to reflect and have accepted that, indeed they are audited and inspected as all JAA carriers are. Of course, if you still insist that your are 100% correct and I am 100% wrong, perhaps you would be kind enough to present some valid evidence to back up your allegation.
I do, however, detect a softening in approach as I have progressed from "not being a pilot" to being "unlikely to be a pilot" ! Keep this up and in 3 or 4 posts you could be of the opinion that I'm the Chief Pilot!!!
The Operations Manual is the de facto rulebook for any airline's pilots. Ryanair's OM is different to other carriers ergo Ryanair operate to different rules. For example this thread is about the new 'rule' at the 500' gate. No other Irish carrier, that I am aware of, has that rule. Different rule.
I reiterate: the Operations Manual contains procedures. The rules are laid down in JARs. The very first parargraph of JAR Ops 1 spells this out:
JAR-OPS Part 1 prescribes requirements
applicable to the operation of any civil aeroplane for
the purpose of commercial air transportation by any
operator whose principal place of business and, [if
any, its registered office] is in a JAA Member State
If you open your own company Ops Manual A, or Volume 1 and turn to Section or Chapter 8, the nomenclature varies by company, you will find that it is titled
"Operating Procedures": this is a copy of the first paragraphs from the FR Part A,Chapter 8. It is probably no different to your company manual.
8 OPERATING PROCEDURES
8.0 General Operating Procedures
8.0.1 Objectives
8.0.1(a) Our primary operations objective is to conduct our air transport activity safely. It
is also Ryanair policy that Flight Operations shall be conducted efficiently and
punctually. This policy devolves on Flight Crew as their basic duty.
8.0.1(b) Commanders and Co-Pilots are required to adhere to the policies and directions
contained in the Operations Manual.
Note however, the use of the phrase "
policies and directions"; not rules and regulations.
So willl you accept that Ryanair operate to the rules and regulations, but may have different policies and procedures?
One of those being the "landing gate"; this is a procedure which requires that the aircraft approach is stabilised at 500ft VMC and 1000ft IMC. I believe that bmi, and probably BA, also have a 500ft stabilised gate. The only modification to this policy / procedure which Ryanair use is a "500 -Continue" or "500 - Go Around" call. Your company " procedure" may be to call " Decide" at DA or DH; another company "procedure" may be to call " minimums" a third may decide that their "procedure" - to comply with the JAR "rules" will be to call "Land" or "Go Around".
Turning to the question of Inspectors flying as Commanders. If the airline and the Inspector have agreed that the Inspector may "fly the line" to remain current and operate as a Commander, that is quite different to flying on an inspection flight where the jumpseat would be occupied and the Inspector would be an observer.
If the Inspector has to regain his / her currency a flight with a TC or sim session would be in order, as per JAR "rules".
Your view of the rules seems to constitute only what the absolute state limits are. That is not the case for us flying the line. We are certainly bound by the state limits but we must remain within the parameters of the Operations Manual otherwise what is the point in having one?
Not at all. I was merely using the situation as an example. The hierarchy of rules, regulations and requirements form the umbrella. This can range from ICAO to IATA to JAR, EASA, State law to National requirements. The approval of the Operations Manual is predicated on the procedures and policies being at
least as restrictive but not
less restrictive than the regulations.
This where the 500ft procedure falls: it is more restrictive than the regulation, hence it is acceptable to the Authority. The example I used of the 100ft Cat 1 DH/DA is not and hence is not permitted as a "procedure".
As to refuelling procedures, an extract from the JAR is reproduced here:
[A two-way communication shall be
established and shall remain available by the
aeroplane’s inter-communication system or other
suitable means between the ground crew
supervising the refuelling and the qualified
personnel on board the aeroplane;]
Note the phrase "other suitable means". Ryanair management obviously decided, or the IAA decided, that the "other suitable means" previously utilised, in accordance with JARs required a review in the light of incidents reported or recorded. In that review the company or Authority is quite at liberty to impose a more specific instruction which meets the JAR. In this instance Ryanair decided that a member of the flight crew should supervise the refuelling whist in communication with the other crewmember via the interphone. The JAR always was complied with; the "procedure", or Acceptable Means of Compliance, was just different.
Your amazement was probably a result of scant knowledge of the rules and regulations, but an intimate reliance on your own "company" procedures.
You will, I trust, accept that there is more than 1 way to skin a cat, and acknowledge that FR are bound by the same rules and regulations. The procedures just differ slightly in achieving compliance.