BIK, it was my understanding that you are correct, however it was pointed out to me that the wording was changed in an amendment back in 2000 I think. In reading that page, i.e. 48.1 1.1 and 1.3, it says nothing about behest of employer anymore. Plainly says that "calculations of flight and duty time limitations made under the provisions of section 48.1 shall take into account any flight and duty time performed in the course of private operations" So if you are required to account for flight and duty times, as per sect. 48, i.e commercial pilot, I would have thought that it now requires you to record and account for all flying time and duty time. I do recall that our previous Operations Manual did differentiate between commercial and private operations, but that was not Sect. 48. And as I said we were "advised" to amend manual to accord with the CAO's. Dunno, what you think?