Here's a thought why not do away with the requirement of CAO 82.3 Para 3.3 then it would no longer be an issue, other ICAO signatory states don't seem to have any issues with that concept.
Here's the FAA definition/version of a "Supervisory Pilot", although the yanks call it.."
AIR TRANSPORTATION FLIGHT INSTRUCTOR—AIRCRAFT":
3-1399 AIR TRANSPORTATION FLIGHT INSTRUCTOR—AIRCRAFT. An air transportation flight instructor in an aircraft may be a pilot instructor, a FE instructor, or both, and may also conduct flight training in a SIM, FTD, or ground training.
A. Eligibility. An instructor candidate airman must meet the following eligibility requirements:
·Hold the certificate and ratings required to serve in revenue service in the specified crewmember duty position on the specific aircraft except that the certificates and ratings are not required for training programs approved under § 121.409(b) (simulators).
·Hold a valid third‑class medical certificate (FAA Form 8500-9) for operations conducted under part 91 such as aircraft training and aircraft ferry operations.
·Meet currency requirements to serve as the PIC for the operator or as FE for the operator, including ground and flight training, proficiency or competency checks, and (for pilots) 90-day landing currency.
·For pilots, must complete an annual line check or line observation module of a recurrent qualification curriculum segment.
·Have received flight instructor qualification training under the operator’s approved training program, including the training required by §§ 121.411, 121.413, and appendix H, or §§ 135.337 and 135.339, as applicable.
·Maintain line currency as a flight deck crewmember with the operator, or be line familiar with the operator’s procedures and line operation by participating in a line observation program that the operator’s POI has approved. (Refer to the current edition of AC 120-35 for a discussion of terms.) For those instructors and check airmen who maintain line currency, holding a medical certificate appropriate to the crew position occupied on the line is a requirement.
B. Authorized Activities. An air transportation flight instructor in an aircraft, when authorized by the employer, may conduct the following flight instruction activities:
·Flight instruction for airmen in an aircraft in flight, including instruction in giving appropriate preflight and postflight briefings.
·Certification of the satisfactory performance of an airman after completion of a flight training curriculum segment or flight training module.
·When authorized by the operator, ground instruction and certification of the satisfactory completion by an airman of a ground training curriculum segment.
Ahh but that would be too logical wouldn't it and how could we trust the Operator to administer such a hair-brain scheme!
