IMC flight test

[Level Attitude]

Reference(s) to no Training given prior to Examining for IMC test

1)
Standards Document 21v1 September 2012 Part 1.2

"Examiners are certified by the CAA to conduct Skill Tests...............
The privileges and requirements of Examiners are set out
in EASA Part-FCL Subpart K"

So CAA has stated that (all) Examiners are governed by EASA and nowhere
in above does it say the "privileges and requirements" do not apply
if testing for a National Rating.

2)
IN-2012/157 EXAMINER INVOLVEMENT IN PILOT TRAINING AND TESTING

The above explains the changes due to implementation of EASA, but it does
not say it only applies to Part-FCL testing.

Specifically:

2.3 "Initial Issue...............................An Exmainer shall not conduct a skill test......to
whom he has given instruction"

The above paragraph does not even refer to EASA / Part-FCL


2.4 "Part-FCL Subpart K, FCL.1005 is mandatory in the UK. The previous CAA policy
as detailed in NOTEXA1-H1/2009 is withdrawn"

Again, no caveats given for National Ratings and:

FCL.1005 Limitation of privileges in case of vested interests
Examiners shall not conduct:

(a) skill tests or assessments of competence of applicants for the issue of a licence, rating or certificate:

The Rules changed on 17 September 2012.

I have provided two references as to why I believe an Examiner may not
conduct an initial IMC test on a candidate to whom they have also given
instruction.

For those who believe otherwise, please provide a reference.
I do not think just saying "It is a National Rating, of course you can" is sufficient.


NB: Stnds Doc 21 and IN-2012/157 would not copy and paste, hence abbreviated
quoting.