View Full Version : Pilot qualification to operate in either pilot’s seat (EASA)
Hello all,
I'm looking for some advice on the practicalities of complying with ORO.FC.235 Pilot qualification to operate in either pilot’s seat in an EASA mixed-fleet scenario:
Commanders whose duties require them to operate in either pilot seat and carry out the duties of a co-pilot, or commanders required to conduct training or checking duties, shall complete additional training and checking as specified in the operations manual.
[...]
In the case of helicopters, commanders shall also complete their proficiency checks from left- and right-hand seats, on alternate proficiency checks, provided that when the type rating proficiency check is combined with the operator proficiency check the commander completes his/her training or checking from the normally occupied seat.
Given the following:
Dual rated pilots
Captains are scheduled as copilot approximately 30% of the time
OPC combined with type rating proficiency check every 6 months
Would I be correct by interpreting this as:
Captains must change seats on alternate checks, because they fly as copilot 30% of the time
The seat swapping is on alternate checks on the same aircraft type. Given that alternate types are checked every 6 months, it would end up being:
Type 1 Left Seat
Type 2 Left Seat
Type 1 Right Seat
Type 2 Right Seat
and so on
When the check is conducted in the left seat, the training must be done in the right seat - to satisfy the "normally occupied seat" requirement
If anybody is able and willing to share how they are managing the practicalities of this under EASA I would be most grateful!
Hi 178
The regs only say you can combine type rating PC and OPC once every twelve months so do the left seat OPC when you are not doing the type rating proficiency check would be my suggestion.
Cheers
TeeS
advent
12th May 2020, 14:52
I’m really not certain of your need .. Or indeed the absolute question you ask.. But, in these current times and I must stress that for the last 20 years I have flown aircraft under rules that allow me to fly both seats.. Norwegian Airlines for example, (nope, don’t fly there.. far to small) !.. (Weight of aircraft alone, apologies) qualify all their Captains (well almost all of them) to fly both seats .. It’s not so difficult when you consider most cars today are designed to be driven from the right !
So, apologies but what was the question?
Hello TeeS,
Many thanks for your reply. In the interests of full disclosure, we are operating under a regulatory framework based upon what was JAR-OPS 3.
When we run into a hiccup it often helps to see how EASA is doing things.
Would you happen to have an EASA reference for only being able to combine an OPC and PC once per year?
Hello advent,
Sorry for any confusion. It isn't an issue of whether pilots are able to fly in both seats. It is a matter of how best to comply with the regulations for doing so.
To rephrase: How would an EASA helicopter operator, using 2 different multi-crew types, arrange the seating during OPC & PC training / checking to ensure that the pilots were complying with ORO.FC.235?
hueyracer
12th May 2020, 18:13
Pilots in commercial operations must conduct two check flights a year-a license proficiency check (annually) and an OPC.
In addition to that, a 12 monthly Line check needs to be carried out as well.
While the OPC and License proficiency check can be done interchangeably, the Line check is something different.
Most operators have an approved program to qualify pilots to fly in either seat, at a minimum, a certain number of landings and an auto rotation must be carried out from the other seat (usually it is required to carry out one opc from the other seat to be qualified).
Thereafter, each OPC should be carried out from the opposite seat.
Does that help?
Edit:
Just seeing that this might be misunderstood.
Of course there must be an opc every 6 months, of which one can be the License Proficiency check, and one line check within 12 month.. Hope that clarifies what I failed to explain better before..
Hi 178
The reference is AMC1 ORO.FC230(b)(1)(iii) is the reference and states:
(iii) Once every 12 months the checks prescribed in (b)(1)(ii)(A) may be combined with the proficiency check for revalidation or renewal of the aircraft type rating.
I realise that is not 'technically' in the regulations but hope that helps.
Cheers
TeeS
Hi hueyracer
Many thanks for the reply. From what you describe it sounds like EASA is still the same as old JAR-OPS 3 with regards to the timing of checks.
It also seems that it is necessary under EASA to swap seats (as well as doing additional training) on alternate OPCs if you fly from both seats. I can see how that would work nicely on a single type
Every 6 months:
OPC/LPC (right seat)
OPC (left seat)
OPC/LPC (right seat)
OPC (left seat)
I'm curious how it works when you throw a second type into the mix. If you alternate seats every 6 months you are always in the same seat on a particular type.
Every 6 months:
OPC/LPC on 1st type (right seat)
OPC/LPC on 2nd type (left seat)
OPC/LPC on 1st type (right seat)
OPC/LPC on 2nd type (left seat)
Or, if you make sure you alternate on each type:
OPC/LPC on 1st type (right seat)
OPC/LPC on 2nd type (right seat)
OPC/LPC on 1st type (left seat)
OPC/LPC on 2nd type (left seat)
Or is the only option to not combine OPC/LPC?
I hope that makes sense!
Many thanks again TeeS, that's very useful. I don't recall seeing that in our AMC. Do you happen to recall if it was the same under JAR-OPS 3?
hueyracer
13th May 2020, 06:18
If you are flying different types (which is limited now by authorities, under commercial operations, the number of type ratings on complex helicopters is limited to anything up to 3 types only), the seats need to be changed not on every opc, but on every other opc on that type.
January Type 1 left seat
March Type 2 Left seat
July Type 1 right seat
September Type 2 right seat
For example.
That is IF the pilot is required to operate from each seat, which should only be the case for certain long line operations or while flying with PICUS/Line Training without being an instructor...
Instructors will be qualified to fly Pic from the left seat anyway....
Mustapha Cuppa
13th May 2020, 07:32
Many thanks again TeeS, that's very useful. I don't recall seeing that in our AMC. Do you happen to recall if it was the same under JAR-OPS 3?
Appendix 1 to JAR-OPS 3.968 may be helpful.
hueyracer
13th May 2020, 11:39
You are not by any chance operating out of Romania?!
Apate
13th May 2020, 11:52
which should only be the case for certain long line operations or while flying with PICUS/Line Training without being an instructor...
Instructors will be qualified to fly Pic from the left seat anyway....
I think you'll find that offshore operators generally will qualify all pilots to fly from either seat. Well, the good ones do ;) ;) :E
hueyracer
13th May 2020, 13:49
That's not the way it's supposed to be in accordance with oil and gas procedures.
If an operator can afford experienced pilots on both seats, glad for him and the pilots..
But the requirements by OGP usually result in experienced Captains and young copilots......
OGP auditors usually want to see pilots in their dedicated seats with exception to the training as required by the ops manual...
.
If you are flying different types (which is limited now by authorities, under commercial operations, the number of type ratings on complex helicopters is limited to anything up to 3 types only), the seats need to be changed not on every opc, but on every other opc on that type.
January Type 1 left seat
March Type 2 Left seat
July Type 1 right seat
September Type 2 right seat
For example.
That is IF the pilot is required to operate from each seat, which should only be the case for certain long line operations or while flying with PICUS/Line Training without being an instructor...
Instructors will be qualified to fly Pic from the left seat anyway....
Thank you again hueyracer.
The left-left-right-right is about where we had got to with it. The problem is then making sure that the 6 monthly OPC is done in the pilot's normally occupied seat, because all our OPCs are combined with LPCs.
Although from the reference TeeS has kindly given, it sounds like combining every OPC/LPC wouldn't be possible under EASA without agreeing alternative means of compliance.
Appendix 1 to JAR-OPS 3.968 may be helpful.
Thank you Mustapha Cuppa. Appendix 1 to JAR-OPS 3.968 is mostly aligned with what we have in our regs. I don't see the "once every 12 months" requirement, either in Appendix 1 or any AMC, so I guess that's a new one for EASA?
You are not by any chance operating out of Romania?!
No, there are no EC155s around here! ;)
I think you'll find that offshore operators generally will qualify all pilots to fly from either seat. Well, the good ones do ;) ;) :E
Which brings us back to the intention behind this requirement (to change seats on alternate checks).
Interpretation 1: it only applies to LTC/TRI/TRE, or captains who need to fly from the left seat for a specific operational reason e.g. long line. In all these cases, the pilot is acting as commander of the flight, but from the left seat.
Interpretation 2: it applies to anyone who finds themselves flying in either seat for whatever reason. This would include a captain who happens to be flying in the left seat, as a copilot, for another captain.
Do we have a consensus on which interpretation is correct under EASA?
Aucky
13th May 2020, 22:09
Thank you again hueyracer.
The left-left-right-right is about where we had got to with it. The problem is then making sure that the 6 monthly OPC is done in the pilot's normally occupied seat, because all our OPCs are combined with LPCs.
Although from the reference TeeS has kindly given, it sounds like combining every OPC/LPC wouldn't be possible under EASA without agreeing alternative means of compliance.
Thank you Mustapha Cuppa. Appendix 1 to JAR-OPS 3.968 is mostly aligned with what we have in our regs. I don't see the "once every 12 months" requirement, either in Appendix 1 or any AMC, so I guess that's a new one for EASA?
No, there are no EC155s around here! ;)
Which brings us back to the intention behind this requirement (to change seats on alternate checks).
Interpretation 1: it only applies to LTC/TRI/TRE, or captains who need to fly from the left seat for a specific operational reason e.g. long line. In all these cases, the pilot is acting as commander of the flight, but from the left seat.
Interpretation 2: it applies to anyone who finds themselves flying in either seat for whatever reason. This would include a captain who happens to be flying in the left seat, as a copilot, for another captain.
Do we have a consensus on which interpretation is correct under EASA?
section 2.3.10.3 (p29) of this NPA may help https://www.easa.europa.eu/sites/default/files/dfu/NPA%202019-08.pdf
The commander needs to be qualified in whichever seat they occupy. If they are not the commander they don’t under EASA, for the moment anyway.
Commander is not their company rank it is their assigned duty. If they are commander but acting copilot and the copilot is flying PICUS then they would need an OPC in the seat they occupy as per Part ORO. If they are actually the copilot for a flight and the other pilot is the commander (not PICUS) then they are not the commander and needn’t be specifically qualified to occupy that seat.
tu154
14th May 2020, 08:58
That's not the way it's supposed to be in accordance with oil and gas procedures.
OGP auditors usually want to see pilots in their dedicated seats with exception to the training as required by the ops manual...
.
Not my experience of North Sea operations (one operator but aware at least one other also qualifies crew in both seats from day one), or an OGP audit. Ops manual is also written in this way.
/thread hijack...
Apate
14th May 2020, 10:12
Not my experience of North Sea operations (one operator but aware at least one other also qualifies crew in both seats from day one), or an OGP audit. Ops manual is also written in this way.
/thread hijack...
Totally agree. Hueyracer is making this up and then making his opinions sound like fact. :ugh:
hueyracer
14th May 2020, 10:25
Nope, not making this up.
Have a look at relevant documents regarding OGP crew requirements (e.g. GS ES LSO 131).
Having done several audits with OGP auditors, they always were looking for crews fulfilling their requirements.
While they were always happy to have two "Commanders" fly on one helicopter, they were also clear on the use of Copilots in their dedicated seats, stating that a copilot-before being allowed to fly "right hand seat" needs to be close to being upgraded to Commander.........
If things work differently in the North Sea-great, good for you.....
I will stick to my opinion that a "commander" is not an "instructor"-hence should not "train" someone (unless authorized to do so by Company procedures, e.g. as Line Training Captain).
Apate
14th May 2020, 11:31
Nope, not making this up.
Have a look at relevant documents regarding OGP crew requirements (e.g. GS ES LSO 131).
Having done several audits with OGP auditors, they always were looking for crews fulfilling their requirements.
While they were always happy to have two "Commanders" fly on one helicopter, they were also clear on the use of Copilots in their dedicated seats, stating that a copilot-before being allowed to fly "right hand seat" needs to be close to being upgraded to Commander.........
If things work differently in the North Sea-great, good for you.....
I will stick to my opinion that a "commander" is not an "instructor"-hence should not "train" someone (unless authorized to do so by Company procedures, e.g. as Line Training Captain).
I have no idea what that reference is you stated. I use the IOGP AMGs as a reference.
"Commander" ....... see Auckys post above. By definition you can't have two Commanders fly an aircraft!
The Commander obviously isn't by default an "instructor", never said he was.
I have a simple question - what difference does it make in which seat the Commander sits? There's plenty of good reasons to allow flexibility; including choosing who will conduct the offshore landing (recency, difficulty, etc) and familiarity of both sides of the cockpit when upgrading to P1.
What a shame some operators like to live in the dark ages :ugh:
hueyracer
14th May 2020, 12:02
What a shame some operators like to live in the dark ages :ugh:
Wow, you really must have missed out on the CRM course where they taught proper communication.....
I see it from a different point of view:
Yes, you cannot have two "Commanders".
I was referring to two "Captain´s" in the cockpit (read this as "Two company approved and qualified Captains"), of which only one can be PIC.
Think about this:
An operation where both crew members just fulfill the requirements.
A young Captain holding an ATPL, and a young Copilot with his CPL/ATPL-Theory.
Why would you put a young copilot into the PIC seat?
The aircraft manual (at least on the types i fly; not sure about other helicopters) specify which seat is the "PIC-seat" (e.g. on Bell 412, the aircraft is designed to be flown by one Pilot in the RHS).
Therefor-from a safety point of view-it makes all sense to put the Copilot into the left hand seat, and let the Captain fly from the right-agreed?
Then, at a later point-when the copilot has gained experience, knows the area and company procedures, and has seen dozens, if not hundreds of proper approaches, he will also have gained enough hours to be ready for his upgrade training.
This is where either an instructor will fly with him in the right seat (no "seat issue" there), or a Captain with approval to conduct Line training (Line Training Captain).
Why should a pilot who is not a training Captain or an instructor fly in a "Copilot seat"?
Apate
14th May 2020, 12:29
Simples - there's no such thing as a "co-pilot seat" or a "PIC seat".
Let's agree to disagree. You've said nothing to make me change my opinions!
Variable Load
14th May 2020, 13:22
As someone who has held both Ops and Training postholder positions on the N Sea, I totally agree with what Apate has stated so far.
As far as I am aware, there is nothing in the OGP guidelines that restrict which seat the Commander or P2 has to occupy. Whilst auditors may have opinions, unless it is in regulation or published guidelines then they are not enforceable.
The fact that the UK CAA are happy that operators manage who sits in which seat also speaks volumes.
As someone who started their career in the '80s, having gone through a command upgrade and change of seat, I am firmly of the opinion that this is not a sensible process. When swapping seats for the first time it feels like you are flying in a totally new aircraft, as everything is different. It is like some sort of twisted initiation process!
To pick up on Apate's other point in favour of flexible seating, maintaining offshore landing recency can be a major challenge, especially night recency. To be able to choose which pilot will likely have to complete the landing is a major benefit.
Having seen both ways of operating, I know which one I favour - by a country mile.
hueyracer
14th May 2020, 18:47
I understand your scenario-but how do you deal with that in real life?
Do a weather briefing, then decide who is taking which seat?
What if the wind changes during the flight?
There was an old document many years ago, stating that take offs and landings should be carried out by the Captains only, who would fly from the RHS (in most helicopter, that is the "PIC" - seat).
Reason behind that was the attention span and reaction time in an incident/accident situation.
The seconds it might take you to look for a switch that is not where you are used to because you are not sitting on your usual seat was sometimes leading to catastrophic scenarios..... Or let's talk about flights in bad weather at night, where some switches have to be moved "blind"...
There are pros and cons-but it helps looking at how the airlines are doing it....
They don't have Copilots fly in the "Captains seat" for a reason... And to me, that makes sense (like I said, with the exemptions I mentioned before..)..
malabo
14th May 2020, 20:19
Hueyracer, you don’t have to wonder how it would all work without the crushing weight of EASA busywork. In Canada and other regulatory jurisdictions there are no separate checks for left or right side, no restriction on what side you sit, no restriction of switching PF-PH on final because it is going to work out better that way, from either seat. Flew EMS & Offshore for 30 years like that, question never came up until we encountered Europeans, which adapted without problems. Dual controls, dual instruments, how hard can it be? Sounds to me like some rigid-minded airline background bureaucrats wrote their antiquated and irrelevant notions into your EASA rules. Thread drift, the OP just wants to know how to comply, but then justifying the regs is a weak case.
Variable Load
14th May 2020, 21:39
Hueyracer, you don’t have to wonder how it would all work without the crushing weight of EASA busywork. In Canada and other regulatory jurisdictions there are no separate checks for left or right side, no restriction on what side you sit, no restriction of switching PF-PH on final because it is going to work out better that way, from either seat. Flew EMS & Offshore for 30 years like that, question never came up until we encountered Europeans, which adapted without problems. Dual controls, dual instruments, how hard can it be? Sounds to me like some rigid-minded airline background bureaucrats wrote their antiquated and irrelevant notions into your EASA rules. Thread drift, the OP just wants to know how to comply, but then justifying the regs is a weak case.
Malabo, there's a few small hoops to jump through in EASA-land, but nothing great. Heuyracer seems to be creating a proverbial mountain out of a molehill. I'm really struggling to understand his stance!
I agree with Variable load this is making a mountain out of a molehill.
The whole purpose of the OPC - be it JAR-OPS or EASA - is to establish the competence of pilot in role. The testing of handling competence in either seat should be undertaken in the most practical way. Normally (the exception when PICUS is being conducted), only captains are tested in both seats. That way a reasonable ratio of captains to co-pilots can be achieved to allow efficient flight and duty time allocation. The regulations were formulated to make this as easy as possible.
On two-crew helicopters, the roles of pilot flying and pilot monitoring are shared. These roles should be assigned to establish a fair sharing of flying and the safety of the operation. Where this is important - for example to a heliport where the landing surface is approached into wind and from the side with the best-field-of view - the roles might be swapped in flight at an appropriate time to allow a safe transition.
When not in training - be that type training, role training, line training or PICUS - command is allocated in accordance with procedures set out by the operator. In the absence of any specific instructions (for example for monitored approaches), the role of pilot flying or pilot monitoring is normally decided by the crew members on the day.
The days of the commander hogging the flying or making cross cockpit approaches should be well behind us.
Jim
Wow, that elicited quite the discussion. I'm not sure if that is a good or a bad thing!
Thank you very much for the replies everyone. My apologies for rather selfishly swinging it back to my original query:
Is it fair to say that if a pilot, for whatever reason, can expect to be flying as commander from either seat station during the course of their duties, then they must swap seats every other OPC? It isn't sufficient to simply do an element of training from both seats.
And on the occasions that they do their OPC in "the other seat" (normally the left) it cannot be a combined OPC/LPC.
Is that about the measure of it?
hueyracer
15th May 2020, 19:07
Yes, that's the way I understand the rules...and the way I have applied it.throughout the past 20 years..