Freelance Flight Crew and OCC | EASA
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Freelance Flight Crew and OCC | EASA
Dear all,
Good afternoon.
At my current operator we are experiencing some issues related to the usage of Flight Crew Members on a freelance basis.
Our NAA is absolutely requesting that each and every FCM shall have the OCC carried out before commencing any duty with the company as well as an OPC.
I don't quite read exactly this in ORO.FC and I can't find any further explanation regarding this.
Does any of you guys have experience in this issue?
Thank you.
Good afternoon.
At my current operator we are experiencing some issues related to the usage of Flight Crew Members on a freelance basis.
Our NAA is absolutely requesting that each and every FCM shall have the OCC carried out before commencing any duty with the company as well as an OPC.
I don't quite read exactly this in ORO.FC and I can't find any further explanation regarding this.
Does any of you guys have experience in this issue?
Thank you.
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ORO.FC.120 Operator conversion training
(a) In the case of aeroplane or helicopter operations, the flight crew member shall complete the operator conversion training course before commencing unsupervised line flying:
(a) In the case of aeroplane or helicopter operations, the flight crew member shall complete the operator conversion training course before commencing unsupervised line flying:
(1) When changing to an aircraft for which a new type or class rating is required;
(2) When joining an operator.
It does not differentiate between freelance or permanent pilots; therefore a freelance pilot would need to complete the OCC prior to flying unsupervised on the line.
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Hi.
Probably I didn't manage to get myself understood, sorry.
There are no doubts regarding the need for the OCC. The question is if an OCC mandates an OPC.
Rgds.
Probably I didn't manage to get myself understood, sorry.
There are no doubts regarding the need for the OCC. The question is if an OCC mandates an OPC.
Rgds.
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ORO.FC.220 details the required content of the operator conversion training course and (d)(1) states that a flight crew member must complete an operator proficiency check as part of that course.
Last edited by Don Coyote; 9th Jul 2016 at 17:12.
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Don Coyote,
Thanks for your replies.
Those parts relating to EASA Air Ops we do know. However, those parts, as so many in the EASA Air Ops are somehow, at least, on grey area.
Our question was relating to people having more experience on this issue.
Our FCM perform their OPCs in an approved ATO (normally CAE or FlightSafety). If we employ a freelancer, he will be doing an OPC in one of those approved organisations.
If we incorporate a FCM on freelance and he does the our OCC and he has an OPC carried out in one of those approved ATO why shouldn't his previous OPC count as credit for the OCC with us? Does it make any safety-sense to force him to do another OPC?
What if he just did his OPC 2 months ago, for instance?
Regards.
Thanks for your replies.
Those parts relating to EASA Air Ops we do know. However, those parts, as so many in the EASA Air Ops are somehow, at least, on grey area.
Our question was relating to people having more experience on this issue.
Our FCM perform their OPCs in an approved ATO (normally CAE or FlightSafety). If we employ a freelancer, he will be doing an OPC in one of those approved organisations.
If we incorporate a FCM on freelance and he does the our OCC and he has an OPC carried out in one of those approved ATO why shouldn't his previous OPC count as credit for the OCC with us? Does it make any safety-sense to force him to do another OPC?
What if he just did his OPC 2 months ago, for instance?
Regards.
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Because an OPC is an OPERATOR proficiency check, and should be performed in accordance with company specific standards and procedures, as detailed in the OM.
That's what we were told also by our authority.
That's what we were told also by our authority.
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Agreed dirk85,
But when your OPC is performed in the usual way by the ATO (without specifics of the Operator) why should we get the pilot to do another one that is going to be exactly has the one he just did?
Is safety in aviation increased but such requirement?
I don't see the rationale behind this...
If we guarantee that we will only hire freelancers that have had their OPCs performed in the ATO we normally work for and if we request detailed information regarding his latest OPCs from the ATO I believe in doing so we guarantee an equivalent level of safety.
I just can't find a reason to justify such requirement.
But when your OPC is performed in the usual way by the ATO (without specifics of the Operator) why should we get the pilot to do another one that is going to be exactly has the one he just did?
Is safety in aviation increased but such requirement?
I don't see the rationale behind this...
If we guarantee that we will only hire freelancers that have had their OPCs performed in the ATO we normally work for and if we request detailed information regarding his latest OPCs from the ATO I believe in doing so we guarantee an equivalent level of safety.
I just can't find a reason to justify such requirement.
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The ATO should be tailoring and completing the OPC specific to each AOC operator; the OPC they complete for a different AOC Operator will probably be subtly different due to different SOPS, standard calls, different decision making skills (DODAR, TDODAR etc) and so on.
A freelance pilot operating for two different AOCs would therefore need to do two different operator specific OPCs.
There is no such thing as a generic OPC.
A freelance pilot operating for two different AOCs would therefore need to do two different operator specific OPCs.
There is no such thing as a generic OPC.
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If I may as a trainer who know pretty well both FSI and CAE, ok there should be no such thing as a generic OPC...but not all companies have the size, ressources, will or competency to tailor a proper OPC.
On top of that most operators now use the SOPS given by the manufacturer (ex CODDE FALCON) so there shall be not a lot of differences.
Frankly it makes more sense to me to give a short line training to a new guy than to send him to CAE/FSI to attend an OPC if no one from the company is attending with him.
But EASA pretends that all corporate are the same than airlines and everybody keeps pretending rather than focusing on what would really be good for the corporate world...
On top of that most operators now use the SOPS given by the manufacturer (ex CODDE FALCON) so there shall be not a lot of differences.
Frankly it makes more sense to me to give a short line training to a new guy than to send him to CAE/FSI to attend an OPC if no one from the company is attending with him.
But EASA pretends that all corporate are the same than airlines and everybody keeps pretending rather than focusing on what would really be good for the corporate world...
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@Don Coyote,
There is no de facto generic OPC, but in reality what most small operators do is a generic OPC with any of the available organisations that provide such training & checking.
We use the manufacturers' SOPs with no differences at all.
@gumpy972,
Spot on, sir. Spot on.
And we will keep on pretending that we are improving safety levels when we are not. And EASA is the number 1 actor in doing so.
Our intention would be to have them do our OPC's Ground School part (which is tailor made and makes all sense that any crew attends such classes before release to line), then carry out a Line Check with one of our trainers to confirm proper normal operation and HF issues.
With regards to the OPC, if the pilot had it in one of the facilities we have contract with we would request from the pilot authorisation to assess his training file on the ATO and assess if we would be suitable for the job.
With this we would stop wasting tonnes of euros in ATOs performing OPCs one after the other and we would have an equivalent level of safety.
Does it make sense? In my humble opinion I believe it does if things are done professionally and with the correct mindset.
With the current regulation, EASA is treating small businesses as if they have the size and complexity of BA and the likes and with that the money that should be in the pilots pockets is in the ATOs pockets.
It's bureaucracy running the show. And surprises me more is that some of us, pilots, agree with that set of rules.
Regards to all.
There is no de facto generic OPC, but in reality what most small operators do is a generic OPC with any of the available organisations that provide such training & checking.
We use the manufacturers' SOPs with no differences at all.
@gumpy972,
Spot on, sir. Spot on.
And we will keep on pretending that we are improving safety levels when we are not. And EASA is the number 1 actor in doing so.
Our intention would be to have them do our OPC's Ground School part (which is tailor made and makes all sense that any crew attends such classes before release to line), then carry out a Line Check with one of our trainers to confirm proper normal operation and HF issues.
With regards to the OPC, if the pilot had it in one of the facilities we have contract with we would request from the pilot authorisation to assess his training file on the ATO and assess if we would be suitable for the job.
With this we would stop wasting tonnes of euros in ATOs performing OPCs one after the other and we would have an equivalent level of safety.
Does it make sense? In my humble opinion I believe it does if things are done professionally and with the correct mindset.
With the current regulation, EASA is treating small businesses as if they have the size and complexity of BA and the likes and with that the money that should be in the pilots pockets is in the ATOs pockets.
It's bureaucracy running the show. And surprises me more is that some of us, pilots, agree with that set of rules.
Regards to all.
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And we will keep on pretending that we are improving safety levels when we are not.
If you ask CAE or FSI to do a "standard" check they will apply LPC standards. This is the standard expected of a low hour F/O straight from his type rating course. In any sane world a company should expect its Captains to be more competent than this, but many companies do not make any effort to apply this.
This results in quite a few pilots flying around thinking that what they are doing is great, beacause they have spent the last x years being told that what they are doing is fine when it is actually barely marginally competent.
but not all companies have the size, ressources, will or competency to tailor a proper OPC
Will - not sure there are too many where this is the only issue, more down to the last one:
Competency - this is the main issue. There are lots of operators who really have no idea of what they are trying to achieve. Unfortunately, the OP would appear to be in this category or he wouldn't be asking the question. It does make you wonder what the NAAs are doing issuing Form 4 approvals to people who don't know their job, but then many NAAs haven't a clue either so it shouldn't be a surprise.
