Ems Pilots Practicing Instrument Approaches without a Safety Pilot..
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Ems Pilots Practicing Instrument Approaches without a Safety Pilot..
I have flown for 2 Large EMS companys in the USA and meet a lot of VFR 135 pilots that will practice instrument approaches with medical crew on board on way home (no Patient on board). Which is good to try to stay up to speed with IIMC Emergency Practice. But I try to explain that as per FAA Part 91 Regs you have to have a safety pilot rated on board with duals , If you plan to log it as an approach/currency etc, especially if you let it show on company records(Duty Flight Records , Golden Hour or 411 etc for FAA.
I do understand we all do it , with crew looking out etc, to just go thru the motions, but remember if you log it somewhere that records it for FAA oversight they will ding you if you are doing it with crew and no qualified safety pilot.
You will be surprised at how many high time pilots and managers think it is fine just to use the crew as observers and go practice approaches on your way home after a patient flight. Like I said we all do it, but dont log it, cos its not legal to do so.
All fine until something goes wrong. You could have something completely unrelated go wrong and it may be noted that you were conducting IFR Practice Approach at time ,( Especially if crew dont like you they will say you were practicing an instrument approach at the time you had a bird strike or near miss or struck by asteroid....
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Also if you are doing it with vectors from approach or PAR etc. FAA will put it down to the fact you were doing something you were not legally able to do at time of incident.
you get the drift
I do understand we all do it , with crew looking out etc, to just go thru the motions, but remember if you log it somewhere that records it for FAA oversight they will ding you if you are doing it with crew and no qualified safety pilot.
You will be surprised at how many high time pilots and managers think it is fine just to use the crew as observers and go practice approaches on your way home after a patient flight. Like I said we all do it, but dont log it, cos its not legal to do so.
All fine until something goes wrong. You could have something completely unrelated go wrong and it may be noted that you were conducting IFR Practice Approach at time ,( Especially if crew dont like you they will say you were practicing an instrument approach at the time you had a bird strike or near miss or struck by asteroid....
)Also if you are doing it with vectors from approach or PAR etc. FAA will put it down to the fact you were doing something you were not legally able to do at time of incident.
you get the drift
Last edited by Bajan3; 27th Mar 2011 at 16:26.
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A safety pilot is required when practicing instrument flight under simulated conditions (under the hood), to provide a lookout for other traffic. Operating under an IFR clearance would not provide separation from VFR traffic.
91.109 Flight instruction; simulated instrument flight and certain flight tests.
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(b) No person may operate a civil aircraft in simulated instrument flight unless— (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.
(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and
(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when—
(i) The safety pilot has determined that the flight can be conducted safely; and
(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
(c) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft.
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(b) No person may operate a civil aircraft in simulated instrument flight unless— (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.
(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and
(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when—
(i) The safety pilot has determined that the flight can be conducted safely; and
(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
(c) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft.
Hi Bajan
I'm not from FAA land but are you sure you are not confusing statements that outside vision must be restricted by artificial means (screens etc.) for IF training/currency and if carrying out IF training/currency you need a safety pilot because you can't see out?
I'm sure they are not going to stop you flying IFR on your own just because you are not in cloud and want to shoot an ILS on the way home!
Cheers
TeeS
I'm not from FAA land but are you sure you are not confusing statements that outside vision must be restricted by artificial means (screens etc.) for IF training/currency and if carrying out IF training/currency you need a safety pilot because you can't see out?
I'm sure they are not going to stop you flying IFR on your own just because you are not in cloud and want to shoot an ILS on the way home!
Cheers
TeeS
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This in refernce to VFR Only HELI OPS
which applies to 90 % of USA EMS OPS. Not IFR Cert OPS. Just VFR Only 135 Heli with Pilot practicing IIMC procedures. Pilots here flying VFR Only EMS Heli part 135 have a IFR Rating but 99 % are not current and are not required to be current, as they are not flying IFR. As part of the 135 check or recurrency pilots are req to show proficiency flying under simulated conditions, able to recover IIMC etc and shoot best avail approach or vectors etc.
Most managers tell pilots its ok to do a practice approach on the back end of a patient flt (RTB Return to base ) to help them stay proficient , thinking it is ok to use medics as safety observers..
And a lot of pilots do it thinking it is ok to do so..when it is a faa violation.
Most managers tell pilots its ok to do a practice approach on the back end of a patient flt (RTB Return to base ) to help them stay proficient , thinking it is ok to use medics as safety observers..
And a lot of pilots do it thinking it is ok to do so..when it is a faa violation.
Hi Bajan
The JAA wording is similar to the quote KK posted. The crux of the matter is that if you don't artificially restrict the view of the pilot then you are not simulating instrument flight!
If you are not operating with foggles/screens etc. to limit the outside cues then you can always look up. The safety pilot is there because the guy behind the screens can't look up.
As I say, I have no knowledge of FAA rules so could be talking rubbish.
Cheers
TeeS
Edit - just seen your header that you are talking about VFR only helicopters - not sure my comments are applicable or not. I still think the rules that would prevent you carrying out the procedure are not the ones you are quoting. e.g. is the helicopter allowed to fly IFR in controlled airspace? I will leave it to someone more up to speed with the FAA rules.
The JAA wording is similar to the quote KK posted. The crux of the matter is that if you don't artificially restrict the view of the pilot then you are not simulating instrument flight!
If you are not operating with foggles/screens etc. to limit the outside cues then you can always look up. The safety pilot is there because the guy behind the screens can't look up.
As I say, I have no knowledge of FAA rules so could be talking rubbish.
Cheers
TeeS
Edit - just seen your header that you are talking about VFR only helicopters - not sure my comments are applicable or not. I still think the rules that would prevent you carrying out the procedure are not the ones you are quoting. e.g. is the helicopter allowed to fly IFR in controlled airspace? I will leave it to someone more up to speed with the FAA rules.
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Interesting thread, I take it we're talking about non rated pilots flying instrument practice in VFR/VMC, if so here in the UK police world we mainly fit that description. Our practice instrument flying is mandated for one hour every 90/120 days with a safety pilot and dual controls fitted and with restricted vision. Of course it's not unknown to return to base during operational flying and couple the ILS just for the practice, but it's not logged and a good crew lookout is maintained throughout (ie no restricted vision and remaining in VMC.
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Pilots logging practice is problem
The problem is that the pilots are logging the time in the Duty Flt records etc as a practice approach. As i said in original post you can do what ever you want and most do. Problem is how you document it and if you are not using hood etc, why document it in the first place.
The FAA Inspector will just take the paperwork for what it states, i.e practice app , sim app, inst app. Pilot would have to prove he was flying with due care and attention as to what was going on outside the aircraft, see and avoid etc, lawyers would have a field day.
For FAA its simple.. paper work says you did a practice approach or sim inst. Then he looks to see if you met the requirements to do such. If you don't, oh well,,, there is no gray for FAA, just Black or White.
The FAA Inspector will just take the paperwork for what it states, i.e practice app , sim app, inst app. Pilot would have to prove he was flying with due care and attention as to what was going on outside the aircraft, see and avoid etc, lawyers would have a field day.
For FAA its simple.. paper work says you did a practice approach or sim inst. Then he looks to see if you met the requirements to do such. If you don't, oh well,,, there is no gray for FAA, just Black or White.
Bajan3....please do not confuse the argument with facts please.
Your kind of thinking is paramount to Treason as one former CP used to brag he would rather have an Autopilot instead of a Co-Pilot.
You keep up this independent thought thing and who knows how much money it will cost the Operator to operate in compliance to the FAR's.
The real question is .... Why has the FAA not tweaked to this practice?
Your kind of thinking is paramount to Treason as one former CP used to brag he would rather have an Autopilot instead of a Co-Pilot.
You keep up this independent thought thing and who knows how much money it will cost the Operator to operate in compliance to the FAR's.
The real question is .... Why has the FAA not tweaked to this practice?
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Treason your an idiot..
I was giving fellow pilots a heads up.. I cant speak for the FAA and why they or the CAA do business the way they do . My info is for the thinking pilot.
I can only state what I see happening in the field.
You and everyone else can do what ever they want. I was just giving those of you out there a heads up on something that a very good friend of mine just got a ticket for and didn't want to see another good pilot just doing there job get screwed.. because of bad information.. let a pilot read the regs and you will get 10 views on what it means. Speak to the guy giving you the ticket and he will tell you exactly what it means.
have a nice day
thats all from me folks, I have a life outside of aviation
I can only state what I see happening in the field.
You and everyone else can do what ever they want. I was just giving those of you out there a heads up on something that a very good friend of mine just got a ticket for and didn't want to see another good pilot just doing there job get screwed.. because of bad information.. let a pilot read the regs and you will get 10 views on what it means. Speak to the guy giving you the ticket and he will tell you exactly what it means.
have a nice day
thats all from me folks, I have a life outside of aviation
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The real question is- are they flying the procedure VFR for the sake of familiarity with the procedures, or are they flying the the procedures to log the approaches for currency? The first instance is no problem and is actually a wise idea for folks who do not have the tools available to fly hooded down to minimums. The latter is not legal and can get you in trouble.
Your logbook is your logbook. If you put 1000 approaches in there, but do not use them for currency or certificate actions, they mean nothing but a measure of experience. Anything, any time, any landings, any instrument approache that you use to show currency or to gain a certificate must be flown iaw published requirements.
Being totally familiar with the approaches at your home airfield and the approaches along your routes is a very smart thing. Flying these approaches VFR will only serve to make you familiar with these procedures. I can find no problem with a pilot flying them VFR. He should know that it is his responsibility to maintain traffic clearance while in VFR conditions, hooded or not! Never depend on ATC for your traffic clearance while in VMC either.
Your logbook is your logbook. If you put 1000 approaches in there, but do not use them for currency or certificate actions, they mean nothing but a measure of experience. Anything, any time, any landings, any instrument approache that you use to show currency or to gain a certificate must be flown iaw published requirements.
Being totally familiar with the approaches at your home airfield and the approaches along your routes is a very smart thing. Flying these approaches VFR will only serve to make you familiar with these procedures. I can find no problem with a pilot flying them VFR. He should know that it is his responsibility to maintain traffic clearance while in VFR conditions, hooded or not! Never depend on ATC for your traffic clearance while in VMC either.
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Bajan3,
You would be right if you fly a practice approach relying only on your instruments for aircraft control without any ground reference (hooded etc). If that is so, indeed you would not be able to maintain separation with other aircraft and it would require a safety pilot (a rated pilot) to be legal and to log "simulated" IFR.
On the other hand, If I request a "practice approach" and I am: cleared for the ILS 27, maintain VFR and no separation provided , I am completely legal to shoot that ILS, turn on the autopilot, couple it and let the aircraft fly the approach while scanning for traffic as usual when VFR. I can even log a "practice approach" if that would be important to me, I just can not log "simulated IFR.
Having said this, If you fly an aircraft without an autopilot it would be hard to comply with visual serrations and "hand-fly" an ILS at the same time.I guess it all comes down to your equipment but indeed, flying a "practice approach" in a EC130 or so, would make it hard for one to comply with all other requirements of VFR regulations as a single pilot. I am actually amazed there are pilots out there doing so...(assuming they are seriously trying to fly an ILS)
Um_lifting: Getting an actual IFR clearance does not relieve you from your responsibility to maintain traffic separation while in VMC conditions and is not a solution either.
To add: there is a company in the US that requires you to fly 1.5 hrs every quarter with another pilot (during shiftchange) practicing in VMC conditions, IFR approached not using your autopilot, This same company also requires you to log 3 "practice approaches per month in VMC conditions while using your autopilot and scanning for traffic. All this aside from required recurrent training and IFR line checks. This however cost a lot of money and is an initiative the company takes itself. I am sure there are more like this out there, just, do not expect this from any of the major money making corporate machines....
The FAA......well, that is an whole other story and like the large corporate operators, do not expect too much from them either.
You would be right if you fly a practice approach relying only on your instruments for aircraft control without any ground reference (hooded etc). If that is so, indeed you would not be able to maintain separation with other aircraft and it would require a safety pilot (a rated pilot) to be legal and to log "simulated" IFR.
On the other hand, If I request a "practice approach" and I am: cleared for the ILS 27, maintain VFR and no separation provided , I am completely legal to shoot that ILS, turn on the autopilot, couple it and let the aircraft fly the approach while scanning for traffic as usual when VFR. I can even log a "practice approach" if that would be important to me, I just can not log "simulated IFR.
Having said this, If you fly an aircraft without an autopilot it would be hard to comply with visual serrations and "hand-fly" an ILS at the same time.I guess it all comes down to your equipment but indeed, flying a "practice approach" in a EC130 or so, would make it hard for one to comply with all other requirements of VFR regulations as a single pilot. I am actually amazed there are pilots out there doing so...(assuming they are seriously trying to fly an ILS)
Um_lifting: Getting an actual IFR clearance does not relieve you from your responsibility to maintain traffic separation while in VMC conditions and is not a solution either.
To add: there is a company in the US that requires you to fly 1.5 hrs every quarter with another pilot (during shiftchange) practicing in VMC conditions, IFR approached not using your autopilot, This same company also requires you to log 3 "practice approaches per month in VMC conditions while using your autopilot and scanning for traffic. All this aside from required recurrent training and IFR line checks. This however cost a lot of money and is an initiative the company takes itself. I am sure there are more like this out there, just, do not expect this from any of the major money making corporate machines....
The FAA......well, that is an whole other story and like the large corporate operators, do not expect too much from them either.
Last edited by otter712; 27th Mar 2011 at 22:40.
Bajan brings an inconvenient truth to the EMS industy....and is exactly right in voicing his concern.
The "treason" I mentioned is his being able to think outside the box and bring to light an issue the EMS Industry shall not want to address properly. EMS Operators like folks working for them to just salute and say "Aye Aye Sir!"
The "treason" I mentioned is his being able to think outside the box and bring to light an issue the EMS Industry shall not want to address properly. EMS Operators like folks working for them to just salute and say "Aye Aye Sir!"
Thinking outside the box, maybe take the same view the FAA did for certifying the AW139 single-pilot VFR, and just make sure your TCAD is working. Wouldn't do much for the meteors or birds, but we're just talking legalities here, not common sense.
Originally Posted by Bajan3
Treason your an idiot..
I was giving fellow pilots a heads up.. I cant speak for the FAA and why they or the CAA do business the way they do . My info is for the thinking pilot.
I can only state what I see happening in the field.
I was giving fellow pilots a heads up.. I cant speak for the FAA and why they or the CAA do business the way they do . My info is for the thinking pilot.
I can only state what I see happening in the field.
Can you legally shoot a practice IFR approach with no safety pilot in a VFR aircraft?
Yes, but only in visual conditions, and you can't use Foggles or screens either.
Can you log this approach for the purpose IFR currency, or log the flight as "simulated Instrument conditions"?
Absolutely not.
Flying practice approaches like that will certainly help you become more familiar with the IFR procedures, but it does not replace real IFR training flights in actual or simulated IMC.
Lots of CFIIs make a similar mistake when doing IFR training flights with their students. The student is wearing the hood, not the instructor. Only the student can log instrument approaches and simulated IMC hours.
All of this refers to FAA rules btw.
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Sorry SaSless and all
sometimes i take feedback too personal, but like all of us here I am still learning, in life as well as aviation.
Thanks for all the reply s posted i do appreciate all the input.
Thanks for all the reply s posted i do appreciate all the input.
If I may paraphrase and (un)clarify a few points:
- The dual controls requirement is only for flight instruction.
- No person can operate in "simulated instrument flight” without a safety pilot.
- Instrument experience needs to be gained under actual or “simulated instrument conditions”.
- To my knowledge, neither “simulated instrument flight”, nor “simulated instrument conditions” is defined by the FAA.
Avoid imitations
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Don't the FAA rules in question refer only to training by an unqualified (i.e. not instrument rated) pilot?
Surely if a "real" ILS is flown by a suitably quailified pilot for recovery to base or another airfield for the purposes of landing then by definition it's not a practice ILS at all.
Surely if a "real" ILS is flown by a suitably quailified pilot for recovery to base or another airfield for the purposes of landing then by definition it's not a practice ILS at all.
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In a VFR-only aircraft without dual controls, and nobody else in the cockpit, you can certainly fly an instrument approach in VMC without a safety pilot. You cannot use a view-limiting device, and you cannot log it (legally) as an instrument approach for currency, nor log it as instrument time. I do it all the time, just to stay just a little familiar with instrument procedures should it be required if goddess forbid I get into IIMC. Instrument flying skills are the most perishable in aviation, IMO, and have to be practiced regularly if there is any hope of being even remotely proficient. On every flight I try to practice instrument skills by flying precisely, using the instruments, and I fly instrument approaches (almost all GPS, because there is no other nav equipment installed), but I never, ever, log any instrument time in those conditions. Practice is fine, even essential, but don't kid yourself, it's not the same thing as actual instrument flying, and you can't legally log it as such, and it certainly doesn't meet the requirements for instrument currency, per the FAA. However, and this is a big however, it probably does meet the requirements for CAMTS, and may satisfy them. For those in other areas, CAMTS is a money-generating organization which certifies EMS programs. Their requirements are obviously set by non-aviation personnel who probably have never been in a helicopter, but being CAMTS certified is a big deal to some companies, and is close to being a requirement. Satisfying CAMTS is a priority for some companies, and if flying instrument approaches in VMC helps, then I see no reason not to, and since it's a good thing anyway, why not? Just remember, it does nothing to satisfy FAA requirements in any way. In a VFR program, I don't need to meet any IFR IFR requirements anyway, so it's all moot for that.
@shytorque, the rules in question apply to any pilot, in any aircraft. If you use a view-limiting device, you must have a safety pilot. It matters not if you're a student or an ATP.
@shytorque, the rules in question apply to any pilot, in any aircraft. If you use a view-limiting device, you must have a safety pilot. It matters not if you're a student or an ATP.
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Don't the FAA rules in question refer only to training by an unqualified (i.e. not instrument rated) pilot?
Surely if a "real" ILS is flown by a suitably quailified pilot for recovery to base or another airfield for the purposes of landing then by definition it's not a practice ILS at all.
Surely if a "real" ILS is flown by a suitably quailified pilot for recovery to base or another airfield for the purposes of landing then by definition it's not a practice ILS at all.
61.57
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(c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR only if:
(1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—
(i) Six instrument approaches.
(ii) Holding procedures and tasks.
(iii) Intercepting and tracking courses through the use of navigational electronic systems.
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(c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR only if:
(1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—
(i) Six instrument approaches.
(ii) Holding procedures and tasks.
(iii) Intercepting and tracking courses through the use of navigational electronic systems.