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Pilot qualification to operate in either pilotís seat (EASA)

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Pilot qualification to operate in either pilotís seat (EASA)

Old 12th May 2020, 11:43
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Pilot qualification to operate in either pilotís 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 pilotís 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!
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Old 12th May 2020, 14:14
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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
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Old 12th May 2020, 14:52
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Iím 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, donít fly there.. far to small) !.. (Weight of aircraft alone, apologies) qualify all their Captains (well almost all of them) to fly both seats .. Itís not so difficult when you consider most cars today are designed to be driven from the right !

So, apologies but what was the question?
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Old 12th May 2020, 17:13
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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?
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Old 12th May 2020, 17:22
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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?
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Old 12th May 2020, 18:13
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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..
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Old 12th May 2020, 20:29
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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
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Old 12th May 2020, 21:55
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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!
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Old 12th May 2020, 21:56
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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?
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Old 13th May 2020, 06:18
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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....



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Old 13th May 2020, 07:32
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Originally Posted by 178 View Post
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.
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Old 13th May 2020, 11:39
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You are not by any chance operating out of Romania?!
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Old 13th May 2020, 11:52
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Originally Posted by hueyracer View Post
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
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Old 13th May 2020, 13:49
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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...
​​​​​​.
​​​​


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Old 13th May 2020, 13:59
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Originally Posted by hueyracer View Post
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.

Originally Posted by Mustapha Cuppa View Post
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?

Originally Posted by hueyracer View Post
You are not by any chance operating out of Romania?!
No, there are no EC155s around here!

Originally Posted by Apate View Post
I think you'll find that offshore operators generally will qualify all pilots to fly from either seat. Well, the good ones do
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?
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Old 13th May 2020, 22:09
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Originally Posted by 178 View Post
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/def...%202019-08.pdf

The commander needs to be qualified in whichever seat they occupy. If they are not the commander they donít 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 neednít be specifically qualified to occupy that seat.

Last edited by Aucky; 13th May 2020 at 22:24.
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Old 14th May 2020, 08:58
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Originally Posted by hueyracer View Post
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...
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Old 14th May 2020, 10:12
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Originally Posted by tu154 View Post
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.
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Old 14th May 2020, 10:25
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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).

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Old 14th May 2020, 11:31
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Originally Posted by hueyracer View Post
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
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