RESPONSE to Safety Recommendation:
Operator’s response to AAIASB SR 2022-04 was received by email on 08/9/2022.
“ You are kindly requested to read the following:
As it is referred on OM-PART A, §5.2.2 :
«5.2.2 Qualification to act as Pilot-In-Command/Commander
(ORO.FC.105 & 205)
“I Fly” shall only designate a flight crew member to act as pilot-in-command/ commander when he/she has:
5. Completed the “I Fly” Conversion Course, through a subcontracted ATO;
6. Acquired adequate knowledge of the route or area to be flown and of the aerodromes, including alternate aerodromes, facilities and procedures to be used;
7. Completed a Line Training
8. Completed the “I Fly” command course if upgrading from co-pilot to pilot-in-command/commander. »
and on OM-PART D / Appendix R, §1.2 it is stated:
1.3 « Command Course (ORO.FC.205)
For helicopter operations, the command course shall include at least the following elements:
(7) training in an FSTD, which includes line oriented flight training (LOFT) and/or flight training;
(8) operator proficiency check, operating as commander;
(9) command responsibilities training;
(10) line training as commander under supervision, for a minimum of:
(iii) 20 flight hours including at least 20 sectors, in the case of less than 2000 flight hours experience; and
(iv) 10 flight hours, including at least 10 sectors, in the case of more than 2000 flight hours experience;
(11) completion of a line check as commander and demonstration of adequate knowledge of the route or area to be flown and of the aerodromes, including alternate aerodromes, facilities, heliports, landing sites and procedures to be used and
(12) crew resource management training. »
According to the above, the criteria for assigning the duties to the Pilot-in-Command (PIC) are only mentioned in the Operations Manual Part A, while in the Operations Manual Part D only the Command Course is described, the completion of which is one of the conditions for the designation as Pilot in Command.
The minimum flight experience of the PIC for the undertaking of commercial flights is stated identically in OM-PART A, §5.2.1.B.HELICOPTERS (5) and in OM-PART D/ Appendix R/§1.1.( c )(5) , as below:
«(5) When a flight crewmember is required to operate a helicopter, following completion of a Type Rating (by an ATO) or the conversion course and the associated line flying under supervision, is not to be designated to commence a revenue or hired flight before he achieves the requirements on flight hours on the type as is referred below according to the total helicopter PIC flight experience.
(i) has achieved 20 flight hours totally on the type within a period of 60 days and performed at least 20 sectors, only for Cdr with less than 2000 flight hours as PIC on helicopters.
(ii) has achieved 10 flight hours totally on the type within a period of 60 days and performed at least 10 sectors, only for Cdr with more than 2000 flight hours as PIC on helicopters.
(iii) has achieved 100 flight hours on the type and/or in the role (no time limit);»
The above is a statement of the flight hours that the PIC must have completed upon completion of Conversion training and on-line training before being assigned the duties of PIC for commercial flights, recording the Company's policy to the strictest of Legislation which requires a minimum of ten (10) hours including a minimum of ten (10) flight sectors in accordance with ORO.FC.205 Command course.
As a conclusion, we believe that there is not any conflict between the OM – PART A and the OM – PART D of the company regarding the criteria for the assignment of Captain duties, as it is stated on the Safety Recommendation 2022-04.”
[AAIASB changed status of SR 2022-04 to “Open- Response Received awaiting assessment” and will assess the Response within 60 days as per EU Reg. 996/2010.]