Narrative:

I have been employed as a pilot since march 1983. Upon completion of my training, I had a commercial pilot certificate with ratings airplane single engine land and instrument airplane. In addition, I had a F/east (turbojet) certificate. My initial position was flight engineer on the large transport. In 1/85, I received upgrade training for the position of first officer, and began flying in that position in 1/85. I did not receive any additional rating as a result of my upgrade training, nor have I received any additional rating since then. I was not aware that a multi engine rating was required for the position I was flying. In fact, I was advised by at least 1 of the company's instrs (in response to my inquiry) that a first officer is not required to have a multi-engine rating. Today (9/88), I received a telephone call from our assistant chief pilot, who had just received a call from an FAA inspector, and he advised me that I was being removed from flight status effective immediately, because I did not have a multi engine rating as required by FARS. Needless to say, I was taken by surprise. Over the last 3 yrs and 9 mos, I have flown 2,604 hours as first officer. During that period, I have had my credentials checked numerous times by air carrier inspectors. On most such occasions, the aci made verbal note of the fact that I had a single engine rating, and dismissed the subject with a statement to the effect of, 'I don't see that very often.' additionally, during the time that I have flown as first officer, the company's training records have been exhaustively reviewed by the FAA at least twice (most recently in 5/88), and my credentials were checked by an FAA inspector in connection with a check ride for captain upgrade (which I did not complete) in 6/88, all with no mention made of my deficiency in rating. All of the above made me feel confident that I had the required rating for the position in which I was flying. Before I return to the line, I will have a multi-engine rating. I must say, however, that I fail to see how a multi engine rating earned in an small aircraft will make me more qualified than I presently am to fly as first officer on an large transport, other than to meet the letter of the regulation. In closing, I would like to point out a somewhat confusing paragraph in the FARS that may have contributed to the delay in detecting my situation. When I was advised of my problem today, I immediately started thumbing through the FARS and read PAR 121.437 (a) and (B), which left me with the impression, since (a) is not applicable to me, that a multi-engine rating was not required for my position. Then my attention was called to paragraph (C) of the same section, which contradicts and evidently supersedes (B), and requires a multi engine rating for my position. I submit that paragraph 121.437 (B) should be deleted, as it has not been applicable since 7/80, and thus causes confusion. In addition, the last sentence of paragraph 121.437 (C) (starting with 'notwithstanding the requirements of...') should be deleted for the same reasons.

Related reports:

Google
 

Original NASA ASRS Text

Title: FLYING AS FO WITHOUT MULTI ENGINE RATING ON CERTIFICATE.

Narrative: I HAVE BEEN EMPLOYED AS A PLT SINCE MARCH 1983. UPON COMPLETION OF MY TRNING, I HAD A COMMERCIAL PLT CERTIFICATE WITH RATINGS AIRPLANE SINGLE ENG LAND AND INSTRUMENT AIRPLANE. IN ADDITION, I HAD A F/E (TURBOJET) CERTIFICATE. MY INITIAL POS WAS FLT ENGINEER ON THE LGT. IN 1/85, I RECEIVED UPGRADE TRNING FOR THE POS OF F/O, AND BEGAN FLYING IN THAT POS IN 1/85. I DID NOT RECEIVE ANY ADDITIONAL RATING AS A RESULT OF MY UPGRADE TRNING, NOR HAVE I RECEIVED ANY ADDITIONAL RATING SINCE THEN. I WAS NOT AWARE THAT A MULTI ENG RATING WAS REQUIRED FOR THE POS I WAS FLYING. IN FACT, I WAS ADVISED BY AT LEAST 1 OF THE COMPANY'S INSTRS (IN RESPONSE TO MY INQUIRY) THAT A F/O IS NOT REQUIRED TO HAVE A MULTI-ENG RATING. TODAY (9/88), I RECEIVED A TELEPHONE CALL FROM OUR ASSISTANT CHIEF PLT, WHO HAD JUST RECEIVED A CALL FROM AN FAA INSPECTOR, AND HE ADVISED ME THAT I WAS BEING REMOVED FROM FLT STATUS EFFECTIVE IMMEDIATELY, BECAUSE I DID NOT HAVE A MULTI ENG RATING AS REQUIRED BY FARS. NEEDLESS TO SAY, I WAS TAKEN BY SURPRISE. OVER THE LAST 3 YRS AND 9 MOS, I HAVE FLOWN 2,604 HRS AS F/O. DURING THAT PERIOD, I HAVE HAD MY CREDENTIALS CHKED NUMEROUS TIMES BY AIR CARRIER INSPECTORS. ON MOST SUCH OCCASIONS, THE ACI MADE VERBAL NOTE OF THE FACT THAT I HAD A SINGLE ENG RATING, AND DISMISSED THE SUBJECT WITH A STATEMENT TO THE EFFECT OF, 'I DON'T SEE THAT VERY OFTEN.' ADDITIONALLY, DURING THE TIME THAT I HAVE FLOWN AS F/O, THE COMPANY'S TRNING RECORDS HAVE BEEN EXHAUSTIVELY REVIEWED BY THE FAA AT LEAST TWICE (MOST RECENTLY IN 5/88), AND MY CREDENTIALS WERE CHKED BY AN FAA INSPECTOR IN CONNECTION WITH A CHK RIDE FOR CAPT UPGRADE (WHICH I DID NOT COMPLETE) IN 6/88, ALL WITH NO MENTION MADE OF MY DEFICIENCY IN RATING. ALL OF THE ABOVE MADE ME FEEL CONFIDENT THAT I HAD THE REQUIRED RATING FOR THE POS IN WHICH I WAS FLYING. BEFORE I RETURN TO THE LINE, I WILL HAVE A MULTI-ENG RATING. I MUST SAY, HOWEVER, THAT I FAIL TO SEE HOW A MULTI ENG RATING EARNED IN AN SMA WILL MAKE ME MORE QUALIFIED THAN I PRESENTLY AM TO FLY AS F/O ON AN LGT, OTHER THAN TO MEET THE LETTER OF THE REG. IN CLOSING, I WOULD LIKE TO POINT OUT A SOMEWHAT CONFUSING PARAGRAPH IN THE FARS THAT MAY HAVE CONTRIBUTED TO THE DELAY IN DETECTING MY SITUATION. WHEN I WAS ADVISED OF MY PROB TODAY, I IMMEDIATELY STARTED THUMBING THROUGH THE FARS AND READ PAR 121.437 (A) AND (B), WHICH LEFT ME WITH THE IMPRESSION, SINCE (A) IS NOT APPLICABLE TO ME, THAT A MULTI-ENG RATING WAS NOT REQUIRED FOR MY POS. THEN MY ATTN WAS CALLED TO PARAGRAPH (C) OF THE SAME SECTION, WHICH CONTRADICTS AND EVIDENTLY SUPERSEDES (B), AND REQUIRES A MULTI ENG RATING FOR MY POS. I SUBMIT THAT PARAGRAPH 121.437 (B) SHOULD BE DELETED, AS IT HAS NOT BEEN APPLICABLE SINCE 7/80, AND THUS CAUSES CONFUSION. IN ADDITION, THE LAST SENTENCE OF PARAGRAPH 121.437 (C) (STARTING WITH 'NOTWITHSTANDING THE REQUIREMENTS OF...') SHOULD BE DELETED FOR THE SAME REASONS.

Data retrieved from NASA's ASRS site as of August 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.