121.436 question

ATP and PIC type required if hired after August 1, 2013?

  • Yes

    Votes: 5 83.3%

  • No

    Votes: 1 16.7%
  • Total voters
    6
ctab5060X

ctab5060X

Well-Known Member
I've quoted the entire regulation at the bottom of the post for reference, but I am seeking the wise opinion of the JC council.

The question I have is more of a clarification and making sure I am reading the regulation correctly in regards to second in command operations under part 121.

According to our most recent seniority list, there are new hires in training with an August 2013 start date. These are the first FOs hired since the new regulation went into effect and, as luck would have it, they are going to be based where I currently am based. All other FOs in base have hire dates of last summer.

The way I interpret the regulation, the FOs hired last summer only need to have an ATP and can hold an SIC type rating for the aircraft, yet the FOs hired post August 1, 2013, will need to have both an ATP and an appropriate type rating (assuming PIC type here) for the aircraft.

Am I correct in this interpretation?



§ 121.436 Pilot Qualification: Certificates and experience requirements.
(a) No certificate holder may use nor may any pilot act as pilot in command of an aircraft (or as second in command of an aircraft in a flag or supplemental operation that requires three or more pilots) unless the pilot:
(1) Holds an airline transport pilot certificate not subject to the limitations in § 61.167 of this chapter;
(2) Holds an appropriate aircraft type rating for the aircraft being flown; and
(3) If serving as pilot in command, has 1,000 hours as second in command in operations under this part, pilot in command in operations under § 91.1053(a)(2)(i) of this chapter, pilot in command in operations under § 135.243(a)(1) of this chapter, or any combination thereof. For those pilots who are employed as pilot in command in part 121 operations on July 31, 2013, compliance with the requirements of this paragraph (a)(3) is not required.
(b) No certificate holder may use nor may any pilot act as second in command unless the pilot holds an airline transport pilot certificate and an appropriate aircraft type rating for the aircraft being flown. A second-in-command type rating obtained under § 61.55 does not satisfy the requirements of this section.
(c) For the purpose of satisfying the flight hour requirement in paragraph (a)(3) of this section, a pilot may credit 500 hours of military flight time obtained as pilot in command of a multiengine turbine-powered, fixed-wing airplane in an operation requiring more than one pilot.
(d) Compliance with the requirements of this section is required by August 1, 2013. However, for those pilots who are employed as second in command in part 121 operations on July 31, 2013, compliance with the type rating requirement in paragraph (b) of this section is not required until January 1, 2016.[/QUOTE]
Click to expand...
 
Doesn't matter when somebody was hired. If they operate a 121 aircraft they must have an ATP and a PIC type.
 
I thought the PIC type was pushed back to something like 2016. ATP, yes, but I think the full type was changed a bit for an FO.
 
(d) However, for those pilots who are employed as second in command in part 121 operations on July 31, 2013, compliance with the type rating requirement in paragraph (b) of this section is not required until January 1, 2016.
 
BobDDuck said:
Doesn't matter when somebody was hired. If they operate a 121 aircraft they must have an ATP and a PIC type.
Click to expand...

See, that is what I originally thought until I read the same exception that @Bandit_Driver posted.

From that, it would seem that FOs that were on the seniority list as of July 31st only need a SIC type rating until January 1, 2016.

However, those hired after August 1 will need to have a PIC type. My company hasn't been issuing PIC type ratings during recurrent so with the new hires coming on board, we are potentially going to see a mix of SIC and PIC type rated FOs. Trying to keep everything straight.
 
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