Dutch said:
OK, the school I work at is switching to 142 from 141. One of the questions I have is in regards to duty time restrictions. Under 141 we were limited to 8 hours of flight instruction but part 142 states a limit of 8 hours of instruction [no mention of flight see 14CFR142.49(c)]. Our chief pilot and training managers are stating that sim time does not count towards this limit but can't give a reference for this interpretation. Any 142 drivers have any experience with this?
Dutch
Considering FAR 142 pertains to "Training Centers" and talks almost exclusively about training conducted in simulators (although it does mention training conducted in aircraft), there's not much question in my mind that the 8 hour limit refers to simulator as well as aircraft instruction time.
If you are already a 141 school, you must have a POI that will probably also monitor your 142 ops. Ask him. I'm sure he will tell you what it says below: Excluding briefings and debriefings, you can't instruct more than 8 hours in a 24 hour period - simulator or aircraft.
I'm not sure whether that limit includes any classroom ground school instruction or not, but I don't have much doubt about sim instruction time being limited to 8 hours/day.
I know that at my airline, when we do a 4 hour sim session, it has about 1-1/2 brief prior and a 1/2 hour post.
Now, if your chief pilot and training managers want you to brief and debrief for a couple hours, instruct in the sim for 8 hours, and then do 4 hours of ground school per day, that may be okay. I hope they pay you a whole lot of money if you're gonna work some 16 hours/day!!! I don't know how much value you're going to be to the students.
TriDriver Bob
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Here's 142.49:
§142.49 Training center instructor and evaluator privileges and limitations.
(a) A certificate holder may allow an instructor to provide:
(1) Instruction for each curriculum for which that instructor is qualified.
(2) Testing and checking for which that instructor is qualified.
(3) Instruction, testing, and checking intended to satisfy the requirements of any part of this chapter.
(b) A training center whose instructor or evaluator is designated in accordance with the requirements of this subpart to conduct training, testing, or checking in qualified and approved flight training equipment, may allow its instructor or evaluator to give endorsements required by part 61 of this chapter if that instructor or evaluator is authorized by the Administrator to instruct or evaluate in a part 142 curriculum that requires such endorsements.
(c) A training center may not allow an instructor to --
(1) Excluding briefings and debriefings, conduct more than 8 hours of instruction in any 24-consecutive-hour period;
(2) Provide flight training equipment instruction unless that instructor meets the requirements of §142.53 (a)(1) through (a)(4), and §142.53(b), as applicable; or
(3) Provide flight instruction in an aircraft unless that instructor --
(i) Meets the requirements of §142.53(a)(1), (a)(2), and (a)(5);
(ii) Is qualified and authorized in accordance with subpart H of part 61 of this chapter;
(iii) Holds certificates and ratings specified by part 61 of this chapter appropriate to the category, class, and type aircraft in which instructing;
(iv) If instructing or evaluating in an aircraft in flight while occupying a required crewmember seat, holds at least a valid second class medical certificate; and
(v) Meets the recency of experience requirements of part 61 of this chapter.
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