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SIC Check and BFR

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Jump Pilot

Well-known member
Joined
Dec 31, 2001
Posts
277
Does a 12 month 135 SIC check also count as a BFR?
 
When I use company training to meet BFR/IPC requirements for GA purposes, I bring my logbook and have the check airman sign it off as a BFR or IPC. That way I have a permanent record and don't have to worry about regs pertaining to what counts and what doesn't.
 
Yes...
(d) A person who has, within the period specified in paragraph (c) of this section, passed a pilot proficiency check conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege need not accomplish the flight review required by this section.
Note that it does not say a Pilot In Command check, or anything like that...simply "a pilot proficiency check".

Fly safe!

David
 
Sounds like a previous ruling or interpretation from FAA legal council may be required in order to settle this one.

FAR 61.56 requires that a flight review must have been accomplished within the previous 24 calender months in order to act as PIC of an aircraft. Exception to this requirement is provided under para (d) of this section:

(d) A person who has, within the period specified in paragraph (c) of this section, passed a pilot proficiency check conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege need not accomplish the flight review required by this section.

At first glance, the flight and ground testing required by FAR 135.293 to act as a required pilot flight crewmember would appear to qualify as a "pilot proficiency check" for the purposes of 61.56 (d). It certainly seems to cover enough areas IMO. However, the .293, when used only to qualify an SIC, is not a pilot-in-command check. The purpose of 61.56 is to establish qualification as a PIC. This casts some doubt on whether the SIC check qualifies as a "pilot profciency check" for the purposes of 61.56. I have seen this come up in the past and the answers from FAA were not universal. Sorry to muddy the waters here, but this is a gray area in terms of interpretation. FAA, CFIs and others may not agree on a single correct answer to your question and "some guy on the internet" is not really a very solid reference source. So I have provided the references to applicable regs so that you may interpret and discuss their meaning with whoever you may wish to.

If the the check airman is a CFI, he may sign off a flight review at his discretion. However, the following excerpt from 61.56 (c) may indicate that you must be the holder of a type rating in the particular aircraft used for the check (if one is required) in order to qualify for a 61.56 signoff from the CFI:

(1) Accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor and


While 61.58 clearly states that pilots operating under approved air carrier and fractional training and qualification programs are excepted from this requirement with regard to pilot-in-command proficiency checks, second-in-command requirements are not addressed here. So it appears to me that if SIC qualification is considered (by FAA legal) to be an "operating privilege" (as referred to in 61.56(d)), then your 135.293 SIC qualification entitles you to the exception provided for in 61.56(d). If you have any doubt at all, I suggest you just get a friend or co-worker who happens to be a CFI to do the flight review with you. Then there is no way to say you are not in compliance with 61.56 if it ever comes up. Sorry this comes out looking like a court opinion, but that's how rules interpretations sometimes go! My personal approach to this problem was to get the 61.56 signoff. Once designated as a PIC in 135, it will no longer be an issue.

Best,
 
In many years of airline work I have never seen or heard of a check airman being asked to sign off a 6-month type check as a Flight Review or anything else. In fact, most likely the check airman doesn't even have a CFI. If the pilot satisfactorily completes the check it is now a matter of company record so the pilots that keep logbooks just enter that they passed their pilot proficiency check on that date. As far as I know that has always counted for the purpose of meeting the Flight Review requirements. I have never heard of any challenges (other than on this board) as to whether or not that person is qualified to act as PIC of GA aircraft.

This applies to SIC checks too, whether the pilot has a SIC type rating or not.
 
Last edited:
UndauntedFlyer said:
In many years of airline work I have never seen or heard of a check airman being asked to sign off a 6-month type check as a Flight Review or anything else. In fact, most likely the check airman doesn't even have a CFI. If the pilot satisfactorily completes the check it is now a matter of company record so the pilots that keep logbooks just enter that they passed their pilot proficiency check on that date. As far as I know that has always counted for the purpose of meeting the Flight Review requirements. I have never heard of any challenges (other than on this board) as to whether or not that person is qualified to act as PIC of GA aircraft.

This applies to SIC checks too, whether the pilot has a SIC type rating or not.

We have a lot of CFI's in the training dept. (regional), and I've always been able to get a signoff when I needed one. Actaully I suspect our training dept ONLY hires CFIs.

Majors may not have as many CFI's since they have more ex-military guys who would use their ATP as their 121 instructor authorization.
 
What if your company does AQP? Where there is only a Manuevers day and a LOE every 9 months. does that count as a BFR?
 
WMUSIGPI said:
does the same then hold true for Instrument proficiency checks?
Assuming you're referring to a 135 ride counting for instrument proficiency, SIC's do not take an instrument proficiency check...The specific regs are:

135.293, which is company specific stuff, regulations, and aircraft knowlege/proficiency. Both PIC and SIC are checked. This is what the Flight Review would be based on.

135.297, which is the "instrument proficiency" check, is only required of PIC's.

So, no. SIC checkrides under 135 do not count as an IPC.

Fly safe!

David
 
wmuflyguy said:
What if your company does AQP? Where there is only a Manuevers day and a LOE every 9 months. does that count as a BFR?

If the guy doing it is a CFI and will sign a BFR endorsement, then yes.

I always get them to sign the pre-printed BFR block.
 
MauleSkinner said:
Assuming you're referring to a 135 ride counting for instrument proficiency, SIC's do not take an instrument proficiency check...The specific regs are:

135.293, which is company specific stuff, regulations, and aircraft knowlege/proficiency. Both PIC and SIC are checked. This is what the Flight Review would be based on.

135.297, which is the "instrument proficiency" check, is only required of PIC's.

So, no. SIC checkrides under 135 do not count as an IPC.

Fly safe!

David

actually I was talking about a 121 initial sic check. Don't intend on returning to a 135 world right now. I like to know my days off before they have passed.
 
WMUSIGPI said:
actually I was talking about a 121 initial sic check. Don't intend on returning to a 135 world right now. I like to know my days off before they have passed.

121 SIC training/PCs don't automatically translate to an IPC, but since you will probably do 6 approaches, a hold, and intercepting/tracking, you can log it and have the sim instructor sign it. This is NOT an IPC, but if you are currently current it will extend your current currency for another 6 months.
 
rickair7777 said:
121 SIC training/PCs don't automatically translate to an IPC, but since you will probably do 6 approaches, a hold, and intercepting/tracking, you can log it and have the sim instructor sign it. This is NOT an IPC, but if you are currently current it will extend your current currency for another 6 months.

It woukd be a lot more simple to just have him sign it off as an IPC.
 
Ralgha said:
It woukd be a lot more simple to just have him sign it off as an IPC.

Well an IPC requires a specific selection of events from the IR PTS, and they have to be logged. Off of the top of my head, I don't think a PC necessarily hits all of them, and most companies would be lukewarm to your request to throw in a few extra manuevers for your personal 91 proficiency. Also, a 121 instructor may not actually have a CFII, he can do airline training on his ATP, but a CFII is required to conduct an IPC. An ATP could however document that you completed six approaches, a hold, and intercepting/tracking in your logbook.
 
rickair7777 said:
Well an IPC requires a specific selection of events from the IR PTS, and they have to be logged. Off of the top of my head, I don't think a PC necessarily hits all of them, and most companies would be lukewarm to your request to throw in a few extra manuevers for your personal 91 proficiency. Also, a 121 instructor may not actually have a CFII, he can do airline training on his ATP, but a CFII is required to conduct an IPC. An ATP could however document that you completed six approaches, a hold, and intercepting/tracking in your logbook.

§ 61.57 Recent flight experience: Pilot in command.

d) Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who does not meet the instrument experience requirements of paragraph (c) of this section within the prescribed time, or within 6 calendar months after the prescribed time, may not serve as pilot in command under IFR or in weather conditions less than the minimums prescribed for VFR until that person passes an instrument proficiency check consisting of a representative number of tasks required by the instrument rating practical test.


(1) The instrument proficiency check must be—
(i) In an aircraft that is appropriate to the aircraft category;
(ii) For other than a glider, in a flight simulator or flight training device that is representative of the aircraft category; or
(iii) For a glider, in a single-engine airplane or a glider.


(2) The instrument proficiency check must be given by
(i) An examiner;


(ii) A person authorized by the U.S. Armed Forces to conduct instrument flight tests, provided the person being tested is a member of the U.S. Armed Forces;


(iii) A company check pilot who is authorized to conduct instrument flight tests under part 121, 125, or 135 of this chapter or subpart K of part 91 of this chapter, and provided that both the check pilot and the pilot being tested are employees of that operator or fractional ownership program manager, as applicable;


(iv) An authorized instructor; or


(v) A person approved by the Administrator to conduct instrument practical tests.
 

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