B1900 : P2 Rating

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Goffel
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B1900 : P2 Rating

Unread post by Goffel » Tue May 22, 2012 9:40 am

There was a comment on another thread about P2 rating on a B1900?

Facts: B1900 is over 12500lbs....Commercially operated under Part 121.....must be operated under Part 121 as a multi crew, another words, two pilots.......manufacture certified as a SINGLE crew operation.

FORGET THE ARGUMENT OVER COMM OR ATP TO BE CAPTAIN.

My question is.......you arrive to fly as captain and you find your assigned co pilot only has a P2 rating on the aircraft.......do u fly with him as co pilot or do u ask for a suitably rated P1 rated co pilot.

Why...........he has a P2 rating...........BUT, since it is a manufacturer certified single crew operation, technically you do not get a P2 rating on the aircraft.......you only get a P1 rating and since there is no P2 rating sylabus for this aircraft, you theoretically should be doing the whole P1 rating sylabus from the LEFT seat.....thus entiteling you to be given a P1 rating to fly the aircraft.

Fact.......to fly from the right hand side, you must be signed out to fly left AND right seat AND your proff check must be from both sides if you are going to fly left and right seat.

Fact.....CIVIL AVIATIONS HAVE NO SAY IN THE HOUR REQUIREMENTS ON WHO IS PIC ON THE B1900, IT IS AN OPERATOR REQUIREMENT ON THE NUMBER OF HOURS NEDED TO BE PIC.....it is written in your MOP.

Question to yourself.......IF i fly with a co pilot with a P2 stamped in his licence.....is he leagally rated..........IF we have an accident or incident, am I as the PIC in the dwang as I flew with a co pilot not suitable rated in terms of the law, should the P2 rating not be legal.........

Is the operator also in the dwang if a passanger questions the validity of the the P2 rating, as the operator's quality control should have queeried the P2 rating, should their be a passanger injured in this acident or incident.

IF this P2 rating is not legal, then is the hours logged by the co pilot legal hours as he or she was not legeally rated on the aircraft.

Fact......A C406, turbine caravan, just like the B1900, certified as a single crew operation............have you ever seen a P2 rating on this aircraft.....mmmmmmm.

My personal opinion is that the P2 rating on a B1900 is not legal and i would ask for another co pilot, because, as murphys law, should something go wrong, i am in contravention of the law and will be held liable for all costs and damages and could also land up in some way out jail.

I do know for a fact that there are some of the big users of B1900 companies with their pilots still having P2 ratings on their licence and it would be interesting to hear their comment on this subject, as this encroaches onto their insurance, as it could make their insurance claims null and void IF in fact a P2 rating is in fact not legal........and nope, I am not suggesting that anyone is going out of their way to break the law, I would have just put it down to ignorance of the law.

Any sugestions or comments.........and please, this is not to start a bun fight, but a legit safety concern question.

Goffel.
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Re: B1900 : P2 Rating

Unread post by beckers » Tue May 22, 2012 10:04 am

Hi Goffel,

Interesting thoughts and there are arguments either way.

Aircraft Certification
The B190 is certified for single crew operation, except the 1900D which has restrictions on the equipment required to operate single crew. This then has the Comm & ATPL implications....

Then CAA law
IFR Part 91 requires auto-pilot with ALT hold, (Very few 1900's have that)
Turbine IFR restrictions part 121 etc..

So in summary, in our South African Commercial B190 operations require 2 crew.

Next thing is if you train somebody on the aircraft, and train from either seat, we can sign the paper work with CAA out on a crew member as:
Rated - restricted to Co-pilot duties only

In other words I have rated the person but based on the training and experience the said pilot may not yet operate the aircraft single crew or a Captain.

The CAA then issues a P2 - very different terminology to the original paperwork.

My opinion is that, the P2 is issued by the CAA. There is room for it. I would very happily fly with a P2, as they have been trained to operate from their assigned station.
At this stage there are many complications with the P2 system, I don't think the CAA has decided which way to go, perhaps they should rather then have a P1 (Restricted).

In the interim we are signing everybody as P1 regardless of experience.
Unfortunately there are some crew still with P2 ratings. If the CAA is not happy with that, they should approach us to sort out the mess.

P.S. I think you are more legal flying with a P2 trained to operate from that station rather than a P1 who has never sat right seat in the aircraft before and is not proficiency checked from that seat......
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Re: B1900 : P2 Rating

Unread post by beckers » Tue May 22, 2012 10:17 am

B190-D UE Series Limitations section 2
MINIMUM FLIGHT CREW
The minimum crew is one pilot. See the Kinds of Operations Equipment List in this section for required equipment

SINGLE PILOT OPERATION ONLY
1. Headset
2. Boom mounted microphone
3. Emergency, Abnormal and Normal Procedures Check List
4. Kit 114-5042 (All passenger seats in excess of nine (9) must be rendered nonoccu-piable by "DO NOT OCCUPY" seat belt tube assembly.)
It is item 4 that most 1900D's do not comply with and hence are certified for more than one pilot. And hence a 2 crew aircraft.....
Last edited by beckers on Tue May 22, 2012 4:57 pm, edited 3 times in total.
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Re: B1900 : P2 Rating

Unread post by Burner » Tue May 22, 2012 12:27 pm

Goffel I'd tend to agree with Beckers as far as the law and insurance is concerned. Surely the buck gets passed to the CAA if they are issuing incorrect ratings in the first place. I also as a Captain don't physically check that the FO's that I fly with have a P1 or P2 rating, it's none of my business as my employer, the operator is responsible to send correctly licensed crew on contract, and then obviously the crew member himself is ultimately responsible to stay within the stipulations of their licence.

I still do not understand why these P2 ratings were allowed to be issued in the first place. Are there P2 ratings being issued on C208s that can carry 12 passengers and does not have the disabling kit that Becker's mentioned. Either the instructors issuing the ratings need to be corrected, or the CAA should be rejecting the paper work in the first place.
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Re: B1900 : P2 Rating

Unread post by Goffel » Tue May 22, 2012 3:46 pm

beckers......if you felt a pilot was not up to standard on a C406, (Caravan2, turbine), would you sign him out as a co pilot or fail him......you would fail him and ask him to do more training.

The B1900 falls into the same category, single crew........forget about seating and auto pilots etc....the manufacturer has certified it as single crew operation

If a pilot is not up to speed on the aircraft, then he should get additional training until he is P1 rated as there is no legal P2 rating for the 1900.......same as a mustang jet...that is also a P1 rating and no P2.

Yes, I do agree there should be a P2 sylabus for the 1900, but until then, the sylabus and the law says it is a certified single crew operation and thus a P1.

Regardless of what I think, or anyone else thinks, my question is......where does the operator or PIC stand should there be an accident or incident, as far as the insurance and law goes.

Are the co pilots hours valid, remember the fiasco of the Caravan co pilot hours not being recognised as it was said you dont need a co pilot in a caravan.

There is a fine line beteween my interpretation and the next persons, but at the end of the day, should there be an incident or accident, whose interpretation is the law (yer), or insurance going to take.

The ONLY reason that you may fly a 1900 as PIC with a COMM, is because it is certified as a SINGLE CREW OPERATION, even though it is heavier than 12500 lbs and in my interpretation, sinlgle crew operation means P1, regardless of whether i agree with beckers or not....(sorry beckers, I am not being personal).

Burner, by the way, it is up to the PIC to check whether the person next to him is still legal, as the onus falls onto your lap should you get to Bloemfontein enroute to Cape Town with a 100 pax in the back only to find out that your co pilots dangerouse goods certificate expired the day before and everyone forgot......ooooooo sheeeevers, now you are going no where until new cojo arrives......no matter where the company quality failed, you are still PIC........another words, the boss.

Yes, I know, in real life, we dont check, we assume.

What would be nice, is, if someone from the SACAA could give us clarity on the 1900 P2/P1 saga and put it in writing whether the P2 is in fact legal or not, regardless of what an instructor or the person issueing the licences think and me for that matter.

Goffel.
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Re: B1900 : P2 Rating

Unread post by beckers » Tue May 22, 2012 5:23 pm

The B190 is unique because not all the manuals and Certification requirements are the same. Thus it does not fall under the same as a BE20 or C406.

2 Arguments here:

1. B190 are not all simply "Single Crew" aircraft. Hence an ATPL should be operating a B190-D under Part 121 and hence in essence the P2 does exist

2. The B190 (all series) is a "Single Crew" aircraft. Hence a Comm may captain the B190 under Part 121 and hence the P2 does not exist.

Unfortunately the CAA has accepted both and not decided which one to choose. (It is unfortunately an interpretation choice).

I personally go with option 1 but it suits the industry better to go with option 2.

So under the above argument the following will apply under Part 121.
B190-D - Capt ATPL P1, F/O Comm P2 - LEGAL
B190-D - Capt Comm P1, F/O Comm P2 - ILLEGAL
B190-C - Capt Comm P1, F/O Comm P1 - LEGAL
B190-C - Capt Comm P1, F/O Comm P2 - ILLEGAL?????

All very grey, we will not find the answer here. Best is to get some-one at the CAA to take a stand and let the industry know and thus correct the issue.

Oh wait, you are more likely to get an elephant with pink toenails flying by......
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Re: B1900 : P2 Rating

Unread post by Burner » Tue May 22, 2012 6:22 pm

I completely understand where you guys are coming from, and you are totally correct that this grey area will exist until such time as the CAA has the balls to clarify it and turn it into black and white. I'm a CPL 1900D Captain, with 1000 hours in the left seat. I have been flying the 1900 for 4 years, and joined my current company with all the requirements for an ATP, i.e. hours and exams. However because local operators don't require an ATP, there is no difference in salary whether I have a CPL or an ATP, so why should I invest my own cash to upgrade my licence at my own cost?

Should the CAA step in and require (as they should) that 1900 PAX operators put a "green book" in the left, they would be forced to make it more lucrative for their P1's.

Goffel I also do agree that it is a responsibility of a P1 to ensure that all crew members are correctly licensed, but I'd be interested to know how many P1's routinely check the licences of their P2's and indeed flight attendants. It's something that I guess you get apathetic about, and incorrectly assume that the company will make sure of. Again you are completely correct though, what happens in the book and what happens on the line is totally different (not all operators can afford a 3 hours prior to off blocks sign on time, in order to audit all the paper work associated with the aircraft, the operation, the line station, etc, etc, etc)
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There is no gray area

Unread post by MilesvdM » Tue May 22, 2012 9:43 pm

It is simply not true that you require 2 crew to operate under Part 121. In VMC you can fly a 1900C with 19 passengers all day long on your own. Also if you meet the autopilot requirement then IMC can be undertaken on the same basis. Note its an IMC limitation, not an IFR limitation.

A 1900D is single pilot certified. Under some conditions as specified in Section 2 it requires 2 crew but the aircraft is still certified for single pilot operation.

Why the CAA issued P2 ratings on this type is indeed a mystery. But when you look closely at it you will find that the identifier they use in the flight crew license is not in fact the same as that specified in CATS-FCL. We asked why this would be but they must still be looking into it because they haven't replied yet........one year later.

Remember the in the US 1900 freighters are flown at night in IF, single crew with no autopilot in the worst weather you can imagine. Every night with a fantastic safety record. It is not a difficult aeroplane to fly, in fact its one of the easiest. If you increase the operating cost even further you simply decrease the size of the market.

Aviation professionals need to be less greedy and more grateful that they have a job in the first place. Look around you, the industry is hurting.
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Re: There is no gray area

Unread post by Burner » Tue May 22, 2012 10:27 pm

MilesvdM wrote: Aviation professionals need to be less greedy and more grateful that they have a job in the first place. Look around you, the industry is hurting.
I tend to agree with you, up to the last statement...

The industry is certainly battling, but yet operators are expanding rather rapidly with new turbo props and small jets :evil: :evil: It has happened in the past where a surplus of crew has resulted in a trend to pay a lot less than was market par in the preceding years.

Greed is definitely a problem, but predominantly not in the area you have laid blame.

Cat.... Pigeons... Popcorn... awaiting nasty threatening PM again... :smt026 :smt026 :smt026 :smt026
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Re: B1900 : P2 Rating

Unread post by Piperdriver » Wed May 23, 2012 10:34 am

Hasn't the CAA now scrapped the whole B190 P2 rating? Thought you can only get a P1 rating nowadays?

Burner, Im with you, supply and demand has meant that there is a surplus of crew out there and the ones with jobs are not getting what they used to get.

Heard a story the other day,therefore can't verify if its true or not, of a guy who paid up for his 737 rating with Vevlet Sky, before he could begin his training the doors slammed shut and he lost his cash in the ensuing chaos. Point is as long as there are guys out there who are prepared to pay their own way, pilot salaries and terms of employment will continue to erode. Especially in the GA side of the industry.
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Re: B1900 : P2 Rating

Unread post by MilesvdM » Wed May 23, 2012 11:23 am

Be fair Burner, its at least a midsized jet...

I can't speak for other operators but we don't partake in the salary auction. For staff to stay it needs to be a fair deal, and a fair deal for both sides. If either side has their back to the wall the whole arrangement is temporary. As we have said in many interviews, we aren't the biggest pay cheque out there, but we are the one that pay on time every month.

The margins in aviation are thin and there are many hands in the queue that need to be paid. It isn't the honey pot that some think. If money is your driver then the plumbing industry is probably more likely to give you what you need.

The regs should allow for P2's on the 1900's. It allows inexperienced pilots the chance to be exposed to an aircraft larger and more complex than those they trained on. The contraction of the small aircraft charter market has made it more difficult for new entrant to get started. P2 positions in aeroplanes that are single pilot certified is a way to narrow the gap a little.

Lost me on the popcorn reference.
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Re: B1900 : P2 Rating

Unread post by Burner » Wed May 23, 2012 11:58 am

Hi Miles,

I wasn't talking about your outfit... since I don't work for them I was talking about another well known, a lot larger operator. I think operators very often forget how privy us "peelots" are to the costs associated with operating aircraft in deepest dark Africa.

To not be given a decent paycheck, while a company is rapidly expanding, despite a recession, is a slap in the face, and certainly affects morale. I am an aviation professional who has worked incredibly hard to get to where I am now (self funded), and deserve to be treated like one.

Fortunately I work for a company that treats me very well, doesn't cut corners or ask me to do anything illegal, and at the end of the day I get a decent chunk of cheese to take home. Unfortunately there are other operators who have the mentality "Aviation professionals need to be less greedy and more grateful that they have a job in the first place."... that's a total load of <<moderated - language>>. :evil: :evil: :evil: :evil: :evil:
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Re: B1900 : P2 Rating

Unread post by MilesvdM » Wed May 23, 2012 12:43 pm

Yip, perhaps I stated that a bit strongly. As I said, everyone is due a fair deal. I agree, many have a very different outlook.

Not sure who you are refering to but over the years we have all seen a few operators who expand rapidly only to contract even more rapidly a few years on. Please not another one, they do so much damage for all.
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Re: B1900 : P2 Rating

Unread post by Goffel » Wed May 23, 2012 1:11 pm

So we all agree that it is still a grey area........now without being rude.......what happens when an incident or accident occurs........is the P2 legal or not legal......and yes, only CAA can give that answer on paper.

As much as i am niggling for an answer, wud the insurance pay, cud we as the PIC be sued by the operator for no pay out by the insurance if they rule against.

I personally want clarity before i fly with a co pilot with a P2 in his/her licence.

Goffel.
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Re: B1900 : P2 Rating

Unread post by macdaddy » Wed May 23, 2012 2:28 pm

If everyone is getting no joy from the CAA, which could be indefinite, would someone at the insurance comapany who insures your aircraft not be able to give you the answer you are looking for?

While on the subject, when I got my rating on a Caravan 5 or 6 years ago, the CAA issued it as a P2 rating. What a joke! Some things will never change it seems!

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