Narrative:

6 air carrier a employees unqualified on my type aircraft (medium large transport), were scheduled by my company, air carrier a to deadhead on my aircraft which was placed into a cargo dispatch condition. A company interpretation of far 121.583 is as follows: 'if minimum far flight attendants requirement cannot be met, far 121.583 permits the carriage of air carrier a and air carrier corp and air carrier B crew members, air carrier a company employees, FAA and NTSB personnel in the cabin. There is no limit to the number of such persons that may be carried....' air carrier a is using this interpretation of the far to move their minimally qualified people (8 days training) on non passenger flts. I question the intent of the far. Since in this case it places the captain and first officer in the position of being the only fully qualified people on board. It is possible from this interpretation that a fully loaded (142 people) medium large transport could be dispatched without any qualified people behind the cockpit door. In the event of an emergency evacuate/evacuation, chaos would result. No evacuate/evacuation commands would be given, and far evacuate/evacuation timing would not be met. Since on my flight 6 persons only were involved, safety was not too badly compromised. I have submitted this report because I feel the FAA may not interpret far 121.583 as air carrier a does and decides to take punitive action against crew members involved.

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Original NASA ASRS Text

Title: AN ACR MLG PLT QUESTIONS THE LEGALITY OF HIS ACR'S ACTION IN A RECENT STRIKE REGARDING CARRYING COMPANY PERSONNEL WITHOUT FLT ATTENDANTS ABOARD.

Narrative: 6 ACR A EMPLOYEES UNQUALIFIED ON MY TYPE ACFT (MLG), WERE SCHEDULED BY MY COMPANY, ACR A TO DEADHEAD ON MY ACFT WHICH WAS PLACED INTO A CARGO DISPATCH CONDITION. A COMPANY INTERP OF FAR 121.583 IS AS FOLLOWS: 'IF MINIMUM FAR FLT ATTENDANTS REQUIREMENT CANNOT BE MET, FAR 121.583 PERMITS THE CARRIAGE OF ACR A AND ACR CORP AND ACR B CREW MEMBERS, ACR A COMPANY EMPLOYEES, FAA AND NTSB PERSONNEL IN THE CABIN. THERE IS NO LIMIT TO THE NUMBER OF SUCH PERSONS THAT MAY BE CARRIED....' ACR A IS USING THIS INTERP OF THE FAR TO MOVE THEIR MINIMALLY QUALIFIED PEOPLE (8 DAYS TRAINING) ON NON PAX FLTS. I QUESTION THE INTENT OF THE FAR. SINCE IN THIS CASE IT PLACES THE CAPT AND FO IN THE POS OF BEING THE ONLY FULLY QUALIFIED PEOPLE ON BOARD. IT IS POSSIBLE FROM THIS INTERP THAT A FULLY LOADED (142 PEOPLE) MLG COULD BE DISPATCHED WITHOUT ANY QUALIFIED PEOPLE BEHIND THE COCKPIT DOOR. IN THE EVENT OF AN EMER EVAC, CHAOS WOULD RESULT. NO EVAC COMMANDS WOULD BE GIVEN, AND FAR EVAC TIMING WOULD NOT BE MET. SINCE ON MY FLT 6 PERSONS ONLY WERE INVOLVED, SAFETY WAS NOT TOO BADLY COMPROMISED. I HAVE SUBMITTED THIS RPT BECAUSE I FEEL THE FAA MAY NOT INTERPRET FAR 121.583 AS ACR A DOES AND DECIDES TO TAKE PUNITIVE ACTION AGAINST CREW MEMBERS INVOLVED.

Data retrieved from NASA's ASRS site as of July 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.