Narrative:

I am filing this report regarding a predicament that I have found myself in. I am employed as a line pilot for a part 135 operator. All pilots have a minimum of 1200 hours in order to meet far 135.293 and 297 requirements. As stated by far 135.297, all pilots are required to pass an instrument proficiency check every 6 months, which shall be done by the last day of the month in which it is due. The FAA also grants a 30 day or 1 month grace period in order to accomplish this. My date of employment with my company is december, therefore my base months for my proficiency checks are december and june. In june/96 I verbally informed my chief pilot that my 6 month proficiency check was due. His response was a question concerning whether june was my base month or my grace month. Since june was my base month, it was his decision to wait until july, my grace month. I did not understand nor was I given a reason for this delay. 1 month later, while discussing the july schedule, I again informed my chief pilot that I was now into my grace month and that I was due my proficiency check. His response was a simple okay and that we would get together sometime during the month of july and do it. Once again I reminded my chief pilot that my proficiency check was still due. His response at this time was again a simple ok. On the morning of jul/xx/96 I informed my chief pilot that there were now only a few days left in which to complete my proficiency check. His response was a look of astonishment and confusion. Since he is the only person qualified to give me a proficiency check in the aircraft that I fly, we now had a problem. He was leaving for louisiana and would be gone all week. His solution was for me to complete the instrument portion of my chkride in a piper lance PA32R-300 and when he returned we would do a make and model check in a C208, the aircraft that I was due my proficiency check in. I doubted his solution to this problem, a problem that I might add could have easily been avoided. I decided it was now time to involve the owner/directorof operations of the company. On the morning of jul/yy/96 I questioned my director of operations about my chkride status. He seemed somewhat dismayed about the situation and said that before he could give me an answer he needed to look into my file at his office. That day, around XA00 pm, I received a long distance phone call from my director of operations. He explained to me the situation as he understood it. According to him, as of aug/xx/96 I still had 30 days left in make and model C208 VFR only. As of aug/yy/96 I was not to fly IFR, file IFR or fly in IMC conditions. I was to fly VFR only at all times until my far 135.297 proficiency check was completed. Since he was the owner and director of operations, and in my opinion more knowledgeable of the situation, I chose to follow his advice. On aug/zz/96 I was informed that the chief pilot would be returning. It was friday and my director of operations asked if I would like to do my proficiency check that night. I responded with a definite yes, let's get this done, no sense in delaying it any longer. Consequently, that evening my proficiency check was completed successfully. The chief pilot and I discussed the chkride while I gave him a ride back to his vehicle. At the conclusion of our post chkride review, he said that he did not have any FAA forms 8410-3 with him. He would get it to me on monday before I left on a trip. He also stated, to my shock, that he would be back dating the date of my proficiency check to sometime in july on form 8410-3. I did not understand why this was necessary since I was under the impression from both the director of operations and the chief pilot that we were operating in compliance with the FARS. Deliberate, fallacious statements made on a legal FAA document is wrong. I want it known at this time that I do not agree with this practice nor do I condone it. My personal logbook, pilot duty time log sheet and the aircraft flight time log sheet will correctly show the date of aug/yy/96, as the day of my proficiency chkride. These documents were filled out by myself aspic of the aircraft at that time. In conclusion, this whole situation could have been avoided simply by doing my proficiency check in the month that it was due. There was no reason to delay what could have been accomplished in a matter of a few hours. The 30 day grace period is clearly a regulation that was abused in this case. In my opinion, the 30 day grace period is unnecessary. One month is more than enough time to schedule and complete a proficiency check. It is a regulation that is ripe for abuse. A classic case of giving someone an inch and their taking a mi.

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Original NASA ASRS Text

Title: PLT OF A CESSNA 208 ATX CARGO WAS INFORMED BY HIS CHIEF PLT AFTER COMPLETION OF A 6 MONTH PROFICIENCY FLT, THAT THE CHK FLT WOULD BE RECORDED IN HIS COMPANY PLT RECORDS AS BEING COMPLETED IN THE PRIOR MONTH IN ORDER TO COINCIDE WITH HIS GRACE PERIOD MONTH THE CHK WAS DUE.

Narrative: I AM FILING THIS RPT REGARDING A PREDICAMENT THAT I HAVE FOUND MYSELF IN. I AM EMPLOYED AS A LINE PLT FOR A PART 135 OPERATOR. ALL PLTS HAVE A MINIMUM OF 1200 HRS IN ORDER TO MEET FAR 135.293 AND 297 REQUIREMENTS. AS STATED BY FAR 135.297, ALL PLTS ARE REQUIRED TO PASS AN INST PROFICIENCY CHK EVERY 6 MONTHS, WHICH SHALL BE DONE BY THE LAST DAY OF THE MONTH IN WHICH IT IS DUE. THE FAA ALSO GRANTS A 30 DAY OR 1 MONTH GRACE PERIOD IN ORDER TO ACCOMPLISH THIS. MY DATE OF EMPLOYMENT WITH MY COMPANY IS DECEMBER, THEREFORE MY BASE MONTHS FOR MY PROFICIENCY CHKS ARE DECEMBER AND JUNE. IN JUNE/96 I VERBALLY INFORMED MY CHIEF PLT THAT MY 6 MONTH PROFICIENCY CHK WAS DUE. HIS RESPONSE WAS A QUESTION CONCERNING WHETHER JUNE WAS MY BASE MONTH OR MY GRACE MONTH. SINCE JUNE WAS MY BASE MONTH, IT WAS HIS DECISION TO WAIT UNTIL JULY, MY GRACE MONTH. I DID NOT UNDERSTAND NOR WAS I GIVEN A REASON FOR THIS DELAY. 1 MONTH LATER, WHILE DISCUSSING THE JULY SCHEDULE, I AGAIN INFORMED MY CHIEF PLT THAT I WAS NOW INTO MY GRACE MONTH AND THAT I WAS DUE MY PROFICIENCY CHK. HIS RESPONSE WAS A SIMPLE OKAY AND THAT WE WOULD GET TOGETHER SOMETIME DURING THE MONTH OF JULY AND DO IT. ONCE AGAIN I REMINDED MY CHIEF PLT THAT MY PROFICIENCY CHK WAS STILL DUE. HIS RESPONSE AT THIS TIME WAS AGAIN A SIMPLE OK. ON THE MORNING OF JUL/XX/96 I INFORMED MY CHIEF PLT THAT THERE WERE NOW ONLY A FEW DAYS LEFT IN WHICH TO COMPLETE MY PROFICIENCY CHK. HIS RESPONSE WAS A LOOK OF ASTONISHMENT AND CONFUSION. SINCE HE IS THE ONLY PERSON QUALIFIED TO GIVE ME A PROFICIENCY CHK IN THE ACFT THAT I FLY, WE NOW HAD A PROB. HE WAS LEAVING FOR LOUISIANA AND WOULD BE GONE ALL WK. HIS SOLUTION WAS FOR ME TO COMPLETE THE INST PORTION OF MY CHKRIDE IN A PIPER LANCE PA32R-300 AND WHEN HE RETURNED WE WOULD DO A MAKE AND MODEL CHK IN A C208, THE ACFT THAT I WAS DUE MY PROFICIENCY CHK IN. I DOUBTED HIS SOLUTION TO THIS PROB, A PROB THAT I MIGHT ADD COULD HAVE EASILY BEEN AVOIDED. I DECIDED IT WAS NOW TIME TO INVOLVE THE OWNER/DIRECTOROF OPS OF THE COMPANY. ON THE MORNING OF JUL/YY/96 I QUESTIONED MY DIRECTOR OF OPS ABOUT MY CHKRIDE STATUS. HE SEEMED SOMEWHAT DISMAYED ABOUT THE SIT AND SAID THAT BEFORE HE COULD GIVE ME AN ANSWER HE NEEDED TO LOOK INTO MY FILE AT HIS OFFICE. THAT DAY, AROUND XA00 PM, I RECEIVED A LONG DISTANCE PHONE CALL FROM MY DIRECTOR OF OPS. HE EXPLAINED TO ME THE SIT AS HE UNDERSTOOD IT. ACCORDING TO HIM, AS OF AUG/XX/96 I STILL HAD 30 DAYS LEFT IN MAKE AND MODEL C208 VFR ONLY. AS OF AUG/YY/96 I WAS NOT TO FLY IFR, FILE IFR OR FLY IN IMC CONDITIONS. I WAS TO FLY VFR ONLY AT ALL TIMES UNTIL MY FAR 135.297 PROFICIENCY CHK WAS COMPLETED. SINCE HE WAS THE OWNER AND DIRECTOR OF OPS, AND IN MY OPINION MORE KNOWLEDGEABLE OF THE SIT, I CHOSE TO FOLLOW HIS ADVICE. ON AUG/ZZ/96 I WAS INFORMED THAT THE CHIEF PLT WOULD BE RETURNING. IT WAS FRIDAY AND MY DIRECTOR OF OPS ASKED IF I WOULD LIKE TO DO MY PROFICIENCY CHK THAT NIGHT. I RESPONDED WITH A DEFINITE YES, LET'S GET THIS DONE, NO SENSE IN DELAYING IT ANY LONGER. CONSEQUENTLY, THAT EVENING MY PROFICIENCY CHK WAS COMPLETED SUCCESSFULLY. THE CHIEF PLT AND I DISCUSSED THE CHKRIDE WHILE I GAVE HIM A RIDE BACK TO HIS VEHICLE. AT THE CONCLUSION OF OUR POST CHKRIDE REVIEW, HE SAID THAT HE DID NOT HAVE ANY FAA FORMS 8410-3 WITH HIM. HE WOULD GET IT TO ME ON MONDAY BEFORE I LEFT ON A TRIP. HE ALSO STATED, TO MY SHOCK, THAT HE WOULD BE BACK DATING THE DATE OF MY PROFICIENCY CHK TO SOMETIME IN JULY ON FORM 8410-3. I DID NOT UNDERSTAND WHY THIS WAS NECESSARY SINCE I WAS UNDER THE IMPRESSION FROM BOTH THE DIRECTOR OF OPS AND THE CHIEF PLT THAT WE WERE OPERATING IN COMPLIANCE WITH THE FARS. DELIBERATE, FALLACIOUS STATEMENTS MADE ON A LEGAL FAA DOCUMENT IS WRONG. I WANT IT KNOWN AT THIS TIME THAT I DO NOT AGREE WITH THIS PRACTICE NOR DO I CONDONE IT. MY PERSONAL LOGBOOK, PLT DUTY TIME LOG SHEET AND THE ACFT FLT TIME LOG SHEET WILL CORRECTLY SHOW THE DATE OF AUG/YY/96, AS THE DAY OF MY PROFICIENCY CHKRIDE. THESE DOCUMENTS WERE FILLED OUT BY MYSELF ASPIC OF THE ACFT AT THAT TIME. IN CONCLUSION, THIS WHOLE SIT COULD HAVE BEEN AVOIDED SIMPLY BY DOING MY PROFICIENCY CHK IN THE MONTH THAT IT WAS DUE. THERE WAS NO REASON TO DELAY WHAT COULD HAVE BEEN ACCOMPLISHED IN A MATTER OF A FEW HRS. THE 30 DAY GRACE PERIOD IS CLRLY A REG THAT WAS ABUSED IN THIS CASE. IN MY OPINION, THE 30 DAY GRACE PERIOD IS UNNECESSARY. ONE MONTH IS MORE THAN ENOUGH TIME TO SCHEDULE AND COMPLETE A PROFICIENCY CHK. IT IS A REG THAT IS RIPE FOR ABUSE. A CLASSIC CASE OF GIVING SOMEONE AN INCH AND THEIR TAKING A MI.

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.