{"id":237,"date":"2015-02-24T16:16:32","date_gmt":"2015-02-24T16:16:32","guid":{"rendered":"https:\/\/www.aircrewacademy.com\/blog\/2015\/02\/24\/grace-provisions\/"},"modified":"2018-07-03T18:20:15","modified_gmt":"2018-07-03T18:20:15","slug":"grace-provisions","status":"publish","type":"post","link":"https:\/\/www.aircrewacademy.com\/blog\/grace-provisions\/","title":{"rendered":"Grace Provisions"},"content":{"rendered":"<p>&nbsp;<\/p>\n<p style=\"margin-left: 30px;\">If a crewmember who is required to take a test or a flight check under this part, completes the test or flight check in the calendar month before or after the calendar month in which it is required, that crewmember is considered to have completed the test or check in the calendar month in which it is required.<\/p>\n<p>What about the training requirements in 135 Subpart H? 135.343 specifies that a crewmember must have completed the appropriate initial or recurrent phase of the training program within the preceding 12 calendar months. Does 135.301 provide grace provisions for these 12 month training requirements? As it turns out, the concerns about applying 135.301 to training requirements were unnecessary. The grace period for training is provided in 135.323(b):<\/p>\n<p style=\"margin-left: 30px;\">Whenever a crewmember who is required to take recurrent training under this subpart completes the training in the calendar month before or the calendar month after the month in which that training is required, the crewmember is considered to have completed it in the calendar month in which it was required.<\/p>\n<p>Talking about due months and grace provisions may be as exciting as watching the grass grow, but, as pilots, we share responsibility with our air carrier certificate holder to ensure we are qualified and current before accepting an assignment for a Part 135 trip.<\/p>\n<p>The bottom line is that grace provisions apply to both training and checking. The FAA legal interpretations we consulted also confirm these findings.<\/p>\n","protected":false},"excerpt":{"rendered":"<p><img loading=\"lazy\" decoding=\"async\" style=\"margin: 5px; float: right;\" alt=\"iStock 000020182560 Medium\" src=\"images\/iStock_000020182560_Medium.jpg\" height=\"166\" width=\"250\" \/>In a recent discussion with a Part 135 operator, I was asked whether the grace month provisions in 14 CFR 135.301 that apply to checking also apply to training. I had to admit that I have not committed the entire book of regulations to memory, but had always assumed that 135.301 applied to training as well as checking. If not, a pilot whose recurrent training and check ride was scheduled for later in his or her grace-late month would not be legal to fly in the beginning of that month because the training would be considered overdue. No one involved in our discussion had ever heard of a POI raising this issue. However, even if a POI interpretation allowed an operator to consider 135.301 as applicable to training, what would a judge or a jury say about it in the aftermath of an accident?<\/p>\n<p>Let\u2019s review the regulations on this subject.<\/p>\n<p>Crewmember testing (a.k.a. checking) requirements are in 135 Subpart G. The completion of an Initial or Requalification check ride, such as a competency check required by 135.293, establishes the pilot\u2019s base month for that check. Thereafter, recurrent checks are required at the interval called for in the applicable regulation, in the case of a 293 check, every 12 months. The due month for these recurrent checks is based on the Initial checkunless the pilot\u2019s qualification lapses and a Requalification check is required, which then establishes a new base month. Fortunately, the FAA recognized the need for more flexibility for operators and pilots and made provisions for grace months in 135.301(a):<\/p>\n","protected":false},"author":19,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[2],"tags":[142],"class_list":["post-237","post","type-post","status-publish","format-standard","hentry","category-blog","tag-14-cfr-135-301checkingtraininggrace-late-monthinitial-or-requalification-check-ride135-293base-monthrecurrent-checks135-subpart-h135-343"],"_links":{"self":[{"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/posts\/237","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/users\/19"}],"replies":[{"embeddable":true,"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/comments?post=237"}],"version-history":[{"count":1,"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/posts\/237\/revisions"}],"predecessor-version":[{"id":644,"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/posts\/237\/revisions\/644"}],"wp:attachment":[{"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/media?parent=237"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/categories?post=237"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.aircrewacademy.com\/blog\/wp-json\/wp\/v2\/tags?post=237"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}