61.3(d) question

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dsffdssdf

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This is something that has been on my mind for a while. The gist of 61.3(d) is that if a flight instructor is exercising the privileges of his CFI certificate while in the airplane, he must have that certificate on board with him. This is what I don't understand, when do you ever exercise your CFI privileges in an airplane? As far as I understand things, the act of giving instruction is not a privilege in an of itself. You can give instruction as a commercial pilot without a CFI, it just won't count towards a certificate or rating. The only privilege a CFI certificate gives you is the ability to sign your name in the student's logbook and 8710 form, which you always do on the ground, outside the plane.

Lets say you're a CFI and you're about to embark on a flight with a friend of yours who is a Private pilot who happens to be working on his instrument rating. The way I guess the regulation is intended to mean is that if you're planning on giving this student instruction, and having it count towards his instrument rating, you must have that certificate on board with you. But if you're just flying for fun, then you don't need your CFI certificate onboard with you because you won't be using that certificate.

Here lies the problem: If you were ramp checked, how is the FAA supposed to determine which situation is about to occur; friendly CFI/pilot flight where no instruction is given, or pilot instruction? The act of making the instruction "official" (and therefore requireing the CFI certificate) occurs after the flight when the CFI signs the student's logbook. It seems like the FAA has no way of enforcing this regulation. What are some of your thoughts on this?
 
I think you're looking for a lot of teeny detail in something that is pretty straight-forward.

Take your scenario and lets get rid of the CFI altogether. It's 2 pilots. They're ramp checked. One has his pilot certificate; one doesn't. So, how does the Inspector know which one was planning on acting as PIC?

Or let's say both have their pilot certificate but one doesn't have his medical. How does the inspector know whether one was going to be a safety pilot and who was going to be PIC on the flight?

Or, let's say that there are two pilots dancing on the head of a pin. How does the inspector know...

These kinds of questions tend to be very context-deficient, and the assumption is that no one has any way of knowing anything that isn't staring him in the face at that specific moment.
 
midlifeflyer said:
I think you're looking for a lot of teeny detail in something that is pretty straight-forward.

Take your scenario and lets get rid of the CFI altogether. It's 2 pilots. They're ramp checked. One has his pilot certificate; one doesn't. So, how does the Inspector know which one was planning on acting as PIC?
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Does it matter? When I was in college, me and some friends spent the weekend in Winsor, Canada, where the legal age to buy alcohol is 19. We bought a ton of beer, so we brought most of it back into the US. When we went through customs, the guy asked us if we had brought anything back. The driver said "yes, we have a bunch of beer in the trunk". He asked the driver how old he was, the driver said "20". Then he asked the passenger how old she was, she said "19", he then asked me, in the backseat how old I was, I said "21". The customs officer then seemd really relieved and then said "It's a good thing he is 21, or I would have arrested all of you".

He didn't ask who owned the beer, because it doesn't matter. The same goes for being ramp checked. It doesn't matter who is the PIC, all that matters is if there is a PIC capable person on board.


These kinds of questions tend to be very context-deficient, and the assumption is that no one has any way of knowing anything that isn't staring him in the face at that specific moment.
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The enforcement issue really wasn't my point. The point is the regulations say that you must have your instructor certificate on board with you when you exercise the privileges of that instructor in an airplane. There are no instructor privileges that can be exercised in an airplane.

Its like the regs saying that in order to give a speech at an aviation conference as a commercial pilot, you must have your commercial certificate on your person during the speech. Its a weird regulation that doesn't make any sense.
 
Would you really want to test the FAA if they suspected you were doing more than giving a friend a few pointers on how to improve? I wouldn't.

They don't always win but they certainly have the "home court" advantage.
 
KennyFlys said:
Would you really want to test the FAA if they suspected you were doing more than giving a friend a few pointers on how to improve? I wouldn't.

They don't always win but they certainly have the "home court" advantage.
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Imagine a non-CFI commercial pilot and a pre-solo student holding short for takeoff. Under all circumstances is perfectly legal. If they were ramp checked, there is no reason to suspect wrong-doing. Correct?

Now imagine that commercial pilot happens to hold a CFI certificate but doesn't have it with him. How has this fact changed anything? There is no way to prove that they had intended to log thr time as official "8710 approved" dual given, since they haven't logged the flight yet. What make it now all the suden a violation of 61.3(d)? Is it even possible for a CFI to still be able to fly with other pilots in the same way a non-CFI commercial pilot can? If so, then what factors can the FAA use to determine whether or no the CFi intended to use his CFI certificate or not? If not, then why doesn't rhe FAA just come right out and say that if you happen to hold a CFI certificate, then you must have it on you at all times when you are flying?


Does having a CFI certificate somehow remove your ability to fly with anyone else without requiring the use of that CFI certificate? It seems to me like a paradox.
 
Imagine, imagine, imagine. Tell you what. Go try it out and let us know how it worked out for you. If you have no problems, perhaps a move to vegas or atlantic city should be in your future 'cause you are a pretty lucky person/
 
Maybe speed limit signs on highways should read "Speed Limit 65mph when in presence of Law Enforcement Officials"...............
 
Rotor&Wing said:
Maybe speed limit signs on highways should read "Speed Limit 65mph when in presence of Law Enforcement Officials"...............
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You're not understanding my point. It is absolutely, 100% impossible to prove that an instructor violated this regulation because the only proof that exists (the logbook entry) is created after the fact.

I'm saying all instructors should start instructing without their certificates on them, I'm just pointing out that this one regulation is very poorly worded and makes absolutely no sense, and hoping someone could clear this up for me, since it's something I have had on my mind for a while.

It would be like if speed limits were worded "No going over 65 mph unless you reach your destination 10 minutes earlier". There is absolutely no way to determine that you violated this until to reach your destination. I guess the cop could radar gun you, then follow you home and give you a ticket as you arrive, in the same way a FAA officer can witness you flying without your CFI card then follow you into the FBO and write up your violation notice letter as you sign the student's logbook. Thats a poor example, but its not as simple as you claim I'm making this.
 
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dsffdssdf said:
I'm saying all instructors should start instructing without their certificates on them, I'm just pointing out that this one regulation is very poorly worded and makes absolutely no sense, and hoping someone could clear this up for me, since it's something I have had on my mind for a while.
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I think you need a hobby.:rolleyes:
 
dsffdssdf said:
You're not understanding my point. It is absolutely, 100% impossible to prove that an instructor violated this regulation because the only proof that exists (the logbook entry) is created after the fact.
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Let's see now....

A review of the student's logbook shows that the CFI has given him 30 hours of instruction. The CFI's logbook shows the same. Both logbooks show they've never flown together unless instruction was being given. The student rented the airplane from the flight school they've always rented from before and the airplane was rented for the standard "lesson time."

And (most important in this scenario) the FAA inspector had some reason (real or imagined) to want to give the CFI a hard time.

You're saying that it's "100% impossible" for the FAA to satisfy a NTSB judge that it was "more likely than not" that the CFI was exercising the flight instructor privilege to "give training" (see FAR 61.93)?

I guess we disagree on what's possible and what is not.
 
midlifeflyer said:
Let's see now....
A review of the student's logbook shows that the CFI has given him 30 hours of instruction. The CFI's logbook shows the same. Both logbooks show they've never flown together unless instruction was being given. The student rented the airplane from the flight school they've always rented from before and the airplane was rented for the standard "lesson time."
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But what if you were truly intending to do a pleasure flight and not give instruction? The FAA could still bust you, according to your reasoning, if that instructor had given that student instruction in the past. You are assuming the only reason a CFI holding pilot should ever be in a plane with another pilot is to give instruction. There are lots of times I can think of where a CFI could fly with a previous or current student without the intent of receiving instruction. How is the FAA determining which situation is occuring?

Just like how there are guidelines to follow that ensure you aren't accused to doing an illegal charter (pro-rata share, etc), there should also be guidelines for CFI holding commercial pilots so they aren't accused of operating as an instructor in times when they shouldn't be.

This is important not only for the context of this one particular regulation, but also in general. If I hold a CFI certificate, and I'm flying with someone, and the FAA sees me as a CFI acting as a CFI, I think thats pretty important thing to be aware of. Knowing where the FAA draws the line between commercial pilot flying with another person, and CFI giving instruction to another person is a pretty important thing for a professional aviator, imo.

And (most important in this scenario) the FAA inspector had some reason (real or imagined) to want to give the CFI a hard time.
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Typically when you are ramp checked, if you're curtious the instector will look the other way on a lot of things. If you aren't, lets say you ticked off the guy, he will make your life a living hell. He won't look the other way on anything. He is still limited to the regulations though. He can't just make up stuff you nail you on. The regulations go both ways. I see this attitude some up a lot on internet forums. People assume the FAA has the power to do anything they want. That is not the case. They have to answer to the regulations the same way we do.

I'm not calling you out personally, it's just something I've seen a lot.

You're saying that it's "100% impossible" for the FAA to satisfy a NTSB judge that it was "more likely than not" that the CFI was exercising the flight instructor privilege to "give training" (see FAR 61.93)?

I guess we disagree on what's possible and what is not.
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I think is just as easy to prove you were just doing a pleasure flight.

Anyways, this is all assuming that of you plan on signing the logbook, then that makes the instruction exercising the privelages of the flight instructor certificate, which I'm not 100% sure is the case. You can legally give instruction with a commercial license ("instruction" in the generic sense), so why would the CFI certificate ever come into play? Does it say anywhere in the regs that you can't teach people stuff in airplanes unless you have a CFI certificate? Has the FAA ever published anything that implies (or outright states) that if you hold a CFI certificate and are giving instructing, that you are giving instruction according to your CFI certificate, regardless of how it's logged?
 
There was a case cited by either Mark or Ron where two friends flying together and they became involved in an incident. I cannot recall the particulars but let's see how much I do recall. Either way, this is a realistic scenario.

The FAA and NTSB held Pilot One responsible over Pilot Two even though it was Pilot Two who was actually the sole manipulator of the controls at the time of the incident. Why? Because Pilot One held a CFI ticket.

The CFI being there and not exercising privileges under his CFI ticket was irrelevant. His position alone was indication he should have known better than to allow circumstances to progress to the point of causing the incident.

Now, how do you think they are going to react to someone without a CFI ticket who appears to be doing more than offering a few tips?

By the above scenario, whether the CFI signs the log book or not is irrelevant. He's on the hook by simply holding the certificate whether it's in his pocket or back on the ground.
 
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I'm wondering why the CFI wouldn't have his certificate with him. My certificate is in my wallet so it goes everywhere with me. I assume that's the case for the vast majority of pilots.
 
I think everyone's missing his point (and I may have too):

You are required to have your CFI Certificate on you whenever you are exercizing the privlidges of that certificate in the airplane.

When are you exercizing the priviliges in an airplane?

The only time I can think of is when you have a chart in the back seat, and you're teaching the student with a pointer.

But its obvious that is not what the FAA intended. I think they meant anytime you are logging "Instruction Given" or whatever the fancy columns CFIs log is.
 
kkoran said:
I'm wondering why the CFI wouldn't have his certificate with him. My certificate is in my wallet so it goes everywhere with me. I assume that's the case for the vast majority of pilots.
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Both my certificates are in a holder along with my medical certificate which is placed in my flight bag. Essentially, I never fly without my pilot certificate, CFI certificate nor my medical certificate.

But, I also won't simply fly with a friend and give them tips. I'll be asking for their log and documenting what was done followed by my signature and number. If you get instruction on a friendly level from a friend who is a CFI, ask for that. It's for your protection just as much as it is the friend who happens to be a CFI.
 
SkyHog said:
I think everyone's missing his point (and I may have too):

You are required to have your CFI Certificate on you whenever you are exercizing the privlidges of that certificate in the airplane.

When are you exercizing the priviliges in an airplane?

The only time I can think of is when you have a chart in the back seat, and you're teaching the student with a pointer.

But its obvious that is not what the FAA intended. I think they meant anytime you are logging "Instruction Given" or whatever the fancy columns CFIs log is.
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Yeah, you get the idea.

I've always viewed the CFI certificate much in the same way as I see a judge. The only time you are ever exercising your privileges as a judge is when you are handing down a decision. Anyone can put on the robe, anyone can sit in that fancy chair, anyone can have an office in the courthouse, etc. Heck, anyone can make a decision regarding a case. But only the person that has been elected judge can hand down a decision and have it matters in the court of law.

The same goes for CFI's. Anyone can teach lazy-8's, anyone can wear a nametag that says "instructor", but only people who hold that certification from the FAA can sign off a logbook and have it hold water in the eyes of the FAA.

Regardless of the topic of having the certificate on your person, it seems odd to me that the FAA would even refer to the location of acting as a instructor. Does it matter where the judge is located when he makes his decision? Why should it matter where a certified instructor acts as a certified instructor?

Its sort of like my example earlier about the FAA making a rule restricting giving speeches as a commercial pilot. You never, ever exercise your privliges as commercial pilot when you're NOT in a plane, so it seems odd that the FAA would make rules regarding the comemrcial certificate not relating to being in an airplane. Except in the case of an instructor certificate, its the other way around.
 
SkyHog said:
You are required to have your CFI Certificate on you whenever you are exercizing the privlidges of that certificate in the airplane.

When are you exercizing the priviliges in an airplane?

The only time I can think of is when you have a chart in the back seat, and you're teaching the student with a pointer.
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What about when a student pilot is at the controls in the left seat with no solo endorsements at all. Sounds like the CFI is required the be there.
 
citationxjl said:
What about when a student pilot is at the controls in the left seat with no solo endorsements at all. Sounds like the CFI is required the be there.
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A CFI is not required to be there. A private pilot or commercial pilot with a valid medical is all that is required.
 
dsffdssdf said:
Here lies the problem: If you were ramp checked, how is the FAA supposed to determine which situation is about to occur; friendly CFI/pilot flight where no instruction is given, or pilot instruction? The act of making the instruction "official" (and therefore requireing the CFI certificate) occurs after the flight when the CFI signs the student's logbook. It seems like the FAA has no way of enforcing this regulation. What are some of your thoughts on this?
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You're applying logic to the FAA...that's the problem! They probably wouldn't try to get you on this point alone, but it's just yet another charge they could make against you if you do something else wrong to draw their attention. Of course, if they're standing there as you're getting out of the plane/signing the student's logbook, they probably could enforce it.
 
dsffdssdf said:
A CFI is not required to be there. A private pilot or commercial pilot with a valid medical is all that is required.
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If the intention is to log the time it is. And yes..if the FAA walked up and asked you could say you were not giving instruction and not have the student log it. But you might have an angry student that just payed for a lesson.

So the FAA walks into a flight "School" and looks at the schedule and sees a dual flight with one of the flight school instructors and a student pilot on their 2nd flight. You land and try to explain to them that you were not giving instruction, just wasting the students money.

And you took off before sunrise and have to prove you had your nav lights on until sunrise. And how you stayed exactly 500ft below the clouds.
 
dsffdssdf said:
The gist of 61.3(d) is that if a flight instructor is exercising the privileges of his CFI certificate while in the airplane, he must have that certificate on board with him. This is what I don't understand, when do you ever exercise your CFI privileges in an airplane? As far as I understand things, the act of giving instruction is not a privilege in an of itself.
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You are wrong. Only an "authorized instructor" may give instruction (the actual word the FAA uses is "training") -- and that's either on the ground or in flight. See 14 CFR 61.1 for details. So, if it's not a CFI in the plane, there's no training going on, and when training is going on, the CFI is exercising the privileges of the CFI certificate.
 
dsffdssdf said:
Imagine a non-CFI commercial pilot and a pre-solo student holding short for takeoff. Under all circumstances is perfectly legal. If they were ramp checked, there is no reason to suspect wrong-doing. Correct?
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Depends who's sitting in which seat and what's being written in the logbook. If the FAA finds the student in the left seat and the non-CFI pilot in the right seat, they are going to probe further.

Now imagine that commercial pilot happens to hold a CFI certificate but doesn't have it with him. How has this fact changed anything?
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Somewhat. If the student in the left seat says the CFI is giving instruction, and the Inspector believes the student, the CFI is getting written up for violating 61.3(d). If the two people say that it's just a joy ride, and the CFI is acting only as a PIC and not giving training, and there's no entry for the flight in the student's logbook, it's no big deal.

Does having a CFI certificate somehow remove your ability to fly with anyone else without requiring the use of that CFI certificate? It seems to me like a paradox.
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No, it doesn't. It's all about intent and what's written down about the flight.
 
dsffdssdf said:
It is absolutely, 100% impossible to prove that an instructor violated this regulation because the only proof that exists (the logbook entry) is created after the fact.
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That's just not true. The FAA can ask the other person what's happening, and if the other person says it's a training flight, and the Inspector believes that other person, the instructor without his/her CFI ticket handy is in trouble. The Inspector can also go into the flight school/FBO and see how the flight was scheduled/signed out at the front desk -- if it was scheduled and dispatched as a training flight, that is further evidence which may be used in an enforcement proceeding. Remember, the standard of proof in FAA enforcement cases is not "proved beyond reasonable doubt," it's just "more likely than not."

Bottom line here is that the FAA doesn't need the case lockwired and sealed -- just be able to show by a preponderance of the evidence that the regulation was violated. The CFI's self-serving statement that it was not a training flight is insufficient by itself to carry the day in court.

This concludes my Aviation Law lecture for today. Expect a pop quiz at any time.
 
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Rotor&Wing said:
Also, the FAA is the only agency that can prosecute you on hearsay evidence.
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Any Federal agency (not just the FAA) operating under the Administrative Procedures Act can use hearsay evidence against you in a regulatory enforcement proceeding. That includes the IRS, OSHA, FCC, you name it.
 
Ron Levy said:
Any Federal agency (not just the FAA) operating under the Administrative Procedures Act can use hearsay evidence against you in a regulatory enforcement proceeding. That includes the IRS, OSHA, FCC, you name it.
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You're correct, I miss worded my reply.
 
I fail to see what the issue is here about carrying a license with you when flight instructing. Is it really that difficult?
 
Rotor&Wing said:
I fail to see what the issue is here about carrying a license with you when flight instructing. Is it really that difficult?
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Thats not the point. The fact that 61.3(d) is "hard to enforce" is beside the point. There are tons of regulations that are hard to enforce. The point is that in 61.3(d) the FAA evokes an idea that seems to go against the concept of the instructor's license.

Everyone here so far seems to be under the impression that if there is intention to log the flight as "official 8710-ready dual", then the instruction is done in accordance with the CFI certificate. In that case, during the flight, you are indeed exercising a privilege of your CFI certificate and therefore must have your CFI certificate on you for that flight. But I'm not so sure...

I've always considered the CFI certificate to be a purely paperwork certificate. It's not like a pilot certificate that gives you the ability to operate an airplane. All it does is gives you the ability to sign logbooks and 8710 forms and have that signature carry weight with the FAA. The way I see it, the only time a CFI privileges is envoked in an airplane is when you sign a logbook while airborne, which is obviously not what the FAA intended that regulation to mean.

It's like I said earlier about the FAA writing a regulation that limits your ability to exercise your commercial certificate on a boat or on a bicycle. Or a judge who is limited by law from exercising his privilege to signing a warrant unless he is in his office. Its just very odd.

Lets say I'm at the airport and an old student comes up to me and offers me a ride in his new twin engine airplane. Since I don't have my MEI, what can I do to ensure the FAA isn't going to accuse me of trying to illegally exercise my instructor privileges? From many angles, it could look like I'm going just that. He is an old studnet of mine, the flight takes place at an airport where I instruct at... I've always been under the impression that as long as you don't sign anything, no one is going to accuse you of illegally envoking a CFI privileges. But everyone in this thread seems to think otherwise...

So what can I do to protect myself? It seems very likley for some clueless bystander to just blert out, when questioned by the FAA "oh yeah those two used to do instruction together, they were probably doing a training flight", which will end up in me getting in big trouble.
 
Pardner, you're off in outer space on this one.

If your concern is that you'll be accused of instructing just because you're sitting in the right seat with another pilot in the left seat, there's no case law to support that idea. Of course, if the other pilot tells the FAA s/he engaged you as an instructor, that's another story, but the mere fact of your holding a CFI ticket isn't enough. OTOH, if you think you can be in the right seat in an instructional situation and then tell the FAA that because you never signed anyone's logbook they can't prove you were giving training, you'll just add another charge (61.189(a)) to the enforcement action.
 
Ron Levy said:
You are wrong. Only an "authorized instructor" may give instruction (the actual word the FAA uses is "training") -- and that's either on the ground or in flight. See 14 CFR 61.1 for details. So, if it's not a CFI in the plane, there's no training going on, and when training is going on, the CFI is exercising the privileges of the CFI certificate.
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I understand what you're saying, but if that's the FAA's stance, it rather defies logic. By that definition, most of the people who post here should have CFI (or CGI) certificates on them when they post. And, if the actual knowledge transfer takes place when someone reads the post, then I suppose they'd need to know when their posts are being read so they can put 'em in their pockets then, too!

[Edit: yes, I know that this is hyperbole, but given the amount of "instruction" that truly goes on here and in other forums... The saving grace is, I suppose that no one has an intent to log the time.]
 
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KennyFlys said:
There was a case cited by either Mark or Ron where two friends flying together and they became involved in an incident. I cannot recall the particulars but let's see how much I do recall. Either way, this is a realistic scenario.

The FAA and NTSB held Pilot One responsible over Pilot Two even though it was Pilot Two who was actually the sole manipulator of the controls at the time of the incident. Why? Because Pilot One held a CFI ticket.
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I'm pretty sure that I've never cited a case in which a CFI was held responsible for a accident just because he happened to be a CFI.
 
Ron Levy said:
Pardner, you're off in outer space on this one.

If your concern is that you'll be accused of instructing just because you're sitting in the right seat with another pilot in the left seat, there's no case law to support that idea. Of course, if the other pilot tells the FAA s/he engaged you as an instructor, that's another story, but the mere fact of your holding a CFI ticket isn't enough. OTOH, if you think you can be in the right seat in an instructional situation and then tell the FAA that because you never signed anyone's logbook they can't prove you were giving training, you'll just add another charge (61.189(a)) to the enforcement action.
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Lets say there is a pilot named Barry. He is a multi-engine rated commercial pilot who just recently bought his own G1000 Baron. Another pilot named Mike is a non-CFI commercial multi-engine rated pilot who has no time in a Baron, but lots of time flying G1000 King Airs. Barry asks Mike to go flying with him to teach him how to use his new G1000. Mike agrees. Since Mike doesn't have a MEI, is he doing something illegal? If Mike tries to log the time as dual given, and sings Barry's logbook, then yes it most definitely is illegal. But is no dual given/received logging is done?

This is what I call "lowercase i" instruction, as opposed to "capitol I" Instruction. That is to say flight instruction that is "off the record" as opposed to "on the record". This kind of thing happens a lot in aviation. Private pilots teach their wives how to land the family plane all the time. Are you allowed to give "off the record" instruction if you hold a CFI? How? I always thought if you don't try to log it, then it's off the record and you'll be OK. Because where else can the line be drawn? What if a Airline captain asks his non-type rated MEI first officer for help figuring out how to read a Jepp chart or something. Is the FO expected to decline giving the captain any kind of instruction, in fear of him violating the regulation of giving instruction in a multi-engine plane without 5 hours of PIC (or without a type rating)?
 
Ron Levy said:
Don't think it was me, either.
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Can you recall such a case in your vast knowledge of certificate actions?

I may have read it in one of the periodicals as well. I'll give AOPA and NAFI a call later to look for something.
 
If it's important, then the CFI should have the occupants sign notes of intent before embarking and carry one copy and put one copy in the car on the ground.

dsffdssdf said:
This is something that has been on my mind for a while. The gist of 61.3(d) is that if a flight instructor is exercising the privileges of his CFI certificate while in the airplane, he must have that certificate on board with him. This is what I don't understand, when do you ever exercise your CFI privileges in an airplane? As far as I understand things, the act of giving instruction is not a privilege in an of itself. You can give instruction as a commercial pilot without a CFI, it just won't count towards a certificate or rating. The only privilege a CFI certificate gives you is the ability to sign your name in the student's logbook and 8710 form, which you always do on the ground, outside the plane.

Lets say you're a CFI and you're about to embark on a flight with a friend of yours who is a Private pilot who happens to be working on his instrument rating. The way I guess the regulation is intended to mean is that if you're planning on giving this student instruction, and having it count towards his instrument rating, you must have that certificate on board with you. But if you're just flying for fun, then you don't need your CFI certificate onboard with you because you won't be using that certificate.

Here lies the problem: If you were ramp checked, how is the FAA supposed to determine which situation is about to occur; friendly CFI/pilot flight where no instruction is given, or pilot instruction? The act of making the instruction "official" (and therefore requireing the CFI certificate) occurs after the flight when the CFI signs the student's logbook. It seems like the FAA has no way of enforcing this regulation. What are some of your thoughts on this?
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Dave Krall CFII said:
If it's important, then the CFI should have the occupants sign notes of intent before embarking and carry one copy and put one copy in the car on the ground.
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What about in the case of a captain and an FO? Is it really necessary for the FO to have the captain sign a waiver before each flight?
 
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