Legal Interpretations
Barton-Southern Air 2014
Summary
The Question
Must an international relief officer who relieves only the second in command during cruise make a left-seat takeoff and landing during operating experience or complete pilot-in-command proficiency training?
Background
Southern Air Inc. asked two questions about the qualifications of International Relief Officers, pilots who relieve an assigned pilot in command or second in command en route during the cruise portion of a flight.
The FAA’s Interpretation
No to both questions, assuming the pilots serve exclusively en route during the cruise portion of the flight and relieve only the assigned second in command. The questions involved 14 CFR 121.432(a) and 121.543(b)(3)(ii), and the FAA's reasoning is set out in an enclosed memorandum to AFS-1.
- Requester
- Barton
- Organization
- Southern Air
- Issued
- April 29, 2014
- Subject
- Air Carrier & Commercial Operations
Regulations Cited
Page 1
U.S. Deportment
of Transportation
Federal Aviation
Administration
APR zg· 2014
Mr. Keith R. Barton
Director of Training
Southern Air Inc.
Office of the Chief Counsel
7310 Turfway Rd., Ste. 400
Florence, KY 41042
Mr. Donald Osmundson
Director of Operations
Southern Air Inc.
7310 Turfway Rd., Ste. 400
Florence, KY 41042
Dear Mr. Barton and Mr. Osmundson:
800 Independence Ave., S.W.
Washington, D.C. 20591
This letter is provided in response to a Southern Air Inc. request for a legal interpretation sent to this office on April 12, 2010. The request for a legal interpretation included two questions regarding the qualification of "International Relief Officers" or "IROs." For purposes of this legal interpretation, we will consider IROs to be those pilots who relieve an assigned pilot in command or second in command, en route during the cruise portion of a flight.
We understand the two questions to be as follows:
(1) Is a takeoff and landing from the left seat during operating experience, required for a pilot who relieves the assigned SIC en route during the cruise portion of the flight?
(2) Is PIC proficiency training and evaluation required for pilots who relieve the assigned SIC by serving as SIC en route during the cruise portion of the flight? These questions involve the application of 14 C.F.R. §§ 121.432(a) and 121.543(b)(3)(ii) to pilots who serve in your operations. Assuming that the pilots identified in both of your questions serve exclusively en route, during the cruise portion of the flight, and provide relief to the assigned SIC only, the answer to both of your questions is no. The enclosed memorandum to AFS-1 dated April 29, 2014, provides the basis for this response.
Page 2
We appreciate your patience and trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3073. This response was prepared by Sara Mikolop, an attorney in the in the International Law, Legislation, and Regulations Division of the Office of the Chief Counsel, and coordinated with the Air Transportation Division of the Flight Standards Service.
Enclosure
Regulations Referenced
Snapshot retrieved August 6, 2026.