CAPT OF ACR WDB ACFT QUESTIONED THE SAFETY OF AN FAA INSPECTOR OCCUPY THE FORWARD COCKPIT OBSERVERS SEAT IN LIEU OF ASSIGNED RELIEF PLTS.

Narrative

WDB ACFT SFO-HKG. WE HAD A GENTLEMAN PRESENT HIMSELF AS AN FAA ASI. HE SHOWED THE PROPER IDENT AND PRIOR TO ENG START TOOK THE FIRST OBSERVER SEAT; THE ONE JUST BEHIND THE CAPT. SINCE WE HAD 2 ADDITIONAL CREW MEMBERS IN THE COCKPIT; I ASKED HIM IF HE WOULD TAKE THE REAR MOST SEAT IN THE COCKPIT SO I COULD HAVE MY REGULAR CREW MEMBERS IN THEIR NORMAL POS. HE SAID HE WAS AUTHORIZED TO USE THE SEAT IN WHICH HE WAS SITTING; AND PULLED OUT A SHEET OF TYPEWRITTEN PAPER WHICH HE SAID WAS THE DIRECT QUOTE OF THE FARS AUTHORIZING HIS USE OF THE SEAT. HE SAID THE WDB WAS A 2-MAN ACFT AND REPEATED WHAT HE HAD SAID PREVIOUSLY ABOUT HIS AUTHORITY TO USE THIS SEAT. I THEN SAID IF HE WISHED TO EXERCISE THIS AUTHORITY THE SEAT WAS HIS. I ASKED HIM IF HE WAS ACFT MODEL PLT QUALIFIED AND HE SAID NO. I SAID ALSO THAT I DID NOT THINK THIS WAS THE 'SAFEST' SEATING ARRANGEMENT SINCE HE WAS NOT ACFT PLT QUALIFIED. HE OCCUPIED THE SEAT FOR LNDG AT HKG. THE QUESTION HERE IS NOT SAFE VERSUS UNSAFE; BUT SAFE VERSUS 'SAFEST.' CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR STATED THAT HIS REAL CONCERN WAS THE FACT THAT SOME INSPECTORS DID NOT HAVE OPERATIONAL PLT EXPERIENCE OR QUALIFICATIONS AND WOULD THEREFORE; NOT BE AS HELPFUL TO OBSERVING THE FLT AS A KNOWABLE PLT. SINCE THE RPTR WAS DESIROUS OF PRESENTING HIS VIEWS TO HIGHER AUTHORITY; HE WAS GIVEN INFO ON HOW TO PETITION THE FAA ADMINISTRATOR BY THE PROC REFED IN FAR PART 11.27. RPTR EXPRESSED APPRECIATION FOR CALLBACK AND RECOMMENDATIONS FOR MAKING A PROPOSED RULE CHANGE.