AN ACR MLG PLT QUESTIONS THE LEGALITY OF HIS ACR'S ACTION IN A RECENT STRIKE REGARDING CARRYING COMPANY PERSONNEL WITHOUT FLT ATTENDANTS ABOARD.

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6 ACR A EMPLOYEES UNQUALIFIED ON MY TYPE ACFT (MLG); WERE SCHEDULED BY MY COMPANY; ACR A TO DEADHEAD ON MY ACFT WHICH WAS PLACED INTO A CARGO DISPATCH CONDITION. A COMPANY INTERP OF FAR 121.583 IS AS FOLLOWS: 'IF MINIMUM FAR FLT ATTENDANTS REQUIREMENT CANNOT BE MET; FAR 121.583 PERMITS THE CARRIAGE OF ACR A AND ACR CORP AND ACR B CREW MEMBERS; ACR A COMPANY EMPLOYEES; FAA AND NTSB PERSONNEL IN THE CABIN. THERE IS NO LIMIT TO THE NUMBER OF SUCH PERSONS THAT MAY BE CARRIED....' ACR A IS USING THIS INTERP OF THE FAR TO MOVE THEIR MINIMALLY QUALIFIED PEOPLE (8 DAYS TRAINING) ON NON PAX FLTS. I QUESTION THE INTENT OF THE FAR. SINCE IN THIS CASE IT PLACES THE CAPT AND FO IN THE POS OF BEING THE ONLY FULLY QUALIFIED PEOPLE ON BOARD. IT IS POSSIBLE FROM THIS INTERP THAT A FULLY LOADED (142 PEOPLE) MLG COULD BE DISPATCHED WITHOUT ANY QUALIFIED PEOPLE BEHIND THE COCKPIT DOOR. IN THE EVENT OF AN EMER EVAC; CHAOS WOULD RESULT. NO EVAC COMMANDS WOULD BE GIVEN; AND FAR EVAC TIMING WOULD NOT BE MET. SINCE ON MY FLT 6 PERSONS ONLY WERE INVOLVED; SAFETY WAS NOT TOO BADLY COMPROMISED. I HAVE SUBMITTED THIS RPT BECAUSE I FEEL THE FAA MAY NOT INTERPRET FAR 121.583 AS ACR A DOES AND DECIDES TO TAKE PUNITIVE ACTION AGAINST CREW MEMBERS INVOLVED.