FLC MEMBER OF A CESSNA CITATION 5; ACTED AS SIC WHEN HE DID NOT MEET THE TRAINING AND PRACTICE REQUIREMENTS.

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I HOLD A PVT PLT CERTIFICATE WITH INST AND MULTI-ENG RATINGS. OUR COMPANY OPERATES 2 CITATION V ULTRAS FOR INTERNAL BUSINESS PURPOSES UNDER PART 91. I DID THE GND SCHOOL AND 3 TKOFS AND LNDGS NECESSARY TO LOG TIME AS SIC IN THE CITATIONS. AS A RESULT; I HAVE BEEN LOGGING SIC TIME FOR ALMOST 2 YRS ON MOST TRIPS WHERE I'M TRAVELING ON BUSINESS. ABOUT 3 WKS AGO; OUR CHIEF PLT WAS TOLD BY OUR INSURANCE CARRIER THAT; WHILE IT WAS NOT A PROB FOR THEM; THERE HAD BEEN PAST CASES WHERE THE FAA HAD UNDERTAKEN ENFORCEMENT ACTIONS AGAINST PVT PLTS FLYING AS CREW MAN ON COMPANY PLANES; EVEN THOUGH PLTING WAS NOT PART OF THEIR JOB DUTIES (IE; THEIR FLYING OF THE COMPANY PLANE WAS INCIDENTAL TO THEIR JOBS). AT THAT TIME; I ASKED OUR COMPANY'S GENERAL COUNSEL TO REFER THIS ISSUE TO AN AVIATION ATTORNEY FOR AN OPINION. ON JUL/XA/99; I RECEIVED A FAX OPINION FROM THIS LAWYER STATING THE FAA HAD INDEED TAKEN A VERY BROAD INTERP ON THE ISSUE OF PVT PLT EXECUTIVES FLYING AS CREW ON COMPANY AIRPLANES AND THERE WAS A REAL POSSIBILITY OF A SUCCESSFUL ENFORCEMENT ACTION AGAINST ME SHOULD THIS COME TO THEIR ATTN. BASED UPON THIS LEGAL OPINION; I HAVE NOTIFIED IN WRITING OUR CHIEF PLT THAT I WILL NO LONGER SERVE AS SIC ON ANY COMPANY ACFT UNLESS AND UNTIL I QUALIFY FOR A COMMERCIAL RATING. WHILE I THINK IT WOULD BE AN INCREDIBLE OVERREACH FOR THE FAA TO ALLEGE ANY OF MY COMPENSATION AS AN EMPLOYEE OF THE COMPANY IS RELATED TO FLYING DUTIES; I AM UNWILLING TO ASSUME THAT RISK. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR STATED THAT THERE HAD BEEN NO OFFICIAL CONTACT WITH THE FAA REGARDING HIS QUALIFICATIONS; ONLY THAT WHICH HIS COMPANY LAWYERS HAD INDICATED. HOWEVER; HE WAS NOT AWARE OF ALL THE STIPULATED TRAINING REQUIREMENTS SPECIFIED IN SECTION 61.55(B) OF THE FARS. THEREFORE; HE ACKNOWLEDGED THAT HE HAD NOT COMPLETED THOSE ITEMS WITHIN THE LAST 12 MONTHS.