A B767-200ER LEAVES ITS HARD SID ALT; 3000 FT; FOR THE NEXT WAYPOINT'S HARD ALT; 4000 FT; 10 MI TOO SOON; E OF THAT FIX. EGKK; FO.

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ACFT (B767-200ER) DEPARTING LGW (LONDON GATWICK) ON THE SOUTHAMPTON 2P (SAM 2P) SID; RWY 8R AT AB39Z OCT/XA/99. 4000 FT SELECTED IN MCP WINDOW DURING PREFLT AT THE GATE AND FMC LEGS. PAGE PROPERLY DEPICTING XING ALT RESTRS FOR ALL SID WAYPOINTS. LNAV WAS SELECTED AT 400 FT AGL AND VNAV AT 1000 FT AGL. FLAPS 1 DEG AND FLAPS UP SELECTED AT 3000 FT AT APPROX THE END OF THE UPWIND LEG (THE BEGINNING OF THE L TURN). IN THE TURN AT 3000 FT; THE PF (CAPT) SELECTED FLT LEVEL CHANGE IN ORDER TO KEEP THE SPD AT MINIMUM CLEAN AIRSPD AND TO STAY IN THE PUBLISHED BOUNDARY OF THE TURN; AND AS PART OF THE LOW ALT LEVELOFF PROC. ABOVE 3500 FT THE PNF (FO) QUESTIONED ALT NOTING THAT 3000 FT MSL AT WAYPOINT 'D43 DET' WAS A 'HARD' ALT; NOT 'AT OR ABOVE' AS IT WOULD BE ON THE WBOUND SID. AT THE SAME TIME THE DEP CTLR CALLED AND RECLRED US TO 4000 FT; THEN QUESTIONED THE ALT WE WERE TRANSITIONING. THE PNF (FO) CONFIRMED THE 4000 FT CLRNC (NOTING MCP ALT SET TO 4000 FT) AND ASKED THE CTLR TO REPEAT THE QUESTION. THE QUESTION WAS UNDERSTOOD WHEN REPEATED AND FO RESPONDED THAT THE ACFT WAS PASSING THROUGH 3700 FT; IN REALITY MORE THAN 10 MI PRIOR TO REACHING THE DET 43 MI FIX. NO FURTHER COMMENTARY REGARDING THIS WAS RECEIVED FROM THE DEP CTLR EXCEPT A FREQ CHANGE A FEW MOMENTS LATER. NO TA/RA OBSERVED FROM TCASII AND NO PREVENTIVE ACTION WAS ISSUED TO US OR OTHER ACFT AS FAR AS WE KNOW. SUPPLEMENTAL INFO FROM ACN 451839: I WAS THE THIRD PLT SITTING JUMP SEAT (INTL RELIEF OFFICER). I DID NOT NOTICE THAT CAPT HAD SWITCHED FROM VNAV TO FLT LEVEL CHANGE UNTIL FO MENTIONED ALTDEV NOTED ABOVE.