FLYING AS FO WITHOUT MULTI ENGINE RATING ON CERTIFICATE.

Narrative

I HAVE BEEN EMPLOYED AS A PLT SINCE MARCH 1983. UPON COMPLETION OF MY TRNING; I HAD A COMMERCIAL PLT CERTIFICATE WITH RATINGS AIRPLANE SINGLE ENG LAND AND INSTRUMENT AIRPLANE. IN ADDITION; I HAD A F/E (TURBOJET) CERTIFICATE. MY INITIAL POS WAS FLT ENGINEER ON THE LGT. IN 1/85; I RECEIVED UPGRADE TRNING FOR THE POS OF F/O; AND BEGAN FLYING IN THAT POS IN 1/85. I DID NOT RECEIVE ANY ADDITIONAL RATING AS A RESULT OF MY UPGRADE TRNING; NOR HAVE I RECEIVED ANY ADDITIONAL RATING SINCE THEN. I WAS NOT AWARE THAT A MULTI ENG RATING WAS REQUIRED FOR THE POS I WAS FLYING. IN FACT; I WAS ADVISED BY AT LEAST 1 OF THE COMPANY'S INSTRS (IN RESPONSE TO MY INQUIRY) THAT A F/O IS NOT REQUIRED TO HAVE A MULTI-ENG RATING. TODAY (9/88); I RECEIVED A TELEPHONE CALL FROM OUR ASSISTANT CHIEF PLT; WHO HAD JUST RECEIVED A CALL FROM AN FAA INSPECTOR; AND HE ADVISED ME THAT I WAS BEING REMOVED FROM FLT STATUS EFFECTIVE IMMEDIATELY; BECAUSE I DID NOT HAVE A MULTI ENG RATING AS REQUIRED BY FARS. NEEDLESS TO SAY; I WAS TAKEN BY SURPRISE. OVER THE LAST 3 YRS AND 9 MOS; I HAVE FLOWN 2;604 HRS AS F/O. DURING THAT PERIOD; I HAVE HAD MY CREDENTIALS CHKED NUMEROUS TIMES BY AIR CARRIER INSPECTORS. ON MOST SUCH OCCASIONS; THE ACI MADE VERBAL NOTE OF THE FACT THAT I HAD A SINGLE ENG RATING; AND DISMISSED THE SUBJECT WITH A STATEMENT TO THE EFFECT OF; 'I DON'T SEE THAT VERY OFTEN.' ADDITIONALLY; DURING THE TIME THAT I HAVE FLOWN AS F/O; THE COMPANY'S TRNING RECORDS HAVE BEEN EXHAUSTIVELY REVIEWED BY THE FAA AT LEAST TWICE (MOST RECENTLY IN 5/88); AND MY CREDENTIALS WERE CHKED BY AN FAA INSPECTOR IN CONNECTION WITH A CHK RIDE FOR CAPT UPGRADE (WHICH I DID NOT COMPLETE) IN 6/88; ALL WITH NO MENTION MADE OF MY DEFICIENCY IN RATING. ALL OF THE ABOVE MADE ME FEEL CONFIDENT THAT I HAD THE REQUIRED RATING FOR THE POS IN WHICH I WAS FLYING. BEFORE I RETURN TO THE LINE; I WILL HAVE A MULTI-ENG RATING. I MUST SAY; HOWEVER; THAT I FAIL TO SEE HOW A MULTI ENG RATING EARNED IN AN SMA WILL MAKE ME MORE QUALIFIED THAN I PRESENTLY AM TO FLY AS F/O ON AN LGT; OTHER THAN TO MEET THE LETTER OF THE REG. IN CLOSING; I WOULD LIKE TO POINT OUT A SOMEWHAT CONFUSING PARAGRAPH IN THE FARS THAT MAY HAVE CONTRIBUTED TO THE DELAY IN DETECTING MY SITUATION. WHEN I WAS ADVISED OF MY PROB TODAY; I IMMEDIATELY STARTED THUMBING THROUGH THE FARS AND READ PAR 121.437 (A) AND (B); WHICH LEFT ME WITH THE IMPRESSION; SINCE (A) IS NOT APPLICABLE TO ME; THAT A MULTI-ENG RATING WAS NOT REQUIRED FOR MY POS. THEN MY ATTN WAS CALLED TO PARAGRAPH (C) OF THE SAME SECTION; WHICH CONTRADICTS AND EVIDENTLY SUPERSEDES (B); AND REQUIRES A MULTI ENG RATING FOR MY POS. I SUBMIT THAT PARAGRAPH 121.437 (B) SHOULD BE DELETED; AS IT HAS NOT BEEN APPLICABLE SINCE 7/80; AND THUS CAUSES CONFUSION. IN ADDITION; THE LAST SENTENCE OF PARAGRAPH 121.437 (C) (STARTING WITH 'NOTWITHSTANDING THE REQUIREMENTS OF...') SHOULD BE DELETED FOR THE SAME REASONS.