Grace Provisions

If a crewmember who is required to take a test or a flight check under this part, completes the test or flight check in the calendar month before or after the calendar month in which it is required, that crewmember is considered to have completed the test or check in the calendar month in which it is required.

What about the training requirements in 135 Subpart H? 135.343 specifies that a crewmember must have completed the appropriate initial or recurrent phase of the training program within the preceding 12 calendar months. Does 135.301 provide grace provisions for these 12 month training requirements? As it turns out, the concerns about applying 135.301 to training requirements were unnecessary. The grace period for training is provided in 135.323(b):

Whenever a crewmember who is required to take recurrent training under this subpart completes the training in the calendar month before or the calendar month after the month in which that training is required, the crewmember is considered to have completed it in the calendar month in which it was required.

Talking about due months and grace provisions may be as exciting as watching the grass grow, but, as pilots, we share responsibility with our air carrier certificate holder to ensure we are qualified and current before accepting an assignment for a Part 135 trip.

The bottom line is that grace provisions apply to both training and checking. The FAA legal interpretations we consulted also confirm these findings.