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3.1.4 Preflight Risk Analysis. Risk Analysis procedures, principles, and policies are documented and are the subject of training by HAA operators. Multiple people with defined and documented roles and who receive specific training are typically involved in an FAA-approved HAA flight operations risk analysis program.
3.1.5 R isk Analysis. Risk analysis is an iterative risk assessment, mitigation, and reassessment process. Risk assessment is one key element of the broader risk analysis process. The risk assessment process should identify hazards, the probability of their occurrence, and the likely severity of the outcome should a hazard occur.
3.1.6 R isk Mitigation . Risk mitigation and its effectiveness in reducing risk is an essential component of the risk analysis program. If the risk assessment rates an individual risk element highly, mitigations may be advisable. Risk mitigations should be preplanned and preapproved, not assembled at the time of need, as unintended consequences may result.
Following application of an effective mitigation, the associated individual and total residual risk factor should be reassessed. This risk mitigation/re-assessment cycle should be repeated until all higher risks are effectively mitigated. Risks that remain high must either be acknowledged and accepted in accordance with the operator’s risk analysis program, or the proposed original flight operation or proposed flight operation modification should be declined.
3.1.7 R isk Threshold. Each individual risk element is weighed against an operator’s individual risk threshold and aggregated (combined risk scores remaining after application of approved mitigation strategies) into a total risk which, in turn, is weighed against the operator’s predetermined aggregate risk threshold. If the final aggregate residual risk and/or individual risk elements exceed the operator’s predetermined thresholds, approval of a higher level of operator management (above the OCS) is required. If this approval cannot be obtained, the flight should be refused (refer to §§ 135.615 and 135.617(a)(5)).
Section 135.617 requires HAA operators to have an FAA-approved and documented risk analysis program that includes procedures for elevating the final post mitigation residual risk to a higher management level for approval when the total risk exceeds a predetermined threshold.
3.1.8 P articipation Requirements . By regulation, the OCS must participate in the preflight risk analysis required by § 135.617. This section contains a brief description of the minimum participation requirements. HAA operators are encouraged to include in their risk analysis program any other requirements they deem appropriate to enhance safety.
3.1.8.1 The OCS must ensure the pilot has completed all required items on the preflight risk analysis worksheet. Procedures for determining the minimum items to be completed on the risk analysis should be detailed in the certificate holder’s approved risk analysis program. Risk analysis is discussed in detail in the current version of AC 135-14, Helicopter Air Ambulance Operations.
3.1.8.2 The OCS must confirm and verify all entries on the preflight risk analysis worksheet. The process of confirming and verifying the risk analysis entries
3-3 should be documented in each certificate holder’s Manual or approved risk analysis program.
3.1.8.3 The OCS must assist the pilot in mitigating any identified risks prior to takeoff and during flight if conditions change unexpectedly.
3.1.8.4 Risk mitigation strategies offered by the OCS should be offered in the form of suggested options that are previously validated by the operator. Risk mitigation strategies made on an ad hoc basis may result in unintended consequences. It’s important to note that the pilot in command (PIC) makes the final decision whether or not a recommended risk mitigation strategy is acceptable for the circumstances at hand. Conversely, the OCS is expected to evaluate mitigation strategies proposed by the PIC and determine their adequacy. The OCS should have the authority to direct the PIC to decline or abort a flight if the proposed risk mitigation is inadequate or inappropriate for the circumstances or if the residual risk remains excessive.
3.1.8.5 Certificate holders are encouraged to document when mitigation strategies are employed and their effect on the safe conduct of a flight.
3.1.8.6 The OCS must acknowledge, in writing, specifying the date and time that the preflight risk analysis worksheet has been accurately completed and that, according to their professional judgment, the flight can be conducted safely.
3.1.8.7 The method of this acknowledgement may be in any manner specified by the certificate holder in their approved risk analysis program. A signature is not required. This acknowledgement may be on the same risk analysis worksheet the PIC completes or on a separate record as long as the record contains the date and time of the acknowledgment, enough information to identify the PIC, the date of flight, the route of flight, that the preflight analysis worksheet has been accurately completed and that, according to the professional judgment of the OCS, the flight may be conducted safely, and any other information deemed appropriate by the certificate holder. The method of acknowledgement may be in writing, electronic, etc., as specified in the approved risk analysis program.
Note: Electronic signature safeguards and data security techniques are evolving rapidly. Discuss this section with your Principal Operations Inspector (POI) at the time of implementation planning (refer to the current edition of AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals, for more details regarding electronic signatures).
3.1.8.8 When an OCS, in their professional opinion, cannot concur that a flight can be conducted safely, the OCS should direct the PIC not to accept the flight. If the OCS observes a change in the risk analysis factors during the course of an HAA operation, the OCS should advise the PIC, recommend possible
3-4 mitigation strategies, and if the risk becomes unacceptable, direct the PIC to divert or abort the flight. This OCS authority should be documented in the certificate holder’s risk analysis program and GOM.
3.1.9 Emergency Assistance Capabilities. In addition to those duties required by regulation, the OCS can play an important role in providing emergency assistance to PICs during emergency situations such as an encounter with inadvertent instrument meteorological conditions (IIMC). In many circumstances, the OCS may be able to observe aircraft position and maintain communications with the PIC when the aircraft is below air traffic control (ATC) radar and communications coverage. Under these circumstances, the OCC may need to relay information to ATC regarding an aircraft declaring an emergency and the pilot’s intentions. Additionally, the only means by which the PIC may be able to receive accurate weather information or route recommendations to escape severe or deteriorating weather may be through the OCS.
3.2 OCS Shift Change/Relief Procedures. In accordance with § 135.619(c), certificate holders must develop a shift change checklist to be used by OCS personnel during OCS shift changes. Procedures for briefing the on-coming OCS of HAA operations currently in progress and those expecting to begin shortly should be developed, documented, and trained. A similar checklist should be available when relief is being provided to an onduty OCS for breaks, etc. These checklists should, at a minimum, contain:
1. Active HAA operations.
2. Any HAA operations being conducted with a risk level higher than “low” or that required management review that employed risk mitigation strategies.
3. Weather affecting possible flight areas including but not limited to a review of current surface analysis, radar/radar summary, surface prognostic charts, and other information deemed appropriate.
4. Available flight monitoring procedures.
5. Temporary flight restrictions (TFR).
6. Pertinent Notices to Air Missions (NOTAM).
7. Any technology anomalies.
8. Any new flight operations policies, manual changes, etc., that have taken effect since the on-coming OCS’ last shift.
9. Human factors affecting any HAA pilot, OCS, CS, or other company personnel that could affect operations.
10. Helicopter maintenance status.
3.3 CS/OCS Interfaces. Some HAA operators consider it a best practice for OCS to pass routine, non-critical information to the PIC through the communications center in order to ensure all parties (OCC, pilot, and communications center personnel) are aware of information being provided and of any possible route deviations, etc., that might occur as a result of OCS suggestions or direction.
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3.3.1 Direct Communications. In all cases where the OCS is performing a task listed in § 135.619(a) and needs information from or wishes to pass information to the pilot, the OCS normally will communicate directly with the PIC. This direct communications link is crucial when the matter is time-critical or requires technical discourse to achieve a consensus position regarding risk analysis or weather options. It is recommended that the OCS advise the communications center as soon as it is feasible of the nature of the communication and any impacts it might have on the HAA operation.
3.3.2 No n -Normal Event. The OCC should be notified by the CS any time the CS becomes aware of an out of the ordinary event during an HAA operation. Such events include diversions, precautionary landings, or any other event deemed appropriate by the certificate holder. These notification processes should be documented in the certificate holder’s Manual or SOP.
3.4 Accident/Incident Procedures. Procedures should be documented for the OCS to follow in the event of an overdue aircraft or if an aircraft is known to have been involved in an accident or incident. This should include procedures for notification of appropriate company personnel and for notification of emergency medical service (EMS), fire, and police, if necessary, in the area where the aircraft is believed to be located. It is recommended that a listing of all EMS, fire, police dispatch centers, and their phone numbers for the areas where HAA operations are normally conducted be maintained at the OCS work station. The OCS may delegate some Post-Accident/Incident Plan (PAIP) local contact tasks to the CS. This option should be noted as such in the PAIP documentation.
4-1 CHAPTER 4. OPERATIONS CONTROL SPECIALIST (OCS) TRAINING
4.1 Helicopter Air Ambulance (HAA) OCS Training. Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.619(d) establishes the requirement and § 135.619(f) establishes the minimum training required for HAA certificate holders operating 10 or more HAAs. Certificate holders operating fewer than 10 HAAs are encouraged to use the same training.
4.1.1 O CS Experience. Preferably, although not required, HAA OCS should be trained helicopter pilots and ideally be highly experienced HAA pilots.
4.1.2 Initial Training. B efore performing the duties of an OCS, each person must satisfactorily complete the certificate holder’s Federal Aviation Administration (FAA)-approved OCS initial training program. Initial training must include a minimum of 80 hours of training on the topics required by § 135.619(f).
4.1.3 Recurrent Training. E very 12 months after satisfactory completion of initial training, each OCS must complete a minimum of 40 hours of recurrent training.
4.2 O CS Prior Experience. A certificate holder may reduce the regulatory requirement of 80 hours of initial training provided the individual has certain prior experience. The training may be reduced as appropriate, but by no more than 40 hours. While the number of training hours may be reduced, all topics listed in § 135.619(f) must still be covered in training. It is recommended that the certificate holder perform a pretraining evaluation to determine which training topic hours may be reduced for persons who have obtained, prior to beginning initial training, a total of at least 2 years of experience during the last 5 years in any one or combination of the following areas:
• Military aircraft operations as a pilot, flight navigator, or meteorologist;
• Air carrier operations as a pilot, Flight Engineer (FE), certified aircraft dispatcher, or meteorologist; or
• Aircraft operations as an air traffic controller or flight service specialist.
Note: Prior experience as a communications specialist (CS) is not a qualifying source of prior experience.
4.3 Training Requirements. OCS regulatory training requirements are specified in § 135.619(f). Other requirements, as determined by the Administrator to ensure safe operations, may be added depending upon individual HAA operator circumstances.
4.3.1 T raining Program Approval. The OCS training program, as required by § 135.619, must be approved by the certificate holder’s Principal Operations Inspector (POI). The required training topics are discussed in paragraph 4-4. Should the operator decide to use contract training resources, the training should be conducted through a 14 CFR part 142 training center or another certificate holder in accordance with § 135.324, and the operator as well as the POI must approve the training curriculum and testing.
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4.3.2 Training Elements. In addition to classroom or computer-based initial training, it is recommended that, after the OCS candidate has passed the knowledge test, initial training include scenario-based, one-on-one supervised, and coached on-the-job training (OJT) leading to the practical test. It must be understood that, in the case of OJT, the OCS acting as trainer must be aware of and is responsible for all actions taken by the OCS candidate under their direct and continuous supervision. Recurrent training should include periodic abnormal/emergency procedures drills. Recurrent training and testing must be accomplished before the end of the twelfth calendar month since the last test was accomplished.
4.3.3 T raining and Testing Personnel Experience. Those persons authorized by the certificate holder to conduct OCS training and testing should be experienced OCS personnel or other persons deemed appropriate and knowledgeable by the certificate holder. Initial OJT may be conducted only by specifically designated and current OCS personnel. This authorization should be shown by position or individual name in the approved OCS training program.
4.3.4 A llocation of Training Hours. While th e training hours specified in § 135.619 must be adhered to, the number of hours dedicated to each topic may be determined by the operator. The operator should develop the training curriculum and training hours based upon the full 80 hour requirements of § 135.619. The training program for OCS would be approved on the basis of the full 80 hours, with an approved means for reducing (but not eliminating) the hours dedicated to each topic based upon the OCS candidate’s prior experience. One method of determining training hours needed for various topics may be the completion of a knowledge assessment by the prospective OCS. This assessment would help determine the depth of knowledge the prospective OCS has with the various topics. The results of the knowledge assessment could be used to allocate training hours appropriately to ensure an adequate depth of knowledge across all subject areas.
4.4 Training Topics. Each certificate holder must have an FAA-approved OCS training program that covers at minimum the following topics:
4.4.1 Aviation Weather. To include:
1. General meteorology;
2. Prevailing weather;
3. Adverse and deteriorating weather;
4. Windshear;
5. Icing conditions;
6. Use of aviation weather products;
7. Available sources of information; and
8. Weather minimums.
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4.4.2 Navigation. To include:
1. Navigational Aids (NAVAID);
2. Instrument approach procedures (IAP);
3. Navigational publications; and
4. Navigation techniques.
4.4.3 Flight Monitoring. To include:
1. Available flight monitoring procedures; and
2. Alternate flight monitoring procedures.
4.4.4 Air Traffic Control (ATC). To include:
1. Airspace;
2. ATC procedures;
3. Aeronautical charts; and
4. Aeronautical data sources.
4.4.5 Aviation Communication. To include:
1. Available aircraft communications systems;
2. Normal communication procedures;
3. Abnormal communication procedures; and
4. Emergency communication procedures.
4.4.6 Aircraft Systems. To include:
1. Communications systems;
2. Navigation systems;
3. Surveillance systems;
4. Fueling systems;
5. Specialized systems;
6. General maintenance requirements; and
7. Minimum equipment lists (MEL).
4.4.7 Aircraft Limitations and Performance. To include:
1. Aircraft operational limitations;
2. Aircraft performance;
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3. Weight and Balance (W&B) procedures and limitations; and
4. Landing zone (LZ) and landing facility requirements.
4.4.8 Aviation Policy and Regulations. To include:
1. Title 14 CFR Parts 1, 27, 29, 61, 71, 91, and 135;
2. Title 49 of the Code of Federal Regulations (49 CFR) Part 830;
3. Company operations specifications (OpSpecs);
4. Company general operations policies;
5. Enhanced operational control policies;
6. Aeronautical decisionmaking and risk management;
7. Lost aircraft procedures; and
8. Emergency and search and rescue procedures, including plotting coordinates in degrees, minutes, seconds format, and degrees, decimal minutes format.
4.4.9 Crew Resource Management (CRM). To include:
1. Concepts and practical application;
2. Risk management and risk mitigation; and
3. Preflight risk analysis procedures required under § 135.617.
4.4.10 Local Flying Area (LFA) Orientation. To include:
1. Terrain features;
2. Obstructions;
3. Weather phenomena for local area;
4. Airspace and ATC facilities;
5. Heliports, airports, LZs, and fuel facilities;
6. Instrument approaches;
7. Predominant air traffic flow;
8. Landmarks and cultural features, including areas prone to flat-light, whiteout, and brownout conditions; and
9. Local aviation and safety resources and contact information.
4.5 Methods of Instructional Delivery. The method of instructional delivery is at the discretion of the HAA operator. While classroom instruction is a preferred method for many topics, others may find it more appropriate to conduct training on some subject areas via computer-based training or some similar method.
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4.5.1 OJT. OJT may be conducted and counted toward the required training hours. Those topics for which OJT are to be used should be clearly identified in the certificate holder’s approved training program. Regardless of whether or not OJT is used to satisfy the training requirements of § 135.619, it is highly recommended that newly trained OCS personnel work under the supervision of an experienced OCS for a period of time after the completion of initial training.
4.5.2 R ecurrent Training . For recurrent training, certificate holders may also use ongoing training such as monthly training modules and abnormal/emergency procedures drills as long as the required hours and topics are accomplished within the 12-month training period. The required annual testing, however, must be accomplished before the end of the twelfth month. Such a training method and the tracking mechanism the operator will use to ensure the training has been completed should be documented in the approved OCS training program.
4.6 Testing. OCS must pass an FAA-approved knowledge and practical test given by the certificate holder on topics required in § 135.619(f). The certificate holder is responsible for developing this knowledge and practical test. The test must cover all topics and must be FAA-approved. The FAA approval is context-sensitive, depending upon the operating environment and the operator’s organizational structure. The POI must assess the adequacy of the operator’s proposed testing methods to ensure an adequate assessment of the individual’s ability is accomplished.
4.6.1 Failure to Complete Recurrent Training. If an OCS fails to satisfactorily complete recurrent training and testing within the preceding 12 months, the individual may not perform OCS duties until the training and testing is accomplished. There is no provision for a grace period. Requalification of OCS following a lapse may be accomplished by satisfactorily completing the recurrent training and testing. The duration of a lapse between previous qualification and requalification via the above training and testing must be determined and justified by the certificate holder.
4.6.2 R etesting . It is recommended that an individual be required to score a minimum of 80 percent in any initial or recurrent OCS testing, and that the test be corrected to 100 percent through topical review with the OCS instructor for each element missed. In the event of a test failure (scoring less than 80 percent), the OCS retest must be preceded by retraining in the subject areas failed; retesting should cover all areas in § 135.619(f).
In the event a retest is required after an initial failure, it is recommended that a different version of the test be used during the retest. The knowledge test must be satisfactorily completed and corrected to 100 percent before the practical test is administered. Failure of the practical test does not require reapplication of the knowledge test, however, a failure of a subsequent practical retest indicates a serious knowledge deficiency and should require the individual to undergo requalification training and retesting.
4.6.3 T est Formats. The knowledge test may be oral, written, or a combination of oral and written, and should be accomplished before the practical portion of the test. The practical portion of the test should evaluate the real-time application of all OCS procedures as well as the use of all normally available and used equipment, computer programs, and other
4-6 technology used by the OCS with special emphasis on new technology and areas of previously identified systemic issues. The method(s) of testing to be used by the certificate holder should be documented in the approved training program.
4.6.4 Annual Recurrent Testing. Certificate holders must describe, in its General Operations Manual (GOM) or approved OCS training program, OCS training and testing procedures, including procedures for retesting after failure and requalification training following an extended absence. As there is no regulatory requirement for requalification training and testing, the operator may define the term beyond which requalification is required and the training requirements to achieve requalification (recommended to be between 40 and 80 hours). Minimum test scores (80 percent recommended) as well as procedures for correcting all tests to 100 percent should be contained in the approved OCS training program.
4.7 Training Records. The certificate holder must maintain a training record for each OCS employed for the duration of that individual’s employment and for 90 calendar-days thereafter. The training record must include a chronological log for each training course, including the number of training hours and the examination dates and results. These records may be stored in paper form or electronically at the discretion of the certificate holder. Certificate holders should be aware that electronic recordkeeping requirements may apply.
5-1 CHAPTER 5. OPERATIONs CONTROL SPECIALIST (OCS) DUTY TIME
LIMITATIONS
5.1 OCS Duty Time Limitations. Each certificate holder must establish the daily duty period for an OCS so that it begins at a time that allows that person to become thoroughly familiar with operational considerations, including existing and anticipated weather conditions in the area of operations, helicopter operations in progress, and helicopter maintenance status, before performing duties associated with any helicopter air ambulance (HAA) operation.
5.1.1 Duty Period. The OCS must remain on duty until relieved by another qualified OCS or until each HAA monitored by that person has completed its flight or gone beyond that person’s jurisdiction.
5.1.2 H ours on Duty. Except in cases where circumstances or emergency conditions beyond the control of the certificate holder, such as a natural disaster, civil curfew, personal crisis, or other situation that prevents relieving personnel from arriving at the Operations Control Center (OCC), require otherwise:
• No certificate holder may schedule an OCS for more than 10 consecutive hours of duty;
• If an OCS is scheduled for more than 10 hours of duty in 24 consecutive hours, the certificate holder must provide that person a rest period of at least 8 hours at or before the end of 10 hours of duty;
• If an OCS is on duty for more than 10 consecutive hours, the certificate holder must provide that person a rest period of at least 8 hours before that person’s next duty period; and
• Each OCS must be relieved of all duty with the certificate holder for at least 24 consecutive hours during any 7 consecutive days.
6-1 CHAPTER 6. DRUG AND ALCOHOL TESTING REQUIREMENTS
6.1 Drug and Alcohol Testing Requirements. Operations Control Specialists (OCS) must be tested for drugs and alcohol according to the certificate holder’s drug and alcohol testing program administered under Title 14 of the Code of Federal Regulations (14 CFR) part 120. OCS are also required to be trained on the certificate holder’s Employee Assistance Program (EAP) in accordance with part 120, § 120.115.