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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.
7-1 CHAPTER 7. COMMUNICATIONS SPECIALISTS (CS) DUTIES AND TRAINING
7.1 General. CS serve a limited role in the helicopter air ambulance (HAA) industry. Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.619 defines duties and responsibilities of the Operations Control Specialist (OCS) and effectively limits the CS role to tasks not performed by the OCS.
7.2 CS Duties. This chapter provides guidance on CS duties and related training topics that will assist operators in the establishment of an effective CS training program. A properly trained and tested CS may be assigned the following duties:
7.2.1 Flight Requests. Receive flight requests from customers (hospitals, emergency medical service (EMS) agencies, etc.). Certificate holders are encouraged to establish written procedures outlining the information to be obtained from the customer, including pickup point and destination, patient weight(s), if available, ground communications contacts, and any pertinent information required by the medical personnel. A pilot in command (PIC) should not be given patient information other than patient weight during the flight notification to avoid influencing the pilot’s “Go” or “No-Go” decision.
7.2.2 P rior Refusal/Rejection of Flight Requ ests. Collect information regarding prior refusals or rejections of a flight request from the requestor. This information is required for the risk analysis process in accordance with § 135.617 and is most easily acquired when receiving a flight request. Though the regulation does not require any further information beyond whether or not the flight request had been previously declined, the informational foundation upon which the risk analysis process will be performed is greatly enhanced when the reason for declining the flight is known (e.g., the impact on flight risk analysis of a request declined due to an aircraft out of service differs substantially from being declined because the weather exceeded the previous operator’s comfort level or weather limitations). The CS will include this information when passing the flight request to the PIC or to the OCS, as prescribed by the operator’s procedures. Certificate holders are encouraged to have a checklist and documented procedure for obtaining this and other pertinent information from the requestor.
7.2.3 C oordination. In some cases, certificate holders may find it advantageous for the CS to notify the Operations Control Center (OCC) of the content of a flight request in addition to, or instead of, the pilot. The CS should provide the flight request details as soon as it is feasible to facilitate the risk analysis. This process should be documented and should be included in CS training.
7.2.4 C ommunication. Provide communication relay between the OCS and the pilot in flight.
In some localities, and due to communications system limitations, some HAA operations require a communication relay between airborne flights and the OCC. In these cases, the CS provides that relay function. Relaying of information, including risk analysis data between the HAA pilot and the OCC, is especially important when an unplanned diversion is required or requested by the customer while en route and the HAA pilot can’t communicate directly with the OCC.
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7.2.5 Recording and Relaying of Flight Position. Though the OCC must monitor the progress of each HAA flight in accordance with § 135.619(a)(3), a CS may maintain a secondary awareness (a “second set of eyes”) of the current location of each HAA flight operation within the geographic area served. Though the OCC in most HAA operations accomplishes flight monitoring through satellite tracking of their aircraft, some rely upon receipt of position reports received from the HAA pilot and relayed through the CS. The certificate holder may find it useful for the CS to maintain a log of position reports or satellite tracking in hardcopy or separate from the online information technology (IT) system. This ensures continuity of flight monitoring in the event of technology failure and to enable the OCS to maintain continuity of flight monitoring in the event of a disruption in the OCC’s ability to continuously monitor flights.
7.2.6 U nplanned Events. Advise the OCC of unplanned events during an HAA operation. The CS may advise the OCC of observed unplanned events during an HAA operation, including diversions, precautionary landings, or any other event deemed appropriate by the certificate holder.
7.2.7 Po st -Accident/Incident Plan (PAIP). Procedures should be documented for the CS to follow at the direction of the OCS 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 when directed, procedures for notification of local EMS, fire, and police, if necessary, in the area where the aircraft is believed to be located. It is recommended that a current 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 CS work station in duplicate of those maintained in the OCC.
7.2.8 Mi scellaneous. Other duties, except OCS duties in accordance with § 135.619(a), deemed necessary and appropriate by the certificate holder.
7.3 CS Training. Effective training is essential because the CS not only receives flight requests, but may also interface with the pilot and the OCS. CS may be employed by the HAA operator, a hospital, an ambulance dispatch center, or local law enforcement entities (e.g., local public safety or 911 dispatchers). Regardless by whom they are employed, all CS should be trained by the certificate holder, or by a designee approved by the operator, in their duties and responsibilities in accordance with the certificate holder’s training program. The certificate holder remains responsible for the quality and effectiveness of training provided by a designee and should conduct testing and/or observation to ensure the CS is able to adequately perform CS duties and responsibilities.
CS are not permitted to engage in OCS duties and responsibilities, including operational control, which remain the exclusive domain of the on-duty OCS or other persons who may exercise operational control authority.
7.3.1 Limits of Duties and Responsibilities. It cannot be overemphasized that any training provided to the CS should include the limits of the CS’ duties and responsibilities and the OCS duties and responsibilities that must not be performed by the CS. For instance, a CS may engage in relaying information to and from pilots (in the same manner as
7-3 transoceanic flights frequently communicate with ARINC (an internationally recognized communication company), who acts as a relay for requests and responses to and from air traffic control (ATC) or an operator’s maintenance control department, etc., transferring information and requests between the pilot and the OCS, and may perform secondary flight monitoring to back up the OCS who performs primary flight monitoring). The CS may not be authorized to gather weather information and provide a weather briefing to a pilot in flight. Likewise, the CS should never engage in the review of risk analyses or the preparation of a weather briefing for a pilot nor the authorization of an HAA flight operation.
7.3.2 R ecurrent Training . Recurrent training should also be conducted annually.
7.3.3 Emergency/Abnormal Event Training. The certificate holder may find it valuable to train and test some remote communications center staff, including CS and OCS, in accordance with § 135.619(d) so these individuals are prepared to take over OCC duties such as flight monitoring should an emergency or abnormal event (fire, earthquake, tornado, flood, power failure, etc.) occur that causes normal OCC operations to be temporarily discontinued. The limits of the CS responsibility during such a time should be clearly documented in company manuals or standard operating procedures (SOP) and appropriate training provided.
Note: I t is recommended that such an event be drilled periodically (perhaps every 6 months) under supervision from a certificate holder OCC representative.
Procedures should also be established, much like those for the OCC, to continue communications center operations in a contingency mode after an emergency or abnormal condition arises that may cause a shutdown of the CS facilities.
7.3.4 T raining Records. Appropriate records of the training should be maintained by the certificate holder.
7.4 D uty Periods. Stressful conditions may develop in communications centers during periods of high activity. Because of this, the certificate holder should consider fatigue and cumulative stress when formulating CS schedules. Due consideration should also be given to scheduling breaks. When possible, a relief CS should be available to take over for a CS when unplanned breaks are required, and a process should be documented for a briefing to be given to the person providing that relief.
7.5 Shift Change Procedures. Certificate holders are encouraged to develop a written shift change briefing to ensure continuity of safe operations. This briefing should include, at a minimum:
• Procedures for ensuring the on-coming CS is aware of all HAA operations currently in progress and those already scheduled and expected to begin momentarily.
• Any HAA operations being conducted with a risk level that exceeded the lowest rating category and required management review or those that employed risk mitigation strategies.