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.
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• Any IT (communications media) anomalies.
• Any new flight operations policies, manual revisions, or bulletins, etc., that have taken effect since the on-coming CS’ last shift.
7.6 Drug Testing Requirements. CS are not, in general, subject to drug testing under 14 CFR part 120, § 120.105 unless they are also acting as an OCS. Certificate holders should be aware that, if any OCS duty or authority is delegated to a CS who has been fully trained as an OCS, they will be subject to drug testing, as required by § 120.105, regardless of their employment relationship with the certificate holder.
Advisory Circular Feedback Form If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by contacting the Air Transportation Division at 9-AFS-200-Correspondence@faa.gov or the Flight Standards Directives Management Officer at 9-AWA-AFB-120-Directives@faa.gov.
Subject: AC 120-96A, Operations Control Center (OCC) for Helicopter Air Ambulance (HAA) Operations Date: _____________________ Please check all appropriate line items:
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