Par 6-1 Page 51 CHAPTER 6. OPERATIONS CONTROL CENTER (OCC)
6-1. GENERAL. This chapter summarizes regulatory requirements, recommendations and best practices regarding the Operations Control Center (OCC). An OCC is required for operators conducting helicopter air ambulance (HAA) operations with 10 or more HAAs and is recommended for other operators. The OCC requirement becomes effective on April 22, 2016.
The current edition of Advisory Circular (AC) 120-96, Integration of Operation Control Centers into Helicopter Emergency Medical Services Operations, provides detailed guidance, including recommendations on establishing the physical layout of an OCC. This chapter provides recommendations to assist HAA operators with identifying best practices for implementing OCCs and operations control procedures. It is intended to help encourage and enable operators without a regulatory requirement to establish and operate an OCC to attain their operational benefit.
6-2. CORE CONCEPTS: OCC AND ENHANCED OPERATIONS CONTROL PROCEDURES. There are three primary concepts from AC 120-96 that define an effective OCC and enhanced operations control procedures:
a. Joint Flight Safety Responsibility. The first concept is joint flight safety responsibility for each HAA flight. Joint flight safety responsibility requires that at least one qualified ground staff member, in addition to the PIC, be actively involved in reviewing the PIC risk analysis in accordance with the required risk analysis program (Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.617) and be responsible for monitoring factors affecting flight safety before and during the flight. The utilization of qualified Operations Control Specialists (OCS) on the ground also provides additional support and risk monitoring redundancy for pilots in high workload situations.
b. Written Standard Operating Procedures (SOP). The second concept is a requirement for documented SOPs that are used to guide training and standardize operations performance.
Standardization of written Operations Control procedures reflects the same concerns that mandate the use of checklists on the flight deck. SOPs are documented so they can be referenced and performed the same way each time. The detail and scope of this documentation should reflect the size and complexity of each HAA operations. SOPs may be accessed either electronically or via hard copy (refer to Operations Specification (OpSpec) A061, Use of Electronic Flight Bag, for in-flight use of electronic documentation), Regardless, written procedures should be readily available, especially in times of high work load situations such as abnormal or emergency operations.
(1) Though industry is moving towards a less paper-dependent environment, a truly paperless environment has yet to be achieved. A key technology (e.g., a local area network (LAN) or workstation) may fail in conjunction with an emergency, or could even be the cause of emergency or abnormal operations. Technology failures may render electronic access to written SOPs unavailable. Therefore, while standard access to written SOPs may be accomplished electronically, these SOPs may not be available, especially in an emergency situation. Hard copy current written versions of all critical SOPs should be maintained and be readily available for use during abnormal or emergency operations.
Par 6-2 Page 52
(2) The requirement for hard copy Operational Control SOPs therefore mandates that the operator also include the Operations Control SOPs in the version and distribution control SOP for managing other required hard copy documents.
(3) Operators should also develop an SOP to provide for a continual internal process to solicit, obtain, and respond to feedback on SOPs and update these SOPs and ensure the value of training based on them. An SOP is needed to provide for a vehicle to continually receive feedback on procedures, respond to and prioritize feedback and accordingly, update procedures, inform staff of changes to procedures, and train staff on new procedures.
c. Leveraging Technology and Communication. The third core concept of OCCs and enhanced operations control procedures is to leverage technology and communication to enhance safety and efficiency. This includes providing an enhanced level of situational awareness to the pilot in command (PIC), OCS, and other individuals.
(1) Flight Operations Support. An OCC is an optimal environment for leveraging technology to support flight operations. An OCC’s centralized location can provide economies of scale that make it economically viable to invest in both the information technology (IT) infrastructure and the IT support staff required to support its functions.
(2) Benefits to HAA Operations. An OCC can leverage technology to provide communication and safety benefits to HAA operations. For example, an OCC may be able to acquire weather information for currently non-covered locations. This information may come from a variety of weather feeds available at the OCC, including non-aviation sources such as telephone calls.
(3) Situational Awareness Improvement. As a result of this leveraging of technology, an OCC can contribute to improving the situational awareness of HAA personnel. This includes receiving and filtering information (including weather as in the example above) and providing inputs for or conducting shift-change and preflight briefings.
(4) Provision of Situational Awareness Information. In addition to the regulatory requirements the operator should establish and document procedures to acquire, fuse and provide situational awareness information to the PIC, using the OCC, OCS and other individuals and capabilities as appropriate. This is an example of the use of leveraging technology and communications to reduce risk in HAA operations.
(5) Shift Change Briefing. Operators should have a procedure to ensure the explicit provision by the OCS being relieved, of information on current operational and flight conditions, locations and status of all flights transferred to the relieving OCS, with emphasis placed on hazard updates to the pilots. This may include using conference call or other technology to link personnel at remote sites. This is an example of the use of leveraging technology and communications to reduce risk in HAA operations.
Par 6-3 Page 53
6-3. OCS.
a. OCS Requirements. The OCS is a critical component of the overall concept of emphasizing safe HAA operations. An OCS must be trained for a range of capabilities, as set out in paragraph 4-5 of this AC. The OCS must:
(1) Provide two-way communications with pilots.
(2) Provide pilots with weather briefings, to include current and forecast weather along a planned route of flight.
(3) Monitor progress of each HAA flight.
(4) Ensure pilots have completed all of the required items (as described in § 135.617) on a preflight risk analysis worksheet.
(5) Acknowledge, in writing, specifying date and time, that a preflight risk analysis worksheet has been accurately completed and that, according to their professional judgment, a flight can be conducted safely (as described in § 135.619(a)(iv)).
b. OCS Recommended Capabilities. It is recommended that an OCS:
(1) Participate in adjustments to risk analysis as a continuous process throughout a flight while carrying out regulatory-required flight monitoring responsibilities;
(2) Assist the pilot in mitigating any identified high risk prior to takeoff; and
(3) Secure management approval of a flight authorization if a predetermined level of individual or total risk is exceeded.
6-4. OCC FACILITIES AND CAPABILITIES. AC 120-96 describes possible OCC facilities and capabilities that can be realized by many different structures and physical configurations, depending on operator requirements. There are many possible alternatives, depending on the size and scope of the HAA operator. The OCC provides a physical location where the OCS and any other personnel can access technologies with the overall objective of being able to assist the PIC.
a. Recommended OCC Facilities. The following hardware and software resources should be considered as best practices for developing an OCC. Refer to AC 120-96 for further explanation and details concerning the following issues:
(1) Enabling technologies (to include LANs, Internet access, and digital signature capabilities for form completion).
(2) Aircraft situational displays depicting status of all certificate holder HAA aircraft.
(3) Aviation weather analysis tools (to include textual, graphical and Geographic Information System (GIS)-enabled).
(4) Notice to Airmen (NOTAM) tools (both textual and graphical).
Par 6-4 Page 54
(5) Air traffic flow tools (to include temporary flight restrictions, special use airspace, special areas of operation, military operations airspace, high density and congested airspace, warning areas and weather watch boxes).
(6) Communication tools (to include telephones, email, datalink, radio (aircraft and first responders including Voice over Internet Protocol (VoIP) capabilities), satellite communications (SATCOM) and advanced communication consoles).
(7) Non-aviation situational awareness tools such as the Federal Highway Administration (FHWA) Meteorological Assimilation Data Ingest System (MADIS), Internet capable of accessing weather cams, or television capable of receiving cable news channels.
b. Adapting OCC Facilities and Capabilities to Smaller Operators. Smaller (less than 10 HAAs) operators are not required by regulation to have an OCC staffed by OCSs. However, best practices of such operators have provided examples of the use of similar appropriately scaled methods to achieve the same goal.
c. Voluntary Implementation. If an OCC is not required and the operator chooses to voluntarily implement a similar capability or function, the operator’s policies and procedures (and details of training specialists in operations control subject matter) should be established and documented by the operators in their General Operations Manuals (GOM) or other permissible forms of documentation. This documentation system must be accepted by the principal operations inspector (POI). The operator should demonstrate that operational control and PIC responsibility and authority is maintained and safety is not compromised through the duties and responsibilities of the individuals staffing that non-regulatory function.
d. Training Requirements. Operations control training of existing staff members should reflect the training requirements of § 135.619(b). Creating SOPs appropriately reflecting the size and complexity of the operation makes it possible for a small operator to increase the safety of their HAA operations with minimal expense.
Par 7-1 Page 55 CHAPTER 7. MANUALS, DOCUMENTATION, AND RECORDS
7-1. GENERAL. Title 14 of the Code of Federal Regulations (14 CFR) part 135 certificate holders conducting helicopter air ambulance (HAA) operations are subject to generally the same documentation and recordkeeping requirements as are other part 135 certificate holders, with a few additions.
7-2. MANUALS AND DOCUMENTATION. Part 135 certificate holders conducting HAA operations are required to compile and maintain Federal Aviation Administration (FAA)-approved procedures for preflight risk analysis (part 135, § 135.617) and visual flight rules (VFR) flight planning (§ 135.615). The following are subject matter areas which, due to either regulatory requirements or industry best practices, should be included in approved/acceptable documentation in a manual (or other accepted format) that goes beyond those required of other part 135 operations. The list below does not relieve the certificate holder from including other items in their operations manual as required.
a. General Operations Manual (GOM). It is recommended that each single-pilot and basic part 135 certificate holder conducting HAA operations, develop a GOM that covers the subject matter contained in §§ 135.23, 135.615, and 135.617. This manual should be available in each helicopter and at each location where flights are initiated.
b. Accident Incident Plan/Post-Accident Incident Plan (AIP/PAIP). All HAA operators, regardless of size, must establish accident and incident notification procedures, to include the local FAA office, National Transportation Safety Board (NTSB) and FAA certificate-holding district office (CHDO) telephone numbers. This is a requirement shared with other part 135 operations. Due to the nature of the distributed base operation generally conducted by HAA operators, this requirement may be somewhat more complex than a response plan for a single base non-HAA part 135 operation. (Refer to § 135.23(d).)
c. Rapid Refueling Procedures. Refueling with the engine(s) running, rotors turning, and/or passengers on board can be hazardous and must be accomplished in accordance with appropriate documented procedures and by trained personnel.
d. Fuel Quality. Due to the nature of HAA operations, many bases are at locations other than airports. It is recommended that operator-developed documentation define a program for determining and maintaining fuel quality. The operator may choose to procure fuel from commercial fixed base operator sources and/or maintain fuel quality within their own system throughout the chain of custody from receipt (from the distributor) to delivery (into the helicopter). It is recommended that the operator consult International Civil Aviation Organization (ICAO) Doc 9977 AN/489 Manual on Civil Aviation Jet Fuel Supply and the current edition of Advisory Circular (AC) 150/5230-4, Aircraft Fuel Storage, Handling, and Dispensing on Airports.
e. Procedures for Medical Equipment Installation and Removal. Removal and replacement of medical equipment items may have to be performed on a frequent basis. If the operation is simple, does not require tools, and can be done in accordance with approved data and procedures contained in the operator’s manual, any person trained by the certificate holder
Par 7-2 Page 56 may be authorized to remove or replace such equipment. If the operator chooses this option, they must include this training in their FAA-approved training and checking program. The HAA operator must document who is authorized to remove and replace equipment on its helicopters. If personnel other than certified mechanics will be removing or replacing equipment, they must do so in accordance with documented instructions and training provided.
f. Flight Authorization and Flight Locating Procedures and Operations Control Personnel Duties and Responsibilities. These should be well considered and be documented in the operations manual. For those operators with an Operations Control Center (OCC), a description of the duties and responsibilities of Operations Control Specialists (OCS) should appear in documentation (refer to § 135.619(c)). Operators not establishing an OCC should document procedures for comparable functions.
g. Local Flying Area (LFA) Documentation. Procedures for developing LFAs should be documented in accordance with § 135.611(a)(2). If any LFAs are proposed and accepted, a list of LFAs and a description of the examination that is given to pilots by the certificate holder enabling the use of alternative minima in these LFAs must be provided to the principal operations inspector (POI) for acceptance. (Refer to § 135.609 and Operations Specification (OpSpec) A021, Helicopter Air Ambulance Operations.)
h. Instrument Flight Rules (IFR) Operating Procedures. The FAA intends to facilitate use of the IFR system by HAA operations through developing approaches and departures to and from heliports that are not served by weather reporting and in accordance with Instrument Approach Procedures (IAP) and departure procedures Standard Instrument Departures (SID) and Obstacle Departure Procedures (ODP) that are developed specifically to serve these heliports.
Certificate holders should document procedures for IFR operations at locations without weather reporting (refer to § 135.611). The operator should document procedures for IFR operations using publicly available published IAPs or per privately developed, FAA approved special instrument procedures, point in space (PinS) approach procedures and SIDs/ODPs.
i. VFR Flight Planning Procedures. VFR flight planning procedures must, by regulation, be documented in accordance with § 135.615(d.) As part of the VFR planning process, operators must document their procedures for determining and documenting the highest obstacles and minimum obstacle clearance altitudes along intended routes of flight (including any contingency routes) prior to departure.
j. FAA-Approved Preflight Risk Analysis Procedures. Risk analysis procedures must be documented in accordance with § 135.617. These procedures are discussed in paragraph 3-4 and Appendix A of this AC.
7-3. RECORDS. Part 135 certificate holders conducting HAA operations are subject to recordkeeping requirements above those required of other part 135 operators not engaged in such operations. Records required by § 135.63 should be kept at an operator’s principal business office or other location(s) approved by the Administrator.
Par 7-3 Page 57 (and 58)
a. Pilot Training Records.
(1) LFA(s) Familiarity Verifications. A record of the 12-month local area demonstration or examination given to each pilot for each LFA assigned. (Refer to § 135.609.)
b. Non-Pilot Training Records. Also, see Chapter 4, Training Program.
(1) Preflight Risk Analysis Worksheets. Preflight risk analysis worksheets completed by pilots and OCS in compliance with § 135.617 are subsequently maintained in compliance with §§ 135.617 and 135.619.
(2) OCS. Training records are kept at least for the duration of that individual’s employment and for 90 days thereafter. Training records are required by § 135.619(e) to include a chronological log for each course, including the number of hours and the examination dates and results as well as copies of such examinations. Development of a record of OCS duty times would facilitate tracking.
(3) Maintenance Personnel. A recordkeeping system should be used allowing supplemental training to be verified and tracked.
(4) Medical Personnel. Each HAA operator must maintain a record of training for each medical crewmember that contains the individual’s name, the most recent training completion date and a description, copy or reference to training materials used to meet the training requirement. This must be maintained for 24 calendar-months following the individual’s completion of training.
c. Administrative Records.
(1) OCS Personnel. OCS personnel are among those employees for whom drug and alcohol testing program records must be maintained in accordance with 14 CFR part 120, §§ 120.105 and 120.215.
(2) Timekeeping. Each operator must maintain flight time and duty records for flightcrews. It is recommended that it do the same for OCS personnel to demonstrate compliance with duty time requirements.
Par 8-1 Page 59 CHAPTER 8. SAFETY
8-1. GENERAL. This chapter is intended to make current and potential operators aware of considerations underlying the safety culture that is central to best practices throughout helicopter air ambulance (HAA) operations. An effective safety program should be developed considering all aspects of the operator’s policies and procedures essential to the safe completion of a HAA flight. Best safety culture practices, even where they are not an explicit part of the regulations, facilitate compliance and enhance safety. Examples of ways to foster the safety culture are presented in greater detail in Appendix B of this advisory circular (AC).
8-2. SAFETY CONSIDERATIONS FOR HAA OPERATIONS.
a. Safety Commitment. Commitment to safety should start at the top of an organization.
The single most important element of a successful safety program is the commitment of senior management. Safety cannot be dictated; it should be practiced. Managers should lead by example and display a safety-conscious attitude including being involved in safety activities. Operators should conduct regular base safety meetings for all affected base and flight personnel.
b. Safety Management System (SMS). Establishment of an effective SMS helps implement a safety culture to address safety considerations unique to HAA operations. Examples of the use of a SMS are provided in Appendix B of this document.
c. Safety Personnel. The HAA operator should designate a safety officer. This individual should be familiar with each aspect of an HAA operation with particular emphasis on safety requirements unique to helicopters. This individual should plan, organize and disseminate information about the safety program to all involved persons. The safety officer should make an effort to reach out to relevant helicopter information sources and organizations such as the International Helicopter Safety Team (IHST), U.S. Helicopter Safety Team (USHST), and Helicopter Association International (HAI) and carefully review the wide range of fact sheets and toolkits available for applicability to their own operations.
8-3. ROLE OF COMPANY PHILOSOPHY AND EXECUTIVE/SENIOR MANAGEMENT.
a. Management Commitment. The regulatory requirement for some HAA operators to establish an Operations Control Center (OCC) (and the recommendation that those not so required carry out OCC functions) is likely to require the commitment of management to be effective. Many existing communication centers have evolved and operated mostly autonomously since their inception. HAA operators may experience difficulty transitioning from the previously autonomous communication centers as an OCC comes online. Management should plan to overcome these issues through education and communication.
b. Philosophy. In is important that an HAA operator’s entire organization embrace and promote a cohesive operational philosophy that provides direction for an OCC (or its functions) and the enhanced operations control procedures described in this AC. The instillation of a company philosophy that enhanced flight operations described in this AC are a team effort. They are not simply a matter of a flightcrew receiving basic flight request information and then it being the flightcrew’s responsibility to complete the flight.
Par 8-4 Page 60
8-4. EMERGENCY OPERATIONS. The longer that an OCC and enhanced operations control procedures described in this AC are used, the more the organization relies upon their availability.
This may result in increasing impact on the ability of the organization to continue functioning if these are interrupted.
a. Documentation. It is recommended that HAA operators prepare emergency procedures that most effectively leverage resources available to the operator, including the OCC. This will include, but may not be limited to those procedures documented by the applicable Accident Incident Plan/Post-Accident Incident Plan (AIP/PAIP). Such procedures should be prepared to provide guidance on how to carry out HAA operations in emergency or degraded capability situations and to manage the partial or total loss of critical capabilities such as OCC and enhanced operations control functions.
b. Training and Drills. It is recommended that an HAA operator conduct regular refresher training and drills to maintain the organization’s ability to follow these procedures.
Drills should be conducted annually at minimum; more often is preferred.
Appendix A APPENDIX A. SAMPLE RISK ANALYSIS TOOLS A-1. PURPOSE OF THIS APPENDIX. The information in this appendix is provided to assist in developing a risk analysis process. It provides examples of approaches that may be used by a helicopter air ambulance (HAA) operator to assess, mitigate, and manage risk. Additional information on risk analysis management can be found in the current edition of Advisory Circular (AC) 120-92, Safety Management Systems for Aviation Service Providers.
a. Background. Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.617 requires preflight risk analysis to be conducted as part of the overall risk analysis and, where applicable, be supported by an operator’s Operations Control Center (OCC). These requirements should be implemented within a broader framework of organizational systems, including policies, procedures, training and supervision that have been developed based on assessment of day-to-day HAA operational risks.
b. Risk Assessment. The risk assessment process should produce a quantitative result.
The process involves identifying hazards associated with a proposed operation and assessing risks associated with each hazard. After risks are assessed, risk mitigation strategies can be identified, developed and implemented. If mitigations will not reduce risk to an acceptable level, a flight should not be authorized.
c. Risk Analysis Components. Risk analysis has two components that are assessed:
severity (what is the worst probable outcome) and likelihood (of occurrence). Severity refers to the consequences of an event resulting from the hazard. Likelihood is an estimate of how likely the event is to occur. If the likelihood of an event is estimated to be high, and the consequences potentially severe, the risk analysis would indicate that the flight should not be operated until the identified hazards are eliminated or suitable mitigations have reduced the risk to an acceptable level.
A-2. SEVERITY AND LIKELIHOOD CRITERIA. This appendix provides some examples of one effective tool that has been used by several HAA operators and is intended to be functional for everyday operations without being cumbersome. As throughout the AC, the focus of this appendix is on the results it yields to inform regulatory required actions and it is not intended to prescribe the use of a particular methodology of process. The definitions and design of the final matrix is left to the HAA operator. The definitions of each level of severity and likelihood will be expressed in terms realistic for the individual operational environment and operator’s profile. This ensures the relevance of decision tools to the operator’s specific needs.
An example of severity and likelihood definitions is shown in the table below.
Appendix A FIGURE A-1. SAMPLE SEVERITY AND LIKELIHOOD CRITERIA Severity of Consequences Likelihood of Occurrence Severity Level Definition Value Likelihood Level Definition Value Catastrophic Equipment destroyed, multiple deaths 5 Frequent Likely to occur many times 5 Hazardous Large reduction in safety margins, physical distress or a workload such that operators cannot be relied upon to perform their tasks accurately or completely. Serious injury or death. Major equipment damage.
4 Occasional Likely to occur sometimes 4 Major Significant reduction in safety margins, reduction in the ability of operators to cope with adverse operating conditions as a result of an increase in workload, or as result of conditions impairing their efficiency. Serious incident. Injury to persons.
3 Remote Unlikely, but possible to occur 3 Minor Nuisance. Operating limitations. Use of emergency procedures.
Minor incident.
2 Improbable Very unlikely to occur 2 Negligible Little consequence 1 Extremely Improbable Almost inconceivable that the event will occur 1