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4.3 Training Topics. The OCS training program should cover the following topics:
4.3.1 Operations Control Specialist (OCS).
• Duties and responsibilities.
• Operational control, concepts, and definition.
4.3.2 Aviation Weather.
• General meteorology.
• Prevailing weather.
• Adverse and deteriorating weather.
• Wind shear.
• Use of aviation weather products available to the operator.
• Cue-based weather training.
• Available sources of information.
• Weather minimums (see Figure 7-1, Risk Assessment Matrix Reflecting Quantification of Factors).
4.3.3 Navigation.
• Navigational Aids (NAVAID).
• Instrument approach procedures (IAP).
• Navigational publications.
• Navigation techniques.
4.3.4 Flight Monitoring.
• Maps/charts.
• Operators commercial air tour routes.
• Local points of interest and checkpoints on navigational publications.
• Local area hazards.
• Primary flight monitoring procedures (specific to operator as per General Operations Manual (GOM)/standard operating procedure (SOP)).
• Alternate flight monitoring procedures (if applicable).
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4.3.5 Air Traffic Control (ATC).
• Airspace.
• ATC procedures.
• Aeronautical charts.
• Aeronautical data sources.
• ATC basic information.
• Who they are and what they do.
• How to contact local ATC in case of an emergency or loss of communication with a pilot.
4.3.6 Aviation Communication.
• Available aircraft communications systems (e.g., very high frequency (VHF), satellite capable, etc.).
• Operator-specific capabilities and what they can do.
• Limitations of aircraft communication.
• Areas of line-of-sight communication.
• Areas without line-of-sight communication.
• Other sources of communication.
• Relayed communication.
• Normal communication procedures.
• Abnormal communications procedures.
• Emergency/alternate communication procedures.
4.3.7 Aircraft Systems. The operation should consider that specific aircraft limitations may require increased levels of operational control, with considerations tailored to each aircraft in a nonstandardized fleet. In other words, less-equipped aircraft necessitate more meticulous management. The following are suggested topics for OCS personnel. It is important to note that this information is presented at a basic level suitable for the operation of commercial air tours.
• Communications systems (company aircraft capabilities, see paragraph 4.3.6 above).
• Navigation systems.
• Surveillance systems.
• Specialized systems (if applicable).
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• General maintenance.
• Minimum equipment lists (MEL) (if applicable).
4.3.8 Aircraft Limitations and Performance.
• Aircraft operational limitations.
• Aircraft performance and performance plans.
• Landing zone (LZ) and landing facility.
• Suitable diversion airports or landing facilities based on landing performance requirements.
4.3.9 Aviation Policy and Regulations.
• Title 14 CFR parts 61, 91, 135, and 136 (pertinent sections).
• Title 49 of the Code of Federal Regulations (49 CFR) part 830.
• Company operations specifications (OpSpecs).
• Company general operations policies.
• Enhanced operational control policies.
• Aeronautical decision making and risk management.
• Lost aircraft procedures.
• Emergency and search and rescue procedures, including plotting coordinates in degrees/minutes/seconds format and degrees/decimal/minutes format.
4.3.10 Crew Resource Management (CRM).
• Concepts and practical application (e.g., working as a team and flight ownership).
• Risk management and risk mitigation.
• Preflight risk analysis procedures.
• How to assist pilot with risk assessment form.
• How to evaluate a risk assessment form.
4.3.11 Area of Operations for Commercial Air Tours. Familiarity with information appropriate to the OCS position pertaining to local geographical features:
• Terrain features.
• Obstructions (e.g., wires, buildings, etc.).
• Weather phenomena for local area.
• Airspace and ATC facilities (sterile cockpit situations).
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• Heliports, airports, LZs, and fuel facilities.
• Instrument approaches (if applicable).
• Predominant air traffic flow.
• Landmarks and cultural features, including areas prone to flat-light, whiteout, and brownout conditions.
• Local aviation and safety resources and contact information. Areas that lack communication should be well-identified.
4.4 Methods of Instructional Delivery. The method of instructional delivery is at the discretion of the operator. Although classroom instruction is a preferred method for many topics, some may deem it more suitable to conduct training on some subject areas through computer-based training or a similar method.
4.4.1 Initial Training. The operator should develop a tailored training program for its OCS personnel. All newly appointed OCS personnel should successfully complete this training before assuming the duties within an EFFC.
4.4.2 On-the-Job Training (OJT). OJT can serve as a continuation of the training, reinforcing learning to ensure a comprehensive understanding. Topics established for OJT should be clearly identified in the commercial air tour operator’s OCS training program. Newly trained OCS personnel are highly recommended to work under the supervision of an experienced OCS (or other qualified personnel) for a specified period after completing the initial training.
4.4.3 Recurrent Training. Commercial air tour operators may utilize ongoing training for OCS personnel, such as annual training modules incorporating abnormal/emergency procedures drills. Alternatively, training could occur quarterly, provided the operator meets preplanned hours and topics within a fixed 12-month training period. Training should be tailored to the operator’s capabilities and documented at least annually.
4.4.4 Testing. OCS should pass a knowledge and practical tests administered by the commercial air tour operator. For 14 CFR part 119 certificate holders (CH), the testing should be inclusive of the CH’s approved training program. The operator is responsible for developing the knowledge and practical tests, covering all topics taught during the initial and recurrent training.
4.4.5 Failure to Complete Recurrent Training. If an OCS candidate fails to satisfactorily complete recurrent training and testing within the preceding 12 months, the air tour operator should not allow the individual to perform OCS duties until the training and testing are completed. Due to the criticality of the OCS position, there should be no provision for a grace period. Requalification following a lapse can be achieved by satisfactorily completing recurrent training and testing, with the duration of the lapse determined by the commercial air tour operator.
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4.4.6 Retesting. It is recommended that an individual achieve a minimum score of 80 percent in any initial or recurrent OCS testing, with the test subsequently corrected to 100 percent through a focused review with the OCS instructor for each missed element. In the case of a test failure (scoring below 80 percent), the OCS retest should be preceded by retraining in the subject areas where failure occurred, covering all topics from the initial or recurrent training, as applicable. If an operator administers a retest after an initial failure, it is recommended to use a different version of the test. The knowledge test should be satisfactorily completed and corrected to 100 percent before proceeding to the practical test. While failure of the practical test does not necessitate a reapplication of the knowledge test, a subsequent failure in a practical retest indicates a significant knowledge deficiency. Therefore, it is recommended that the individual undergo requalification training and retesting.
4.4.7 Test Formats. The knowledge test may take the form of oral, written, or a combination of both, and it should be completed before the practical portion of the test. The practical segment of the test should evaluate the real-time application of all OCS procedures, including the utilization of all regularly available and used equipment, computer programs, and other technology employed by the OCS, with special emphasis on new technology and areas of previously identified systemic issues. The chosen method(s) of testing by the commercial air tour operator should be documented in the approved training program (for 14 CFR part 119 CHs), or a similar document for 14 CFR part 91 commercial air tour operators.
4.4.8 Annual Recurrent Testing. CHs should outline OCS training and testing procedures in their GOM or approved OCS training program. Procedures for retesting after failure and requalification training following an extended absence should be described. As there is no regulatory requirement for requalification training and testing, the operator may define the term beyond which requalification is necessary, considering the need for additional training to achieve requalification. Minimum test scores (80 percent recommended) and procedures for correcting tests to 100 percent should be detailed in the OCS training program.
4.5 Training Records. Commercial air tour operators should maintain a training record for each OCS throughout the duration of their employment and for an indefinite period thereafter. The training record should include a chronological log for each training course, detailing 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 commercial air tour operator.
5-1 CHAPTER 5. OPERATIONS CONTROL SPECIALIST (OCS) DUTY TIME
LIMITATIONS
5.1 OCS Duty Time Limitations. Each commercial air tour operator should establish the daily duty period to begin at a time that allows the OCS to become thoroughly familiar with operational considerations including existing and anticipated weather conditions in the area of operations, tour operations in progress, and maintenance status before performing duties associated with any commercial air tour operation. The operator should consider establishing duty time limitations for OCS personnel to minimize instances of OCS personnel performing their duties while fatigued.
5.1.1 Duty Period. The OCS should remain on duty until relieved by another qualified OCS or until each commercial air tour flight monitored by that person has completed its flight.
5.1.2 Hours on Duty. Except in cases where circumstances or emergency conditions beyond the control of the commercial air tour operator prevent relieving personnel from arriving at the Enhanced Flight Following Center (EFFC), it is recommended that the CH or operator determine duty hour limitations for all OCS personnel.
6-1 CHAPTER 6. DRUG AND ALCOHOL TESTING PROGRAM
6.1 Drug and Alcohol Testing Program. Although this AC and the provided recommendations are not required by regulations, given the critical nature of the duties and responsibilities of an Operations Control Specialist (OCS), if a commercial air tour operator elects to implement an Enhanced Flight Following Center (EFFC), all OCS personnel should participate in the commercial air tour operator’s drug and alcohol testing program administered under 14 CFR part 120. OCS should receive training on the commercial air tour operator’s Employee Assistance Program (EAP) in accordance with 14 CFR § 120.115.
7-1 CHAPTER 7. RISK ANALYSIS TOOL
7.1 Purpose of a Risk Analysis Tool. 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. The operator may or may not choose to utilize a risk analysis tool. Additional information on risk analysis management and tools can be found in AC 120-92, Safety Management Systems for Aviation Service Providers.
7.1.1 Background. The FAA encourages commercial air tour operators to conduct a preflight risk analysis as an essential component of the overall risk analysis, integrated within an operator’s Enhanced Flight Following Center (EFFC). This preflight risk analysis should be incorporated into a comprehensive framework of organizational systems, encompassing policies, procedures, training, and supervision developed based on assessment of day-to-day operational risks.
7.1.2 Risk Assessment. The risk assessment process should produce a quantitative result. This involves identifying hazards associated with a proposed operation and assessing risks associated with each hazard. Once risks are assessed, strategies for risk mitigation can be identified, developed, and implemented. If mitigations fail to reduce risk to an acceptable level, authorization for the flight should not be granted. Unacceptable risks are identifiable as “no go” items, and the flight should not be authorized if a “no go” item is present.
7.1.3 Risk Analysis Components. Risk analysis involves the assessment of two components, Severity (indicating the worst probable outcome) and Likelihood (probability 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.
Note: If the likelihood of an event is estimated to be high, and the consequences are potentially severe, the risk analysis would indicate that the flight should not be conducted until the identified hazards are eliminated or suitable mitigations have reduced the risk to an acceptable level.
7.2 Severity and Likelihood Criteria. This section presents examples of an effective tool utilized by 14 CFR part 135 operators. The intention is to provide a functional tool suitable for everyday operations without unnecessary complexity. Consistent with the approach throughout this AC, the emphasis in this chapter is on the results the tool yields to address safety-related concerns. It is not intended to prescribe the use of a specific methodology of process. The EFFC operator has the discretion to define the final matrix’s design and its definitions. The expressions for each level of severity and likelihood will be tailored to the individual operational environment and operator’s profile, ensuring the decision tools’ relevance to specific needs.
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7.3 Risk Acceptance.
7.3.1 Risk Acceptance. In establishing risk analysis criteria, commercial air tour operators are expected to develop risk acceptance procedures, encompassing acceptance criteria, and designation of authority/responsibility for decision making.
7.3.2 Acceptability of Risk. The acceptability of risk can be assessed using a risk matrix or a numbered system such as those illustrated in Figure 7-1, Risk Assessment Matrix Reflecting Quantification of Factors. A low number corresponds to low or everyday risk, which may be approved by regular OCS personnel. Elevated numbers should be approved at higher levels within an EFFC; for example, a medium risk should be approved by a Chief Pilot, whereas a high risk necessitates approval from both the Chief Pilot and the Director of Operations (DO). There may be certain risks that are deemed unacceptable and are identified as “no go” items.
7.3.2.1 Unacceptable (Red “No Go”). When combinations of severity and likelihood position the risk in the red/high area, it is assessed as unacceptable. A flight should not be authorized under unacceptable conditions until additional controls are developed, either eliminating the associated hazard or which would control the factors that lead to higher risk likelihood or severity.
7.3.2.2 Acceptable With Mitigation (Yellow). If the risk analysis falls into the medium-risk yellow area, the risk may be accepted under defined conditions.
Risk mitigation could involve considering alternate routes/destinations. The decision to initiate an operation should be elevated to the person responsible for decision making at the specified risk level prior to conducting the flight.
For example, landings and takeoffs at high altitude or high-density altitude Landing zones (LZ) present risks resulting from marginal aircraft performance. Risk mitigation might include load reduction or selecting an LZ at a lower altitude, where aircraft performance would be improved, and the impact on the flight would be minimal.
7.3.2.3 Acceptable (Green). Where the assessed risk falls into the green area, it can be accepted by the OCS staff and the pilot without further action. The objective should always be to reduce risk to as low as practicable.
7.4 Safety Risk Assessment. The operator should establish written policies that delineate acceptable levels of risk in numerical terms, procedures for determining risk acceptability, and steps to be taken for a given level of assessed risk, including risk control strategies. The FAA strongly encourages commercial air tour operators to have documented procedures for elevating the management level for flight approval when the risk exceeds predetermined levels.
7.5 Risk Assessment Matrix Example. The definitions and design of a risk analysis matrix are left to the commercial air tour operator. An individualized design ensures each of the operator’s decision tools is relevant to its specific needs. An example of a single-sided paper form is included in this chapter (see Figure 7-1). Note that the numbers on this
7-3 example form are universal representations of an analysis and may be changed by each operator. Not only can the value assigned to each factor be altered, but the factors selected may be changed to meet the operator’s needs. For instance, an operator in an inland area may not need to consider glide distance from shore for overwater flights, while one operating on an island would have to do so. Another relative example is how many tours can be conducted in one day. It is up to the commercial air tour operator to decide the risk assigned to each given application to determine what is or is not acceptable.
7-4 Figure 7-1. Risk Assessment Matrix Reflecting Quantification of Factors Step 1. Complete a system and task analysis matrix.
• Fill out a risk assessment document using the enclosed example below. Follow the instructions in steps 2 through 5 to create a document specific to the operator’s needs and then quantify what is acceptable and nonacceptable.
Step 2. Primary objective is to identify the hazards to flight.
• It’s rainy.
• It’s hot and the Density Altitude (DA) is high.
• The destination crosswinds are greater than 20 knots (if applicable).
Step 3. Secondary objective is to analyze the safety risk (Severity and Likelihood).
• The combination of the risk factors associated with this proposed flight generates a risk value of 50, using the example risk assessment tool.
Step 4. Assess the safety risk.
• Company policy should consider implementing company policies considering the Chief Pilot assessment and approval of any flight risk value exceeds 50. Given that the risk value of 50 surpasses the company’s operational threshold risk of 49, the Chief Pilot decides to operate the flight. To achieve this, the Chief Pilot may adjust the flight route or wait until conditions change, effectively reducing the flight risk value to a more acceptable level.
Step 5. Control the safety risk.
• The Chief Pilot focuses on mitigating adjustable hazards, recognizing that not all hazards can be fully mitigated. Certain “no go” items cannot be downplayed or mitigated.
a. The Chief Pilot decides to permit the scheduled PIC to operate the flight if risks can be lessened or removed.
b. The reduction of risk may prompt the reassignment of the specific flight to another PIC who possesses greater experience with the make of aircraft, who has conducted recent IIMC training, or who has flown more route segments.
c. Further mitigation may necessitate the Chief Pilot involvement and the need to alter the route or area to an area with no high-risk conditions expected or to terminate the flight.
• By closely monitoring the risk values associated with these identified three hazards, the Chief Pilot successfully reduces the overall flight risk value to 35, effectively controlling the level of safety in operations.
7-5 DATE: PILOT NAME: ____________ ACFT #:
CALL SIGN:
COMMERCIAL AIR TOUR ROUTE/S:
RISK FACTOR
1. Pilot Duty/Rest and Health 10. Fuel More than 10 hours rest and not ill or sick = 0 Onboard fuel exceeds required by 10 % = 0
8 to 10 hours rest +5 Onboard fuel meets minimum fuel +10 8 to 6 hours rest and or light pain +15 Onboard fuel does not meet CFR or refuel req. no go
Less than 6 hours rest and or severe pain +50 no go 11. Recency of Emergency Training
2. Commercial Air Tour Experience Within last 3 months = 0 More than 1 year = 0 6–19 months +5 6 months to 1 year +5 9–12 months +10 Less than 6 months +10 12 months or more +50 no go
3. Route Experience With Operator 12. Aircraft Equipment 20 times or more on same route = 0 No GPS +10 Less than 20 times with route +5 One radio +10
4. Aircraft Experience With Operator No ATT indicator +15 More than 250 hrs in model = 0 No HDG indicator +10 Between 50 and 250 hours in model +5 SATCOM equipped -10 reduction Less than 50 hrs in model +15 GPS datalink -10 reduction
5. Commercial Air Tour Flights Previously Conducted for the Day Cell phone coverage -5 reduction 1–2 tours = 0 ADS-B In and Out -10 reduction 2–4 tours +5 13. MEL 4–6 tours +10 Nav. or comm. Inop. +10 More than 6 tours +30 14. IIMC Training
6. Length of Each Tour Route IFR current -10 reduction 1 hours or less = 0 Within last 3 months = 0 1–2 hours +5 6–9 months +5 More than 2 hours +10 9–12 months +10