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.
7-2
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
7-6 DATE: PILOT NAME: ____________ ACFT #:
CALL SIGN:
COMMERCIAL AIR TOUR ROUTE/S:
RISK FACTOR
7. Weather 15. ATC Ceiling greater than 5000’ and 5 miles visibility = 0 High traffic area +10 Less than 5&5, but greater than 2000 and 4 miles +5 Low traffic area = 0 Greater than 1000-3, but less than 2000-4 +10 16. Site Specific 1000-3 or less no go +50 More than 3 aircraft at site +10 Icing if present without deice no go +50 Small area only capable of 2 acft. +10 Precipitation more than light or drizzle no go +50 Multiple flight paths to site +5 Turbulence above Moderate no go +50 FORM TOTAL Thunderstorms present on route no go +50
8. Terrain Free of hazards with large landing areas and no wires = 0
Overwater +10 Risk Level Approval Rough/jagged no emergency landing areas +15 Low Risk: 0–75 OCS CAN SIGN
APPROVAL
9. Lighting Medium Risk: 75–125 CHIEF PILOT
CAN APPROVE
Daylight high illum. no issues = 0 High Risk: 125–200 CHIEF AND DO
SHOULD SIGN APPROVAL
Whiteout chances high +15 Brownout chances high +15 PILOT SIGNATURE:
Flat light chances high no go OCS SIGNATURE:
Nighttime no illum. no aid +25 APPROVAL AUTHORITY:
7-7 Figure 7-2. Sample Risk Assessment Matrix Additional Information Definitions and Abbreviations Pilot – The pilot who is planned to be predominantly at the controls during critical phases of flight.
(FW) – Item applies to fixed-wing aircraft.
(RW) – Item applies to rotorcraft aircraft.
No go items cannot be mitigated.
Additional Information – Examples
1. Pilot Rest and Health. Health and rest of pilot is essential. Good sleep and health ensure an alert pilot. Less sleep and decreased health increases risk numbers.
2. Commercial Air Tour Experience. More experience conducting the operators planned tours increases situational awareness and thus decreases risk.
3. Route Experience. More experience with an individual route decreases risk and identifies problematic areas and weather phenomena.
4. Aircraft Experience. More experience by make and model decreases risk.
5. Commercial Air Tour Flights Previously Conducted for the Day. 1–2 commercial air tours a day is much less risk than conducting 6 a day. Less flights less risk.
6. Length of Each Tour Route. Commercial air tour route length based on environment and time.
7. Weather. Weather that is greater than 5 miles of visibility and more than 5000 feet of ceiling is relatively free of a weather risk for commercial air tours, but as weather decrease the risk exponentially increases. Weather close to or less than a 3 miles visibility and 1000-foot ceiling should be prohibited and is a “no go” item. Severe turbulence is no go. Icing conditions without equipment is no go, and rain more than Light or Drizzle is no go, thunderstorms are no go items.
8. Terrain. Terrain can play a very important part in determining risk. Areas that will not provide for a safe landing in the event of an emergency are significantly higher in risk than say a flat area free of obstacles.
9. Lighting. Commercial air tours are conducted into very diverse areas and the amount of lighting or effects on lighting can alter a pilot’s perception relative to the earth. Less light increases risk. Light can be limited if blowing snow or dust is encountered. Technological advanced aircraft may provide mitigation by increasing situational awareness.
10. Fuel. Extra fuel onboard an aircraft conducting tours allows for multiple options during a tour and may preclude an inadvertent weather encounter thus lessening risk. Minimal fuel limits decisions and increases risk.
11. Recency of Emergency Training. Pilots that are recently trained in flight are more prepared to handle emergencies and have less risk.
12. Aircraft Equipment. More equipped aircraft provide more situational awareness to the pilot and decrease risk.
13. Minimum Equipment List (MEL). Aircraft that have inoperable navigation and/or communication equipment decrease situational awareness and increase risk for a commercial air tour. Some inoperative items authorized to be deferred per the MEL may be extremely detrimental to a commercial air tour and may be no go items based on operators’ profile.
7-8 Definitions and Abbreviations
14. Inadvertent Instrument Meteorological Condition (IIMC) Training. IIMC is an emergency procedure, and only pilots trained and current can be expected to succeed. Recently trained pilots have less risk. Pilots that maintain instrument flight rules (IFR) currency are better prepared for unplanned IIMC events and are less risk.
15. Air Traffic Control (ATC). ATC areas with high density of aircraft create a significant workload for the commercial air tour pilot, so areas with higher density than normal traffic will increase the risk.
16. Site-Specific Area Information. Multiple aircraft in one area could increase the risk levels.
Appendix A A-1 APPENDIX A. INADVERTENT INSTRUMENT METEOROLOGICAL CONDITIONS (IIMC) A.1 Encountering IIMCs should be avoided and considered an emergency. It is far better to practice weather avoidance and employ appropriate maneuvers in instrument conditions to escape a potential IIMCs encounter than to risk entering instrument weather conditions unprepared. Aircraft encountering IIMCs, especially those not equipped for continuous IMC and operated by ill-prepared pilots, may subject the pilot to an unacceptable level of stress and could lead to a fatal outcome.
A.2 Helicopter pilots that encounter IIMCs may experience physiological illusions which can lead to spatial disorientation and loss of aircraft control. Even with some instrument training, many helicopters are not equipped with the proper augmented safety systems or autopilots, which could significantly aid in controlling the helicopter during an IIMC emergency.
A.3 Here are some fundamental guidelines to help a pilot remain in visual meteorological conditions (VMC) throughout a flight:
1. Turn Around: If threatened by deteriorating visual cues, slowly turn around and proceed back to VMC or to the first safe landing area if the weather ahead becomes questionable. Prevention is paramount.
2. Terrain Visibility: Do not proceed further on a course if the terrain ahead is not clearly discernible.
3. Flight Consideration: Delay or consider cancelling the flight if weather conditions are already questionable, could significantly deteriorate based on forecasts, or if there is uncertainty about conducting the flight safely. Trust your instincts, as a gut feeling may signal unreasonable risks.
4. Identify Safe Landing Areas: Always have previously identified safe landing areas (such as large open areas or airports) in mind for every route of flight.
A.4 In the event of IIMCs, there are five basic steps that every pilot should be familiar with and execute immediately, if applicable. However, it is crucial to note that if you are not trained to execute these maneuvers solely by reference to instruments or if your aircraft is not equipped with such instruments, this guidance may be less beneficial, and loss of helicopter control may occur:
1. Level the “Wings”: Level the bank angle using the attitude indicator.
2. Attitude: Set a climb attitude that achieves a safe climb speed appropriate to your type of helicopter. Typically, this involves no more than a 10° pitchup on the attitude indicator.
3. Airspeed: Verify that the selected attitude has achieved the desired airspeed. It is critical to recognize that slower airspeeds, closer to effective translational lift, may require large control inputs and will decrease stability, making recovery impossible while in IMC.
Appendix A A-2
4.
Power: Adjust to a climb power setting relative to the desired airspeed. This should be executed concurrently with steps 2 and 3.
5.
Heading and Trim: Select a heading known to be free of obstacles and maintain it.
This is likely the heading you were already on, which was planned and briefed. Set the heading bug, if installed, to avoid overcontrolling your bank. Maintain coordinated flight to prevent the development of an unusual attitude.
Appendix B APPENDIX B. DIAGRAMS AND EXAMPLES Figure B-1. Flight Monitoring Procedures Flowchart Normal Tour Other Tour Non-Tour Flight (Not Scheduled Stop) (Scheduled Stop Tour) (Charter, Ferry, Training, etc.)
Upon Takeoff:
PIC:
• Radios in on operator radio frequency xxx.x and informs OCS of takeoff time.
• GPS tracker ON and operational (if applicable).
OCS Flight Follower:
• Monitors xxx.x for pilot's reported takeoff time and repeats back to pilot to ensure accuracy.
• Logs takeoff time in online reservation manifest.
• Observes GPS tracker information (if applicable).
Is the flight away from base (i.e., inter-island) or not returning?
No Yes Upon Departure from Other Tour Stop Upon Takeoff PIC: PIC:
• Informs OCS/flight follower of departure time • Activates FAA Flight Plan via FSS/FAA flight from LZ via cellphone call to office (no radio following signal in the area. • GPS tracker ON.
• GPS tracker ON and operational (if applicable). Calls AFFS OCS with off time.
OCS Flight Follower:
• Notes LZ departure time on online reservation manifest and observes GPS tracker (if applicable). Upon Completion of the Flight PIC:
• Calls or radios in to FSS to let them know the flight has been completed safely.
• Calls EFFC OCS with down time.
10 Minutes Prior to ETA • GPS tracker OFF.
PIC:
• Radio in on xxx.x and lets OCS know that the aircraft is "10 minutes out" from landing.
OCS:
• Repeats "Copy 10 minutes out" back to pilot via xxx.x.
• Enters ETA (pilot's reported time + 10 mins) into online manifest and observes GPS tracker (if applicable).
B-1