170x Filetype XLS File size 0.21 MB Source: www.fs.fed.us
Sheet 1: System Summary
Application System | Pre Mitigation Hazards | Post Mitigation Hazards | |||||||
Low | Medium | Serious | High | Low | Medium | Serious | High | ||
Aircraft | 1 | 8 | 15 | 24 | 5 | 29 | 10 | 4 | |
Environmental | 0 | 4 | 12 | 27 | 3 | 22 | 17 | 1 | |
Personnel | 0 | 5 | 7 | 32 | 3 | 33 | 7 | 1 | |
Technology | 1 | 8 | 9 | 12 | 3 | 19 | 8 | 0 | |
Total = 165 | 2 | 25 | 43 | 95 | 14 | 103 | 42 | 6 | |
Revision History: created 08, updates: Jan09-Oct10-Nov11-Apr13-Apr15-Sept17-June19 |
System: FHP Aerial Application - Aircraft | ||||||||||||
Pre Mitigation | Mitigation | Post Mitigation | Mitigation Achieved? | Additional Local | Post Mitigation | |||||||
Sub-systems | Hazards | Likelihood | Severity | Outcome | Likelihood | Severity | Outcome | Yes or No | Mitigation | Value | ||
Avionics (for radios see "Technology" tab) | Unplanned avionics failures (overheating, faulty wiring, etc.) | Occasional | Marginal | Medium | Have dual communications in the audio panel, users prepared to use alternate frequencies (guard), have a spare aircraft radio on site/land and repair or replace aircraft | Remote | Marginal | Medium | ||||
Inability to maintain seperation from other aircraft | Occasional | Catastrophic | High | Utilize AFF.gov or other flight following technology including locally hosted systems if not on AFF.gov; utilize TCAS or ADS-B in/out to display other aircraft locations in the cockpit | Remote | Catastrophic | Serious | |||||
Unavailable or dysfunctional emergency locator (analog ELT systems will be discontinued affecting most aircraft; not required for P-137 but may be equipped) | Remote | Marginal | Medium | Ensuire operators have transitioned to 406 MHz digital ELT; specify digital ELT in all contracts; recommend ELTs with real time or satellite flight following functionality if AFF is not used (adhere to Agency or state requirements as appropriate) | Improbable | Negligible | Low | |||||
Aircraft Configuration | Emergency landing difficulty with engine failure < 500' AGL | Remote | Catastrophic | Serious | Select appropriate aircraft based on project profile considering risk factors such as maneuverability, glide distance, emergency landing zone requirements and potential crash footprint | Improbable | Catastrophic | Medium | ||||
Contract may not accurately specify application equipment, pesticide formulation, and rates of application (EPA, NEPA & possibly state violations - env. hazard, double applications, increases in flight and ferry time) | Improbable | Negligible | Low | Biology to dictate prescription and whether single or multiple treatments, specify in project design and in agency and state contracts including nozzle type, rate of application, pesticide formulation, dose, droplet size, swath width, and environmental parameters during application | Improbable | Negligible | Low | |||||
Reduced visibility if aircraft not purpose built for aerial application or if using bi-plane | Remote | Catastrophic | Serious | During contract solicitation the prospectus should specify aircraft designed and built for aerial application (special circumstances may warrant alternative aircraft, such as twin engine if required in congested airspace), conduct reconnaissance for aerial hazards prior to project, practice "see and avoid", recognize bi-wing may not be the best choice for some applications | Improbable | Critical | Medium | |||||
Doors-off/doors-open flight, potential to fall out of helicopter or FOD or unable to egress during emergency | Occasional | Catastrophic | High | Doors-off/doors-open flight is generally not recommended under most circumstances and must be analyzed/approved in PASP; however, doors-off operation is common in spray operations, restricted category and single pilot-only, OEM pilot restraints are not subject to this requirement; if passengers are authorized (e.g. hazard mapping or aerial observation) approved secondary restraint systems must be utilized; FAA Emergency Order 2018-0243 "prohibits the use of supplemental passenger restraint systems that cannot be quickly released in an emergency during flight operations for compensation or hire with doors open or removed"; ref IASA 18-03 and NIAC's 2018 for approved secondary restraint equipment, prior to conducting flight operations provide personnel with hands-on secondary restraint training for missions requiring aircraft doors to be removed prior to flight, or open during flight | Remote | Critical | Medium | |||||
Restraint Systems | Unapproved/inferior lap belt or shoulder harness design, failure due to condition | Occasional | Catastrophic | High | Inspect for approved restraint systems in proper working condition prior to use; describe minimum requirements such as "four-point belt/harness with single point of release" within solicitation | Improbable | Negligible | Low | ||||
Injury from belt/harness, impact from objects within the cockpit, intrusions into survivable space | Occasional | Catastrophic | High | Properly fit restraint system during flight, stow or secure loose items, use aircraft equipped with airbags; NTSB has made recommendations to FAA for airbags in GA aircraft, currently nonbinding; some agricultural aircraft manufacturers have adopted harness airbags as standard equipment and kits are available as retrofit for older aircraft | Occasional | Marginal | Medium | |||||
Terrorist or malicious activity | Aggressive public, verbal or physical threats to do harm (including gun threats) | Occasional | Catastrophic | High | Conduct effective outreach to educate the public, gain understanding and trust to prevent surprises; also during outreach, contact emergency services (911) and state police to notify of operations and provide a copy of the project plan; assign a government Public Information Officer and defer communications with the press to the PIO; treat all threats as serious, know and brief on procedures, have emergency contact information handy, notify base of operations and pilots; obtain all physical description info possible without placing self at risk (name, address, description of person, vehicle and license plate), follow up IMMEDIATELY with state law enforcement and demand serious action! | Improbable | Critical | Medium | ||||
Remote, unsecured work areas and service landings (risk to containment, aircraft, personnel… theft or damage to aircraft/equipment… threat to public safety) | Remote | Catastrophic | Serious | Adhere to Project Aviation Safety and Security Plans, gov't and contract personnel both have responsibilities to ensure security and respond accordingly. Familiarize with new National Terrorism Advisory System, subscribe to e-alerts, address in security plans. Have emergency contacts and special needs information with you at all times. Contract to address 24-hr security in remote locations, reference local Unit Aviation Plan (on all agency and state contracts, security plan required for both insecticide & aircraft/support equipment). Recommend that aircraft have lock/key access to the aircraft cockpit and at least two of the following: Ignition disabling device (key operated), Propeller lock/key, Keyed magneto, starter switch, or master power switch, Hidden battery cutoff switches or start relay switches, Throttle/power or mixture/fuel lever lock, Locking fuel cutoff, Locking tie down cable, Propeller lock, chain lock, or cable lock, Locking wheel lock or chock, Locking “club” type devices for control yoke | Remote | Critical | Medium | |||||
Performance Standards- Fixed Wing | Insufficient planning considering project needs and aircraft capabilities (mission profile, horsepower, etc.) | Improbable | Catastrophic | Medium | Contract to address minimum requirements: Observation Aircraft capable of transporting a minimum payload of 530 pounds on a standard day at sea level and Power loading not greater than 13.5 pounds, (aircraft with a power loading greater than 13.5 pounds per horsepower (PPH) must be turbo-charged), if multi-engine aircraft are used they shall have 240-horsepower per engine, or more, unless turbo-charged, Application Aircraft must be Turbine engine powered (special circumstances may dictate alternate aircraft, such as congested airspace requirements) | Improbable | Critical | Medium | ||||
Overloading aircraft (near or exceeding gross) | Remote | Catastrophic | Serious | Perform load calculations including weight of pesticide formulation, fuel, pilot and spray equipment; BE AWARE that FAA does occasionally certify restricted category aircraft to operate over GW, know conditions of certification and brief regarding operational limitations and concerns; consider distance to treatment area/fuel burn, download for pilots with minimal experience and/or to optimize performance | Improbable | Catastrophic | Medium | |||||
High density altitude operations | Remote | Catastrophic | Serious | Match machine to task & environment, monitor weather, reduce load | Improbable | Catastrophic | Medium | |||||
Possibility of fixed wing operating near stall speeds in downwind turns/operations in general | Frequent | Catastrophic | High | Brief on heavy load, wind direction & speed/downwind leg, minimize "high G" turns (adhere to operational limitiations for make and model) and pay attention to winds | Occasional | Catastrophic | High | |||||
Performance Standards - helicopter | Hover out of ground effect (HOGE), increased likelihood if using observation helicopter | Remote | Catastrophic | Serious | Maintain forward airspeed, utilize higher performance aircraft… OR to eliminate need for additional aircraft/personnel, consider other monitoring techniques in contract (e.g. real-time AFF subscription) | Improbable | Catastrophic | Medium | ||||
Overloading aircraft (near or exceeding gross) | Occasional | Catastrophic | High | Perform load calculations including weight of pesticide formulation, fuel, pilot and spray equipment; BE AWARE that FAA does occasionally certify restricted category aircraft to operate over GW, know conditions of certification and brief regarding operational limitations and concerns; consider distance to treatment area/fuel burn, download for pilots with minimal experience and/or to optimize performance | Remote | Catastrophic | Serious | |||||
Propensity for spray aircraft to operate within or near height-velocity curve, increased likelihood if hovering an observation helicopter | Remote | Catastrophic | High | Minimize exposure to the HV curve, maintain forward airspeed (at least 20 knots will mitigate HV curve in many circumstances); utilize performance aircraft, maintain adequate height above canopy… note successful autorotation is aircraft/airspeed & AGL-dependent (brief capabilities with pilot); to eliminate need for additional aircraft/personnel in observation aircraft, consider other monitoring techniques in contract (e.g. real-time AFF subscription) | Improbable | Catastrophic | Medium | |||||
Atypical mission parameters such as those prescribed under a "special study" (e.g. slower than normal airspeed, lower height above canopy, "pushing" spray material through canopy using rotor wash) | Probable | Catastrophic | High | Thoroughly brief, use only very experienced pilots, maintain forward airspeed, avoid settling with power in downwind situations/avoid downwind operations, a minimum of 50 mph is preferred/anything less than is a significant "watch out!" | Occasional | Catastrophic | High | |||||
Inspection & Maintenance | Existence of corrosion/fracture in aircraft components due to weights and chemical exposure (e.g.. Skids, landing gear, wing struts/attach fittings) | Remote | Catastrophic | Serious | Partially mitigated by annual inspections per FAA part 91, consider increasing contractual requirement to 100hr inspections (as in part 135), use purpose built aircraft, utilize "carding" procedures, comply with all ADs and SBs as necessary | Improbable | Catastrophic | Medium | ||||
Engine malfunction due to unforeseen failure or insufficient maintenance | Occasional | Catastrophic | High | Utilize electronic engine monitoring technology to simplify cockpit workload, provide in-flight alerts of critical exceedance, download data card with performance history (aids analysis for scheduled or unscheduled maintenance needs); adhere to FAA requirements and manufacturer specs, stay current on ADs and SBs, consider internet subscription for easy access to daily updates such as through the AD Resource System (or other) also providing maintenance-related ACs and STCs | Remote | Marginal | Medium | |||||
Currently some states have no aircraft and pilot inspection procedures. | Probable | Catastrophic | High | Agency will assist in the development and suggest use of an aircraft and pilot check list. The Agency will provide training to state program managers. Even though aircraft will be inspected by state program managers, agency personnel will not be permitted to board application and observation aircraft unless carded per part 135. | Occasional | Catastrophic | High | |||||
Aircraft not design/built for the specific mission profile (i.e. low-level, mountainous terrain, high cycle flight) on agency and state contracts. | Remote | Catastrophic | Serious | Require and implement a Structural Health Monitoring Program approved by the aircraft’s manufacturer. Provide copy of program to the CO and agency aviation inspectors. | Remote | Marginal | Medium | |||||
Aging aircraft and/or not identifying inspecting critical stress points (aerial application aircraft subject to multiple cycles and maximizing payloads) | Remote | Catastrophic | Serious | Require and implement a Structural Health Monitoring Program approved by the aircraft’s manufacturer. Provide copy of program to the CO and agency aviation inspectors. | Remote | Marginal | Medium | |||||
Corrosion/fracture of spray tanks, delivery components leading to leakage, parts detaching | Remote | Critical | Medium | Develop monitoring program for spray operations, critical aircraft components and delivery system; keep dispersal systems and surfaces clean; utilize bypass valve system to return unused chemical to tanks; custom modifications may include stainless, corrosion-resistant tank tray to direct any leakage out of aircraft | Remote | Marginal | Medium | |||||
Insufficient daily cleaning of aircraft to reduce corrosion (all aircraft) | Remote | Critical | Medium | Require in Agency and state contracts that all equipment which comes in direct contact with the pesticides be kept thoroughly clean and free of residues and foreign particulate matter; ensure adequate preflight/postflight inspection, utilize non-corrosive materials, provide for containment of residue in contract | Improbable | Marginal | Medium | |||||
Insufficient cleaning of tanks and delivery components between projects, when changing chemicals (env. hazard) | Remote | Critical | Medium | Require in Agency and state contracts that all tanks and pesticide delivery systems be thoroughly cleaned and free of rust, residues and particulate matter such as grit and sand; inspect all tanks before they are filled with insecticide or water; systems may be uniquely designed and approved for very specific materials (dry, flake or splat) or more generally constructed and applicable for a broad range of ag/forestry uses (dry or liquid), engineer and/or utilize approved dispersal systems for the material to be applied (e.g. flake, splat, liquid) | Improbable | Marginal | Medium | |||||
Unapproved modifications to equipment or unapproved equipment | Remote | Catastrophic | Serious | Both agency and state contracts require a supplemental Type Certificate (STC) or FAA field approval for modified equipment (e.g. pheromone flake pods) | Improbable | Catastrophic | Medium | |||||
Contract Aircraft (common to both State and Federal operations = mix of fixed and rotor wing, CWN, EP or Exc Use) | Minimally skilled pilots | Remote | Catastrophic | Serious | Establish minimum experience contract requirements proven to reduce risk (ref. FSH 5709.16 11.22 standards, AASC contract template and accident rate vs. pilot hours studies) accident rates in ag operations improve dramatically after approx. 1000 hrs total, make another fairly significant drop after 2,500 hrs total, less significant reductions at increments thereafter); acknowledge experience is not the only factor and after a point, other factors may negatively effect even experienced contract pilots; evaluate continuing education and training programs (such as PAASS) and past performance documentation with bid | Improbable | Negligible | Low | ||||
Using incorrect aircraft type for terrain (fixed vs. rotor wing) | Occasional | Catastrophic | High | Project planning shall determine the type of aircraft required, contracts may specify when important to do so. Establish parameters for acceptable a/c type (e.g. ferry distance, block size and distribution, heavily to minimally dissected terrain) use pilot experience and smaller loads to help mitigate risk in challenging terrain | Remote | Catastrophic | Serious | |||||
Incentive to maximize flight time, regardless if paid by acre treated or hours flown | Remote | Catastrophic | Serious | Flight Managers & Project Supervisor need to be involved in flight hour/duty day monitoring for accomplishment, efficiency and safety; record start/stop times for all aircraft loads, suggest flight duty limitations similar to agency - the only mechanism to specify is through the state or federal contract. | Improbable | Negligible | Low | |||||
Operations in densely populated/high air traffic areas | Probable | Critical | High | Contractors must file Congested Area Plans with FAA. Contractors must adhere to FAA requirements (i.e. some FAA offices may require rotor only, others may allow fixed wing operations). Obtain and familiarize with manufacturer's glide data. Simulate feather/dump/turn and glide sequence for proficiency and recording GPS file to document and aid Plan approval. | Probable | Marginal | Serious | |||||
Last-minute contract changes, dropping portions of blocks increases risk to public and operational safety | Occasional | Catastrophic | High | Leave the block as it was proposed and planned, flight pattern and where turns are made are affected with dropped areas/modified boundaries; do not edit day before operations for omissions | Remote | Catastrophic | Serious | |||||
There are no maintenance requirements 'per se' for aircraft operating under FAA part 137, only the minimum requirements per FAA part 91 (annual inspection) | Probable | Catastrophic | High | Consider contract requirements to include 100-hour inspection; establish TBO or TBO extension program through FAA; NOTE 100-hour inspection is required for approval of congested area plans (P-137.53 C 1) | Occasional | Catastrophic | High | |||||
Potential for reduced reliability of reciprocating engines compared to turbine-powered aircraft | Occasional | Critical | Serious | Consider requiring turbine-powered application aircraft in contracts; chase aircraft need not be turbine (Note: by design turbine-powered aircraft tend to have more power and are more reliable, but does not always guarantee better performance) | Remote | Critical | Medium | |||||
Too many or too few aircraft for production needs/project area, unsuitable spray platform for mission profile | Remote | Catastrophic | Serious | Project planning shall determine and contracts specify quantity & type of aircraft needed to complete the project. For example number of a/c or production rates (ac/hr) may be specified in contracts; operating period is specified; ensure operator maximizes efficiency and has suitable support (skilled ground and pilot staff, adequate parts for common repair needs, approved alternate aircraft). In cases where planning is unable to determine (i.e., county coordinators may not be certain of needs), specify two choices in the contract or utilize RFP and review procedures to determine acceptability; adhere to prescription window and duty limits, avoid transferring risk to other system components/users, appropriately pace operations and brief on changes, decline use of any aircraft determined to be unsuitable | Remote | Critical | Medium | |||||
No pre-application survey of area prior to project for aerial hazards | Occasional | Catastrophic | High | Contract requirement that all application pilots are responsible for the reconnaissance of each area before treatment; if used, observation aircraft to also recon prior to and during treatment, reminding application pilots of hazards each time they re-enter block with a load; block monitors to relay any new hazards as they develop | Improbable | Catastrophic | Medium | |||||
Cooperating Aircraft hazards unique in state ops, typically outside of agency operational control (sometimes using mix of fixed and rotor wing) | Some states do not meet highest safety standards such as required for Agency operations, there may not be a carding system in place | Probable | Catastrophic | High | Agency will assist in the development of an aircraft and pilot check list. The agency will provide training to state program managers. Agency personnel will not be permitted to board application and observation aircraft. State contracts should require similar carding procedures. Maintain situational awareness. | Remote | Catastrophic | Serious | ||||
No flight hour/duty day limitation in state contract (hazard to the operation and other aircraft in proximity) | Frequent | Catastrophic | High | Establish duty limits for mechanics, truck drivers and pilots similar to those specified in Agency prospectus and contract. Project Supervisor need to be involved in flight hour/duty day monitoring. Provide training and maintain situational awareness. | Remote | Catastrophic | Serious | |||||
Exhaust gas in cockpit | Carbon monoxide poisoning | Occasional | Catastrophic | High | CO is oderless and tastless, install CO detector in cockpit (if not using purpose-built aircraft); be aware of early symptoms of CO poisoning (light-headedness, confusion, headaches, vertigo, and flu-like effects), provide ventilation and/or O2, land until symptoms go away, identify and correct the problem before returning to availability; NOTE purpose-built aircraft are tested as manufactured and do not fly with doors off, all have some kind of scoop to keep the cockpit slightly pressurized to prevent exhaust gas from entering even if a seal fails. | Improbable | Critical | Medium | ||||
Fuel | Starvation | Occasional | Catastrophic | High | Monitor quantity pumped during fueling, monitor flight time and distance to services, calculate loads after accomodating ferry and fuel reserve; an example with two levels of varification to assure adequate fueling: 1) meter is installed on the fueling hose, results of which are given to the pilot when fueling is complete and a fuel totalizer is installed in cockpit and the pilot compares the two figures, 2) Second verification through the single point fuelding system which indicates when a tank has been filled to the selected level. | Remote | Critical | Medium | ||||
Hot Loading (Fuel and Chemical), potential spill and/or fire | Occasional | Catastrophic | High | Operators who conduct hot fueling/loading should develop standard operating procedures (SOP) for flight and ground crew personnel; hot loading chemical risks include moving parts/fueling adds fire hazard, spec PPE for loading in plans and contracts, include spill procedures in spill plan and/or contract; Hot fueling/loading can be extremely hazardous and is not recommended except when absolutely necessary due to the nature of the operation, ensure hot loading Jet A fuel is consistent with FSM/FSH and IHOG and recommendations in FAA SAFO 10020 | Remote | Critical | Serious | |||||
Helicopter fuel tank rupture during mishap, increased chance of post-crash fire | Occasional | Catastrophic | High | Utilize crash resistant fuel systems (CRFS); reference Special Airworthiness Information Bulletin SW-17-31R1 Dec 2018 which states "Non-CRFS compliant helicopters do not warrant airworthiness directive (AD) action under 14 CFR part 39. However, operating a helicopter with either a full CRFS or a partial CRFS reduces the risk of post-crash fires and improves occupant survivability in an accident." | Improbable | Catastrophic | Medium | |||||
Turbine engines - filter monitor media migration, failed starts, loss of thrust control, and other engine anomolies | Probable | Catastrophic | High | Super-absorbent Polymer (SAP) in aviation fuel is designed to absorb water before it enters aircraft, this media can be released downstream and contaminate fuel if not properly filtered; the filter specification by Energy Institute (EI) will no longer be maintained effective 12/31/2020 (see IA APB 19-01). The majority of the aviation fuel filtration used in DOI/FS aviation operations is AQUA-Con or Fuel Gard media. Both contain SAP which is qualified to EI 1583 contamination removal specifications. With the demise of the specification, the manufacture and distribution of these filters will most likely disappear. The flow rate reduction safety net, an indicator of the presence of water, currently enjoyed by users of this media will also disappear. In the absence of a new media containing the flow reduction characteristic, a renewed emphasis must be made in the areas of filter vessel sump draining and differential pressure readings. No longer will operators be able to solely rely on flow reduction as an indicator of the presence of water. Sump draining sample results and differential pressures should be recorded and retained for trend analysis. Fueling facilities currently using Fuel Gard/AQUA-Con media should inspect and clean nozzle screens in accordance with Shell Global Solutions procedure SR.17.01641. The Shell procedure is intended to remove SAP from nozzle strainers. After completing the cleaning procedures, visually inspect the nozzle screen to ensure there is no sign of damage or residual debris from the flushing process or cleaning procedure. Re-install the nozzle screen into the aircraft refueling nozzle following manufacturer’s instructions. | Improbable | Catastrophic | Medium | |||||
Bad fuel (more likely in portable fuel systems) | Remote | Critical | Medium | Ensure fuel is tested for type and quality prior to fueling. Monitor quantity pumped. Ensure fuel filters are changed as required by manufacturer. | Improbable | Critical | Medium | |||||
Foreign Aircraft | Not carded/inspected for use in other country (e.g., US in Canada, Canada in US) | Remote | Critical | Medium | Use in foreign territory not authorized and illegal | Improbable | Marginal | Medium | ||||
Availability | Sense of urgency & pressure to perform (pilot, manager, organization) | Occasional | Catastrophic | High | Involve Supervisor, Program Manager & Flight Manager in all stages of planning and risk assessment; Program Managers/CORs shall not tolerate performance pressure at the expense of safety considerations, establish and maintain good communications throughout! | Remote | Catastrophic | Serious | ||||
Tendency to over utilize single vendor/pilot & maximize flight hours due to limited availability of other aircraft | Remote | Catastrophic | Serious | Flight Managers & Program Manager need to be involved in flight hour/duty day monitoring. Adhere to contract specifications regarding flight hour/duty limitations. Providing more than the minimum number of aircraft and pilots needed for a project helps reduce workload and likelihood of pushing hours; brief pilot time daily for all project pilots to manage loads and remain within limits. | Improbable | Catastrophic | Serious |
System: FHP Aerial Application - Environmental | |||||||||||
Pre Mitigation | Mitigation | Post Mitigation | Mitigation Achieved? | Additional Local | Post Mitigation | ||||||
Sub-systems | Likelihood | Severity | Outcome | Likelihood | Severity | Outcome | Yes or No | Mitigation | Value | ||
Weather/Time of Day | High wind, high temperatures, low humidity (effect on pesticide drift) | Frequent | Marginal | Serious | Contract specifies thresholds for allowable winds, temperature & relative humidity, cease operations when drift conditions exist | Occasional | Marginal | Medium | |||
High wind, low humidity, high temperatures (effect on aircraft performance) | Frequent | Catastrophic | High | Contract specifies performance requirements, conduct load calculations/weight & balance; cease operations when conditions out of parameter | Remote | Catastrophic | Serious | ||||
Thunderstorms, lightning, hail, high winds | Occasional | Catastrophic | High | Suggest pilots utilize on-board, real-time weather program (such as XM weather on Garmin-type GPS); program managers monitor weather stations provided at airport office, use observation aircraft to help monitor weather conditions | Remote | Catastrophic | Serious | ||||
Typically operations are planned for morning & in shadows/glare conditions | Frequent | Catastrophic | High | Preflight briefing to raise awareness; orient swaths perpendicular to sun angle when possible | Probable | Catastrophic | High | ||||
Afternoon or evening operations causing undue pressure to complete, increased likelihood of exceeding duty limits and pushing civil daylight | Occasional | Catastrophic | High | Do not allow yourself to be pressured; operating morning and evening shifts makes for extremely long days for everyone involved, a long list of hazards are mitigated by simply avoiding afternoon or evening operations | Improbable | Catastrophic | Medium | ||||
Topography/Hi Alt | Turbulence | Frequent | Critical | High | Brief on terrain and wind effects, adhere to wind speed/gust speed limitations in contract and cease operations if unsafe/out of parameter | Remote | Critical | Medium | |||
Treatment block and flight line orientation regardless of aircraft configuration, contributing to inefficient or unsafe profile | Occasional | Catastrophic | High | Sufficiently plan projects and aircraft based on number of and distribution of blocks, block size, and orientation of flight lines; optimize efficiency and safety wherever possible to select correct aircraft and orient flight lines lengthwise/minimizing turns and potential to operate in HV curve (rotor), factor wind direction and any aerial hazards into the plan and adjust as conditions change; implement FOQA program/utilize aircraft monitoring devices to study roll/pitch/yaw/environmental factors experienced in aerial application, inform program efficiencies and safety over time | Improbable | Catastrophic | Medium | ||||
Terrain - box canyons | Occasional | Catastrophic | High | Plan project/treatment block such that application flight lines allow egress; brief pilot | Remote | Critical | Medium | ||||
High Altitude - density altitude | Occasional | Catastrophic | High | Perform load calculations for departure and destination | Remote | Critical | Medium | ||||
Remote Areas or Poor Road Access | Lack of communications | Probable | Catastrophic | High | Test air-air/air-ground/ground-ground radio communications prior to project implementation and throughout project prior to loads leaving ground; test cell coverage for ground personnel; utilize temporary communications tower or oberservation aircraft as downlink when necessary for communications with spray aircraft or ground personnel in areas of poor radio or cell coverage | Remote | Catastrophic | Serious | |||
Long response time in event of search and rescue | Occasional | Catastrophic | High | Mishap Response Plan to address search and rescue procedures, observation aircraft may be used to assist guiding rescue vehicles/personnel to accident site; utilize real-time AFF systems | Remote | Catastrophic | Serious | ||||
Fuel starvation, proper fuel unavailable | Remote | Catastrophic | Serious | Monitor flight time/fuel consumption, utilize fuel trucks or have optional fuel sources pre-identified and confirmed ahead of time. Utilize reliable sources, have dedicated fuel truck if feasible and sample aircraft fuel during preflight. Utilize aircraft with single point fueling design help ensure proper amounts are loaded, and use of a fuel flow/totalizer to maintain accurate awareness of fuel remaining in both flight time and quantity. Check agreement between load meter and pilot's on-board meter prior to take off. Standard flight following procedures also include confirming fuel on board following take off. | Improbable | Critical | Medium | ||||
Unimproved landing strips or helipads with poor dust abatement and/or poor surface condition | Remote | Marginal | Medium | Contractor required to locate and inspect all landing zones prior to project implementation, secure written permission if on private property; for fixed-wing operations, contractor must obtain permission from airport manager, airstrips must be accessible to vehicles, therefore mostly utilizing developed airports (may use unimproved landing strip only in event of emergency); for rotor wing operations water is available for dust abatement if needed | Improbable | Marginal | Medium | ||||
Biological Window | Prioritizing treatment based on pest phenology over safety (must treat within window) | Occasional | Catastrophic | High | Contract specifications include adequate number of aircraft to accomplish mission within biological window, monitor time and brief daily emphasizing safety over production, pilots manage loads to adhere to flight and duty limitations; more than the minimum number of aircraft and pilots necessary to achieve stated production rate helps reduce pressure. | Remote | Critical | Medium | |||
Airspace - General | Working within Military Operating Area, potential mid-air collision | Probable | Catastrophic | High | Contact flight service station or ATC to determine if active and, if so, may request traffic advisories from the controlling agency prior to entry; address during premission planning and briefing. | Remote | Catastrophic | Serious | |||
Working within or proximity to Military Training Route, potential mid-air collision | Probable | Catastrophic | High | Address during permission planning and briefing; keep alert (application aircraft and observation aircraft); contact flight service station to determine if active and, if so, request times of scheduled activity, altitudes in use, actual route width (route may extend several miles beyond shown center line); not all MTRs are published on sectionals. Obtain copy of AP1B for phone numbers to military installations and contact schedulers to deconflict MTR; project manager post NOTAM for military to review during their daily briefing. | Remote | Catastrophic | Serious | ||||
Unable to establish TFR for applications projects | Probable | Catastrophic | High | Post applications projects as NOTAM, remain aware of potential for other aircraft to enter project area; block monitors, observation aircraft and spray pilots communicate presence of non-project aircraft immediately. | Remote | Catastrophic | Serious | ||||
Military training operations distracting application aircraft | Occasional | Catastrophic | High | COR/Project Manager & National Airspace Coordinator to communicate "training" problem to military, describe distraction to application operations and risk (Air Force & Navy have contact points, also a primary single contact "Airspace Manager" for all branches). | Remote | Catastrophic | Serious | ||||
Inability to post NOTAMs due to: FAA office closures, difficulty identifying contact point, FAA refusal to file for aerial application activities | Occasional | Catastrophic | High | Go to www.faa.gov to identify contact and follow procedures for filing NOTAMs, post aerial application NOTAM within 3 days of project (also retrieve NOTAMs for your area www.faa.gov/regulations_policies/notices_airmen/); call 1-800-WX-BRIEF, request to be transferred to the NOTAM Desk, inform them that 1) you are the responsible party, 2) give your phone number and that of your communications base, 3) give operational details (location, date/timing, duration of work); problems in filing should be elevated to your safety manager and FAA superiors | Remote | Catastrophic | Serious | ||||
Risk of mid-air due to not checking NOTAMs or not filing them (as appropriate, mission-dependent) | Occasional | Catastrophic | High | Check NOTAMs prior to aerial application https://www.notams.faa.gov/; filing NOTAMs for normal spray operations is not practical, utilize ATC flight following in congested airspace and in accordance with FAA policy and make contact with ATC when operating in proximity to controlled airspace; Familiarize with NOTAM types: FDC NOTAMS are for disaster and event TFRs, NOTAM-L for military use only, NOTAM-D for projects; INFO ONLY: we may use NOTAM-D for any project that may affect the local airspace, these should be requested by the local dispatch center if desired/states may go through their local FSDO | Remote | Catastrophic | Serious | ||||
Working in proximity to/or within FTA or TFR | Remote | Catastrophic | Serious | Typically avoid; however, Project Manager may request permission to work within FTA or TFR if possible and absolutely necessary, coordination between dispatch, application pilot, and aerial supervision is required; ability to "XM download" to on board GPS will help with TFRs. | Remote | Critical | Medium | ||||
Restricted Areas (artillery firing, guided missiles or aerial gunnery) | Remote | Catastrophic | Serious | Typically avoid; however, if necessary permission to enter may be coordinated through ATC; know intercept procedures, reference in contracts/prework and include in daily briefings. | Remote | Critical | Medium | ||||
Prohibited Areas (e.g.. lack of coordination prior to entering Camp David, White House, Presidential Ranch…) | Remote | Catastrophic | Serious | For all intents and purposes "permanently off limits", typically avoid; however, applications projects are sometimes prescribed within PAs; if necessary, permission to enter may be coordinated through ATC, DOD, Secret Service. Example: procedure for P-40 (Camp David) Project Manager contacts Park Service, Park Service contacts Secret Service; at minimum prebrief by Project Manager includes Secret Service to establish agreed flight plan/flight lines, pilot must strictly adhere to plan; know intercept procedures, reference in contracts/prework and include in daily briefings. | Remote | Critical | Medium | ||||
Mid-air collision while working within or crossing Class B, C, D Airspace | Remote | Catastrophic | Serious | Observation and application aircraft remain aware of other traffic, pilot request clearance, maintain communication with ATC or tower as required; utilize dual communications to ensure comms with local airports and project personnel/aircraft; utilize experienced pilots particularly in complex airspace. | Remote | Catastrophic | Serious | ||||
Airspace in general - near miss/collision in congested areas | Occasional | Catastrophic | High | Communicate with & utilize observation aircraft, ATC, etc., see and avoid, consider TCAS to warn of transponding aircraft in proximity to application aircraft; contact FSDO for requirements to submit a congested airspace plan over urban areas and/or in controlled airspace | Remote | Catastrophic | Serious | ||||
Airspace - UAS Activity | Increasing activity of Unmanned Aircraft Systems (UAS) | Probable | Catastrophic | High | Post and check NOTAMS, UAS are becoming more common and will continue, these aircraft operate at all altitudes and may be frequently encountered in the aerial application environment, utilize the USFS UAS Advisory group for two-way communications regarding spray and UAS activities and plans | Remote | Catastrophic | Serious | |||
Increased UAS activity among private, other government and public operators (potential airspace conflicts) | Frequent | Catastrophic | High | Notify dispatch, local airports and other government entities of UAS missions under our operational control, identify potential for UAS activity which may occur at any operational altitude in any airspace, UAS may be small or large; file or check DROTAMs www.skyvector.com and NOTAMs https://www.notams.faa.gov/ but recognize not all activity will be posted (e.g. hobby operation will not be known, commercial and other government operations may be under COA not necessarily following typical FAA protocol), practice see and avoid; participate in aviation-related meetings with academia, other government, industry and public to ensure mutual understanding of all aviation operations and maintain communication to mitigate risk of airspace conflicts. (Reference UAS Program Risk Assessment) | Remote | Catastrophic | Serious | ||||
Public and other entities operating drones are unaware of our manned operations (possible mid air) | Occasional | Catastrophic | High | "Unmanned Aircraft System (UAS) Communication Materials" have been developed through the UAS-AG, distributed to UAOs/AASC and made available at https://www.nifc.gov/PIO_bb/fs.html; there are four templates to use depending on the notification desired: 1) 1USFS - contact the FS unit where they want to operate drones, 2) 1generic - contact the FS and/or partnering land manager or property owner where they want to operate drones, 3) 2USFS - not fly the FS unit (on specific dates and mission type we indicate and describe), 4) 2generic - not fly over partner lands and/or all lands (on specific dates and mission type cooperator or FS indicates and describes) INFO ONLY: the NIFC link is temporarily unavailable, documents are being revisited to ensure what was once considered potentially sensitive operational details can be included |
Remote | Catastrophic | Serious | ||||
Public and other entities operating drones disregard notifications and TFRs regarding our manned operations (possible mid air) | Occasional | Catastrophic | High | Implement drone denial system to protect manned operations involving emergency response, fire suppression, forest health and resource management, and many other activities; technology is available to jam drones up to 1 km away, line of site is required. INFO ONLY AT THIS TIME, THIS MITIGATION IS NOT FULLY MATURE NOR APPROVED | Improbable | Catastrophic | Serious | ||||
Unaware of other Agency-approved UAS operations during manned our operations areas (potential airspace conflicts) | Remote | Catastrophic | Serious | Agency drone operations utilize UAS Mission Tracking Database to input and request use of UAS; the database also tracks UAS mission progress, location and completion; review prior to manned operations for projects that may be in your area (NOTE the database is not live yet, notify field and partners when on line) | Improbable | Catastrophic | Medium | ||||
Agency UAS operating procedures are immature, final guides and policy are not fully developed and in process; risk of unqualified or unapproved operation, incomplete contracts, unauthorized cooperation or procurement leading to UAS or manned aircraft mishap | Probable | Catastrophic | High | Treat UAS as manned aircraft in terms of pilot and airworthiness requirements (UAS are aircraft), adhere to current policy for procurement, contracting and cooperating. Follow established procedures for agency mission requests, RAO approval, FAA Certificate of Authorization. Ensure operation is cost-effective and justified. Check DROTAMs and NOTAMs prior to operation. Address unique UAS hazards and likelihood of encountering other aircraft within/adjacent to project areas in PASP, ensure notification of planned Agency operations and communicate encounters with non-Agency aircraft. (Reference UAS Program Risk Assessment and UAS Desk Guide) | Remote | Catastrophic | Serious | ||||
Airstrip Availability, Condition and Services | No alternative or suitable landing location for emergency situations | Probable | Catastrophic | High | Identify emergency landing zones in advance (fields, open areas, meadows), indicate LZs on image maps/photos such as Google Earth and provide to pilots. | Remote | Critical | Medium | |||
No alternative fuel source | Occasional | Marginal | Medium | Call FBO/airport ahead of time to determine fuel availability, use alternate airport or fuel tender. | Remote | Critical | Medium | ||||
One-way landing/departure | Probable | Marginal | Serious | Be aware that preferred approach/departure based on wind may not be an option, be aware of the potential for oncoming air traffic. | Probable | Negligible | Medium | ||||
Primitive LZs or airstrips | Probable | Critical | High | Mitigate primitive locations as indicated elsewhere within this subsystem or utilize developed public-use airports with hard surface and existing safety features (lighting, security, wind sock, reliable fuel, etc.). | Remote | Negligible | Low | ||||
No windsock at landing zones | Frequent | Marginal | Serious | Use vegetation (grass, tree tops) as reference; if available, ground support can call pilot with conditions prior to landing, hang flagging. | Remote | Marginal | Medium | ||||
Effects of prevailing wind | Frequent | Marginal | Serious | Know local conditions, retrieve automated weather, make GPS-enabled AWOS Wx data available in cockpit | Frequent | Negligible | Medium | ||||
Terrain/Obstructions | Operations below 500' in either helicopter or fixed-wing, potential to impact terrain or obstruction - aerial application typically 50-200 feet above tree tops | Frequent | Catastrophic | High | Contract specifications require FAA part 137-qualified pilots. Maintain situational awareness, identify emergency landing zones (fields, open areas, meadows); preflight briefing, review aerial hazard map, also specify preflying the block in the contract for hazard reconnaissance prior to treatment. | Remote | Critical | Medium | |||
Noise | Hearing loss due inadequate protection from aircraft noise | Probable | Critical | High | Provide Hearing Conservation Plan for "noise hazardous occupations"; collect baseline data for all crew and provide annual testing to ensure users are not experiencing significant hearing loss due to on-the-job noise exposure (reference FSH 6709.12, CH 23); utilize hearing protection on the ground and noise reduction headsets in aircraft that drastically reduce decibel levels to which crews are exposed. | Remote | Marginal | Medium | |||
Animal activity | Potential for serious injury/aircraft damage from birds | Occasional | Critical | Serious | Know flyways, observation aircraft and ground support to communicate avian activity if present in area | Remote | Critical | Medium | |||
Potential for serious injury/aircraft damage from wildlife on runway (common at remote and county airports) | Occasional | Critical | Serious | Ground support to clear runway and communicate activity to pilot | Remote | Marginal | Medium | ||||
Containment & Handling | No spill plan for fuel & chemicals, no label and MSDS for pesticide, no PPE | Remote | Marginal | Medium | Contractor is required to have spill plan; agency and state contracts require safety plan (includes spill plan) and follow pesticide label regarding PPE. | Improbable | Negligible | Low | |||
Human exposure due to treatment areas not being posted | Remote | Marginal | Medium | Treatment areas are typically posted on public lands only, roads may be closed on public lands at discretion of site manager; be aware that private landowners requesting treatment may not necessarily have their property posted or notify us of their activites. | Improbable | Negligible | Low |
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