IMHO, the FAA, the operator and the pilot are equally to blame.
1. On May 10, 2019 (260 days prior to the accident), the pilot performed two S-76 training flights with a contract training company. During the NTSB interview of the instructor for the above flight, regards wearing a view limiting device during IIMC training, the instructor stated, “so sometimes yes, sometimes no. Especially if you wear a helmet it's difficult to use a hood on something like that. If you wear a headset that may or may not. It depends on what's available, somebody wants it, somebody doesn't want it. Again, it is more tailored for the check ride.” And specifically, on whether the accident pilot wore a view limiting device, the instructor stated, “I don't remember that part.”
2. The operator didn’t have procedures for unusual attitude recovery and IIMC. These procedures were absent from the operator’s S-76 maneuvers guide and training manual at the time of the accident. These procedures were added to the company’s documents after the accident. This added material lacks proper indications highlighting what text was added/altered.
3. The accident docket information is not clear what, if any procedures were in place at the time of the accident.
4. In the absence of a specific delineated procedure, maybe the accident pilot was attempting to perform exactly what the operator’s GOM instructed him to do, “pilots will never take an aircraft into IMC…”?
5. Was the pilot attempting to use the AP? Was he leveling the wings? Was he turning around and/or climbing? Was he attempting a transition to IMC? Was he making things up as he flew?
6. Part 135 IIMC training and checking have existed at least since 2014 (accident date of 3/6/20). FAA Inspector guidance states they must ensure that operators have procedures for recovery from IIMC and that these procedures are incorporated into the certificate holder’s initial, transition, upgrade, and recurrent training curriculums (my emphasis). In addition to training, the certificate holder should establish a GOM loss of control IIMC avoidance policy that supports the emergency authority of the pilot to divert, make a precautionary landing, or make an emergency transition to IFR (my emphasis). Within 60 days of the FAA’s Part 135 Helicopter Training and Qualification Program Review and Competency Check Requirements notice, POIs should have conducted a “focused review of the helicopter training and qualification programs for their assigned certificate holders to identify whether the programs include the required training and testing on procedures for … training and checking on recovery from IIMC.” By all accounts, this was overlooked.
7. The FAA POI characterized the training with this company as not part of the operator’s approved training program, stating, “it was never something where, you know, I either approved, accepted, or required it, or, you know, anything to that effect.” And when asked if he would say that it meets the definition of best practices as the FAA uses that term, he added, “I can't answer that. Because I just don't -- you know, I'm not an expert on their training, or their facility, or really you know, I don't have information -- enough information to make that distinction.”
Last edited by JimEli; 2nd May 2022 at 13:35.
Reason: added point 5 and 7.