<<

Issue 21 • 2007 A Lessons Learned Newsletter Published Quarterly

Wildland Fire

Lessons Learned Center

Air Operations on the Fireline Lessons Learned Ten experienced interagency aviation personnel were recently interviewed regarding their most notable successes, difficult challenges, effective practices and pressing safety issues in wildland fire air operations. Special thanks are extended to these interagency community members for sharing their important lessons and practices with the wildland fire community.

Notable Succ LCES from the Air Effective air tactical group supervisors (ATGS) employ the Lookouts/Communications/Escape Routes/Safety Zones (LCES) concept, in the same manner as ground firefighters; they just do so from an aerial platform. The ATGS can use LCES as a framework for communicating important safety information to ground per- In This Iue sonnel. Because the fire environment is constantly changing, an experienced Notable Successes ...... 1 ATGS will start out the operational period by contacting Division Supervisors, confirming their priorities, asking how they can help, and sharing feedback Difficult Challenges ...... 3 regarding LCES and other pertinent tactical or logistical information. Aviation Effective Practices ...... 5 Building an Effective Air Operations Organization Pressing Safety Issues ...... 6 No one individual can claim a successful air operation, as it always takes a team of people who are dedicated to safety, communicate well, and help each How to Contact Us: other. In this environment, people need to work together to identify and quickly [email protected] resolve problems, proactively plan for emergencies and crisis response, and [email protected] help “fill the potholes of knowledge” by training and cross-training on various (520) 799-8760 or 8761 aircraft and procedures. One memorable incident involved arriving at a wildland fire as a Safety Officer fax(520)-799-8785 Continued on page 2 www.wildfirelessons.net and finding operations not as they should be. Starting at the creek bed. The East Verde represented the only good natu- helibase, the Safety Officer found three aircraft assigned with ral barrier protecting the communities of Pine and Strawberry, no identified Helibase Manager or helibase organization. The and it also served as a trigger point for the fire organization. Safety Officer identified other concerns, including a lack of During one operational period, a smoke column leaned over fire shelters in the aircraft for pilots, no shelter training for the in a strong south wind, and the fire was heading directly for pilots, and no helibase operating plan or consensus on what the East Verde River. With no time for a burnout by ground to do in an emergency. After discussing the situation, the fire personnel, the Operations Section Chief flew in a organization identified a qualified person at the helibase who using a Plastic Sphere Dispenser (PSD) to backfire toward began pulling an organization together. the main fire, from the edge of the creek bed. Once the helibase organization was functioning properly, the The SEATs supported the backfiring operation, laying down Safety Officer moved a mile down the road to the temporary a line of retardant, anchoring into the previous day’s black. As the SEATs finished a section of retardant line, Opera- dispatch center, where people needed some coaching to de- tions would come in and drop PSDs, extending the black velop a plan for an aircraft emergency, which they had not line. By the time the main fire started to get rolling, it met the discussed. The Safety officer printed out a blank template to back fire. The column stood straight up and when the smoke help the dispatch center think through the problem and get settled, fire behavior was minimal and held the organized. When the Safety Officer was leaving, the dispatch existing fire at the creek’s edge with buckets. staff was completing a telephone contact resource list. Because of the light fuels and low elevation, this operation Later that day as the Safety Officer was driving to the fire, worked without ground personnel to reinforce the retardant one of the incident helicopters lost an engine and crashed at drops. The risk assessment showed that it would have been the head of the fire where it had been dropping water. The more hazardous to fly firefighters into this remote location, helibase and dispatch office performed their jobs very well. where they would have been at the head of the fire with no Resources were moved quickly and the pilot was rescued. escape routes and safety zones. This operation involved no Later, at the hospital, the pilot said, “The engine quit and I ground personnel so the IMT put few firefighters in harm’s knew I was in trouble and going down, so I turned the aircraft way, and the operation greatly diminished the threat to near- to hit outside of the flames. I was already thinking about that by communities. fire shelter before I was on the ground. Man, was I glad to A Communications Plan is Key have it when I climbed out of the aircraft and took off.” An Air Tactical Group Supervisor (ATGS) recalls a recent 150 acre wildfire in a very steep canyon with at least 90% slopes in tall mixed conifer. Numerous aircraft were working this incident including three heavy airtankers, a lead plane, two light helicopters, a heavy helicopter, and one medium helicopter. The airspace over the fire was seriously con- gested. ATGS and the pilots communicated well with each other; every pilot knew what the other pilot was doing and aviation personnel took their time. ATGS set up a hold point for the helicopters to use while the airtankers were in the Fire Traffic Area (FTA). Air Attack also set-up and enforced an entry and exit pattern. In these situations, communication proves to be the key to success. If you have a good plan and it is well known, people know what to expect and do. There are no surprises and operations go much more smoothly. Using a PSD Courtesy of USFS SE Region Aviation Personnel Evaluating Risk and Decision Making On one fire, the Incident Commander (IC) asked an Avia- The Right Operation in the Right Fuels tion Safety and Technical Assistance Team (ASTAT) to take a In 2004 during the Willow Fire near Payson, Arizona, no large look at their air operations because they had a concern that airtankers were available to perform retardant drops. In- they felt the IMT needed assistance in mitigating. The ASTAT stead, the Incident Management Team (IMT) used five Single arrived at the incident, finding that the wildfire was located Engine Air Tankers (SEAT). The small airtankers performed high in the “goat rocks” at the base and on the side of a butte. well, benefiting from relatively short turn-around times. The The local unit wanted the fire controlled before it reached the SEATs also proved effective because the wildfire was in light top of the butte to protect several four-wheel drive accessible fuels at a low elevation. cabins located on the plateau a few miles from the fire. The The fire would make a run towards the East Verde River each rocky terrain prevented firefighters from safely constructing evening threatening to jump the river, which is actually a dry fireline, and prevented anyone from staying near the fire to 2 monitor three helicopters working the fire. The fire was at LCES Beyond Wildland Fire an elevation of 8,500 feet, the weather was sunny and the One of the biggest successes noted in one unit’s air op- temperature very hot. erations was realizing that ground safety concepts, includ- One of the ASTAT members requested a flight in the aircraft being used as an air attack platform to observe the air opera- ing LCES, apply not only to wildland fire operations on the tions, and found the helicopters dropping water on the creep- ground, but also serve as a useful to establish and main- ing, spotty fire without much direction or success, and that tain a safe work environment during aviation operations. For the pilots were placing themselves in definite risk. Because example, the person marshalling on the helibase watches of the fire’s location and terrain, if something happened to over the big picture serving as a lookout to identify where the one of the helicopters, rescue operations would have proven helicopter will go if there is a loss of power and where the very difficult and protracted. Shortly after the observation ground personnel we will go to avoid the helicopter. They are flight, the ASTAT brought the overhead personnel together identifying the escape routes and establishing an appropri- to discuss safety and tactical options, resulting in immediate ate safety zone around the helicopter. To cover the commu- cessation of the air show in the rocks. nications portion of LCES, it is necessary to identify a com- munications plan with the aircraft, ground personnel, other aircraft, flight following, etc. Difficult Challeng Practicing for Emergencies Working with aircraft in an interagency environment and out of improvised airfields always presents a challenge. Manag- ing an aviation emergency in this environment presents the most difficult challenge an aviation person can face. Only by having everyone well briefed and practiced on how to imple-

ment emergency procedures can a rapid and professional response occur during emergency situations that nearly al- ways develop rapidly. Since each day typically brings new people into and takes people out of the organization, emer- gency procedures must be a daily topic at briefings if every- one is to know their role and serve it well. During periods of slow aircraft operations, when smoke pro- hibits flying or when personnel are waiting for a mission as- signment, the organization can, and should, train and prac- tice, practice, practice. Supervisors should brief everyone at a helibase or airbase concerning each aircraft on the base and the emergency procedures for each aircraft. Improving Air Operations on Large Incidents Firefighter on 2004 Alaska Solstice Complex Fire From an air attack perspective, the McNally Fire in Southern Courtesy of Alaska Fire Service in 2002 presented several difficult challenges. The incident employed eighteen helicopters and at various times, Adapting to Alaska’s Air Operations four to six air tankers worked the fire as well. Airtankers fly- In 2004 in Alaska, a Helicopter Manager worked with a Type ing between the fire and Porterville experienced a couple of 2 helicopter assigned to Alaska for three months during the close calls as they were using the same saddle to enter and state’s record fire season. On this 14 day assignment, the exit the fire area. To mitigate this hazard, air operations per- Helicopter Manager first learned how much air operations in sonnel set up an Initial Point (IP) for the fixed wing aircraft Alaska differ from air operations in the lower 48 states. Each to report to as they came into the fire area, and another one day brought a new learning experience, and the key lesson for them to exit from. By using this plan, the incident organi- was to seek and use local knowledge. zation eliminated concerns posed by two aircraft using the Air operations personnel needed to attend numerous brief- same saddle. ings and meetings in order to gather and absorb as much of Another difficult challenge stemmed from the size and extent the local protocols and information as possible. This “infor- of the fire. It was spread out over a very large area with steep mation gathering” proved critical to understanding the local terrain and deep canyons. Since aircraft were working five to environment and in making informed decisions. The pilots, six different areas of the fire, the air tactical group supervisor mechanics, and crews discussed safety and LCES every could not maintain visual contact with all aircraft at any given day, and briefings with local personnel addressed numerous time. In addition, because of the deep canyons, air attack safety issues such as unusual work schedules facilitated by could not hear the helicopter traffic on the victor radios in all the lack of night during the summer, and different procedures areas. To mitigate these issues, the IMT put up a Helicop- for loading the helicopter. ter Coordinator (HLCO) and also set up a victor repeater. 33 Lessons in Aviation History - A Perspective “When I look at past aviation accidents and past incidents with potential, what really stands out is how we make decisions regarding the use of aircraft, such as whether a flight is necessary, or whether the choices are justified. Do we utilize the safety we have to include load calculations, manifests, PPE, flight following, briefings etc. to the best of our ability? Is responsibility taken at an individual level for mission safety? Accidents continue to happen, but I do not feel the answer is to create more policy, but simply to understand where existing policy has come from and why it was made. Rules generally come from someone else’s bad experience, or perhaps, bad decision. If we are going to be committed to creating a safer aviation program then we are obligated to become students of history; to learn from the past. We should not reinvent the wheel, but we should continually learn from our experiences, both good and bad. The policy we work with daily has often come from both.” “We work in a setting where there can be tremendous political pressure, where on an almost daily basis someone’s health, and perhaps life, may depend on us helping them. We deal with the urgency of a running wildfire, time constraints of an eve- ning mission with limited daylight left, being pulled in several directions for multiple priority missions, and the human nature of getting caught up in someone else’s emergency. To name a few of our human factors, we are people that become tired and stressed, but we care about others and want to help, wanting to avoid confrontation and please others without being the heavy …no wonder we make mistakes. We do have some evaluation tools to help us avoid having these human factors be- come problems. We must use these tools. Make sure we use them. We must find out why we have the current rules and policy so better choices can be made. This option is far better than new policy creation because of a bad decision that we made!”

Still, there remained areas where aircraft were working that challenge. Experience shows that when firefighters need the required air attack to remain in the immediate area. ATGS aircraft the most, it is often when they cannot fly due to intense made sure everyone knew where everyone else was work- smoke or erratic winds. Do not rely on air attack as a look- ing and which helicopters were transitioning to and from the out or a primary communications link, because if they have helibase. These challenges and the mitigations employed to leave the area, the first two critical elements in LCES, the demonstrate the importance of communications. The better lookout and the communications link, leave with them. informed the pilots are, the less likely it is that they will expe- rience unpleasant surprises. Aircraft Use and Indirect Line Construction Holding a fire with aircraft until ground resources can construct Dealing With Media Helicopters indirect line and successfully burn out presents a difficult chal- Large, complex incidents involving the wildland urban inter- lenge for operations personnel. With large fires and firefight- face naturally draw the attention of the public, and therefore ers going indirect more often, this strategy occurs often these the media, and the Rodeo Chediski Fire in Arizona was no days. In many cases firefighters can justify this strategy, but exception. Media helicopters were everywhere on this fire, they must carefully consider alternatives well in advance. Al- and if one news helicopter received permission to get down ways consider the effort, cost, and exposure to risk involved low to photograph something, they all had to get down low, in holding a fire with aircraft. and they all wanted to go at the same time. The air tacti- cal group supervisors spent more time talking to, and dealing Emphasizing Aviation Education with, media helicopters than with the fire helicopters. Three The limited aviation knowledge of land managers responsible to four media helicopters are challenging enough, but when for an incident can present a difficult challenge. On one fire, there are eight to ten, it really impacts fire air operations and for example, a local unit official considered “heli-mopping” to safety issues ensue. Fortunately, overseeing the media heli- be an acceptable practice, because they did not understand copters occurred for fairly short periods of time - usually from the implications. The official was unaware of density altitude 6:00 a.m. until 10:00 am, and then from around 4:00 p.m. issues faced by the aircraft, had not considered the remote- until 6:00 p.m. ness of the fire area should an aviation accident occur, and Air operations personnel overcame this challenge by trying had not reflected on the actual effectiveness of the water to meet their requests when it did not impact suppression air- dropping without the benefit of ground forces to follow-up. craft operations, and by allowing only a few media helicopters down low at one time. When unable to get down low, the IMT Fire management personnel also tend to use air tankers to limited media aircraft to flying towards the top of the Tempo- drop retardant in the wildland urban interface, even when the rary Flight Restriction (TFR). retardant is obviously ineffective. However, the news footage shows that we are “doing something”. Exposure to risk just to Relying on Aircraft for LCES show we are doing something happens too frequently, though Getting the point across to firefighters that they should not it is rarely necessary or safe. Aviation education is very impor- base their safety or strategy on aircraft presents a significant tant at all levels of fire management. 4 pilot, who usually carries the maximum allowable load while Aviation Effeive Practic combating difficult winds, limited visibility due to smoke, and canopy cover. Programmatic Risk Assessments Firefighters on the ground often fail to realize how slim the The Interagency Risk Management Process is applied pro- safety margin is for what they are telling the pilot to do. If gram wide versus one flight mission at a time. For example, the helicopter experiences a mechanical malfunction, the pilot during reconnaissance, brainstorm what could go wrong with may have nowhere to go. Firefighters must remain mindful of the system. Identify hazards and the possible mitigations us- what they are asking aviation resources to do during an inci- ing a simple checklist to then eliminate those hazards. This dent. If the firefighter is ready with a target description and process was elevated to a national level program. Program- location, gives a mirror flash or good clock direction, and has matic risk assessments have just been done in July 2007 for the drop area cleared of all personnel, the pilot can drop with air tankers and helicopters (long line, external load, aerial su- little to no hover and be on his way to get another load. This pervisor and SEAT) and are available at: practice is true for all aerial drops both water and retardant, http://www.fs.fed.us/fire/av_safety/index.html and for helicopters, SEATs or large air tankers.

Supporting the Incident Commander The ATGS assists the Incident Commander in establishing System Safety the most efficient and effective command structure for their From a national perspective, implementing “System incident. For example, by using their aerial perspective the Safety” as an interagency approach to aviation safety ATGS can make recommendations about operational priori- represents a critical step in our operations. A system ties, including division breaks, additional resources needed, safety approach will assist Safety Managers at all lev- values at risk and operational safety concerns. They also els in creating a Safety program that is proactive to the assist ground personnel with communications and in estab- needs of the interagency aviation community. Find out lishing an effective communications plan. more on system safety application at: Knowing the Emergency Procedures http://www.fs.fed.us/fire/av_safety/index.html Teaching and then practicing aircraft emergency procedures on every air base and at every dispatch center represents an Maintaining Open Communications with Pilots essential practice. An Air Operations Branch Director and a Safety Officer can run a practical drill to assess emergency Helicopter managers must initiate and maintain open and procedures at a dispatch center by visiting the dispatch center honest communications with pilots, their mechanics, and the support drivers. Monitor verbal and non-verbal language to during times when the regular dispatchers are out, introduc- stay on top of the concerns of personnel and help them to find ing themselves, and then asking the question, “What would ways to mitigate their concerns. Pilots are in a tough spot, as you do if an aircraft went down right now?” Too often, this they feel that they need to perform to make money and please question meets with a look of panic and dispatchers running the customer. Talk to them about being honest about what about to find the aircraft mishap or crash rescue plan. When is going on. A pilot could be going into an area that is more the dispatchers find the plan and start to open it, the visitors hazardous than they are letting on. Work with mechanics to should ask “Don’t read it to me; just tell me what it says.” determine maintenance needs and coordinate the timing of The AOBD and SOFR may follow this drill with a general dis- that maintenance to reduce or eliminate any unavailability. cussion of why the dispatch center must talk about emergen- When working with a “call when needed” (CWN) helicopter, cies and identify who does what every day. The goal is that the Helicopter Manager must establish a good working rela- the dispatch center staff will only need the mishap plan for tionship with the helicopter crew quickly; this can be difficult phone numbers and as a checklist to ensure nothing is forgot- because crewmembers do not know one another. It is impera- ten. One experienced Air Operations Branch Director recom- tive to establish this open communication very early on and mends that the dispatch office keep photos available of each continue it throughout the assignment. A size-up should be aircraft they are responsible for, so that when the Federal Avi- one of the first things done with both the pilot and mechanic. ation Administration (FAA) asks what the aircraft looked like Assess the capability, limitations, and the emotional state of in the case of an accident, the dispatcher can better describe the pilot and the mechanic. the color patterns, top to bottom. Evaluating Air Operations Needs Properly Directing an Aircraft Good situational awareness can help ground personnel eval- An effective practice for ground personnel on the fireline is to uate whether continued water or retardant drops are needed. think about how to direct an aircraft to a specific target before Once water or retardant drops stop the spread of the fire and the aircraft is ordered to complete the mission. Too often the the potential threat to the line has been eliminated, it is time pilot gets to the individual firefighter that needs a bucket drop to re-evaluate the need for additional drops. Operations per- and requires several passes before the pilot can figure out sonnel should always consider alternate ways to eliminate what the firefighter actually needs on the ground. The longer threats to the line such as using engines and other ground the hover time, the more dangerous the situation is for the resources instead of “heli-mopping.” 5 Mission Pre-Planning and Pre-Thinking In one large national park, the NPS uses a helitack crew and helicopter for a wide variety of missions, including rappelling to fires, medical emergencies, searches, law enforcement operations, aerial ignition, high angle rescue with short haul, high elevation rescues, wildland fire use and prescribed fire support, aerial mapping and reconnaissance. Often, NPS aviation personnel must switch from one of these missions to another with only minutes in between, and most missions involve a high degree of complexity. The aviation program also demands that many different people of varying skills and abilities be trained and involved in helitack operations, not just fire personnel, but personnel engaged in , law enforcement, emergency and medical services, as well as the media, scientists and others. A critical part of the system is to have pre-planned configura- Interagency Operator Qualification Card tions, diagrams, lists, specific briefings, risk analyses, and Courtesy of USFS SE Region Aviation Personnel project aviation plans. By using this pre-planning and pre- thinking approach, personnel can move faster, remember critical components and gear, cover all the safety bases, and Pring Safy Iu go to the mission as prepared and as efficiently as possible. Overcoming “Missionitis” Competence and Confidence The outcomes resulting from our “can do” culture present Air operations require competent people who can iden- some very pressing safety issues for the wildland fire com- tify and correct both potential and evolving problems. This munity. By being very mission oriented, wildland fire person- competence starts with the Operations Section Chief, and nel have a tendency to assume that a contract pilot arrives includes the Air Operations Branch Director to the Helicopter on an incident prepared to make many operational decisions Crewmember on a module. Everyone needs to be on this team to identify deficiencies on their own. The fact that they are getting paid by the flight and help correct them. hour provides little incentive for a contract pilot to do a risk assessment. Consequently, the aviation community needs to incorporate the risk assessment process into every mission.

Type 1 Helicopter Dipping from Water Source Courtesy of Rowdy Muir’s Type 1 IMT

6 New doctrinal approaches and high reliability organizing Empowering Pilots to Speak Up (HRO) represent positive steps in aviation. All fire aviation From a national aviation safety perspective, it is essential to training will eventually be redesigned to incorporate doctrinal empower pilots to speak up when they are uncomfortable approaches and HRO principles. The target date is January with the mission or mission conditions. This represents a sig- of 2008 for the release of this new Interim Directive for FSM nificant human factors issue and agency operations and avi- 5700 Aviation Management. It is being designed to have a ation personnel need to promote this critical interaction. By positive impact on improving the culture to achieve better de- listening to the tone of their voices, observing performance cision making for better results. and mission condition and soliciting their input, the aerial su- pervisor plays a primary role in aviation safety. Ineffective Use of Aircraft Communicating the risk associated with longline operations The ineffective use of aircraft represents a serious safety provides an excellent example. Often, we push limits and concern. Troubling practices include “heli-mopping,” using increase risk when going into longline sites. With the nar- SEATs in fuel types and at altitudes they are not designed row safety margins associated with longline operations, it is for, and endlessly dropping retardant on a line that will not imperative to provide pilots with accurate information on line see firefighters for days. Some operations personnel still feel length and site conditions. A proactive way to mitigate some it is acceptable to work a fireline with retardant all day without of this risk would be to allow the pilot to observe and assess putting firefighters on the line. When this occurs, aviation the site prior to commencing operations. resources end up working the next ridgeline over the next day, and this proves both frustrating and unnecessarily ex- Staying Clear of the Drop Zone pensive. Operations overhead should not assume that us- Ensuring that all ground personnel are clear of the drop zone ing aircraft instead of crews is safer, more effective or more represents a critical safety practice no matter what type of efficient. Risk is still present - simply transferred to aircraft aircraft are being used. Many firefighters have been injured crews. when they failed to get clear of the drop zone and falling de- Crews often want “just one more bucket drop,” even when bris hits them. Consequently, pilots have become very cau- that bucket drop requires major effort to talk the pilot into a tious over the years and if they see anyone who they consider target where there exists no visible sign of a hot spot. When to be too close, the drop will be aborted until the situation is an experienced ATGS starts hearing evidence of this kind of remedied. Aborted drops add unnecessary risk for the pilots effort over the radio, they should contact the Crew Supervisor as well as wasting time and money for the incident. and/or the Division Supervisor to inquire about the effective- ness of the tactic being used. However, in the ATGS role one can easily become too judgmental, since the ground firefighter has a much different perspective than that from the air. The Division Supervisor might have a situation requiring bucket drops and their tactics are proving effective. The ATGS must take the time to discuss apparent issues as they occur with the intent to help everyone understand the mission and maintain situational awareness.

Chinook Drop Photo Courtesy of Dan Oltrogge’s Type 1 IMT

7 Aviation Personnel Shortages A general shortage of aviation management personnel exists, both in terms of total numbers and in terms of personnel willing to step up and take a management position. The resulting shortage frequently causes aircraft mobilization or utilization delays. Wildland fire agencies need to increase the number of qualified air operations personnel and find incentives to get personnel to fill aviation management positions. The agencies should target training and developmental assignments toward Helicopter Manager, Helibase Manager, Fixed Wing Base Manager, Tanker Base Manager, Air Support Group Supervisor, Air Tactical Group Supervisor (ATGS), and Air Operations Branch Director, with the intent of increasing the number of people available to fill these positions.

ATGS may represent the most critical of the chronically short positions, not because it is the most important, but because it takes a significant amount of time to obtain a Division Super- visor qualification, a requirement for ATGS qualification. Many qualified Division Supervisors would much rather achieve qualification as an Opera- tions Branch Director or Op- erations Section Chief than ATGS and, in addition, there are those who do not do well flying in a small plane going in circles for hours at a time. Being in a small plane for extended periods is dif- Pilot Briefing Courtesy of USFS SE Region Aviation Personnel ferent than being in a helicopter and this position is not for everyone.

Radio Communications and Air Operations Radio communications interoperability and the associated narrow banding issue, represent what some would describe as “a disas- ter waiting to happen,” and the agencies have been slow to resolve this critical safety concern. Federal wildland fire agencies have switched to narrow band frequencies, while most state cooperators are still using wide band. Consequently, interagency resources must work very hard to ensure that all personnel can talk to one another on every incident, and incident managers must cease avia- tion operations when resources cannot communicate. Too often, though ground resources may be able to talk to one another or relay communications safely, aviation communications represents a significantly different problem altogether. For one thing, ground resources working with tactical aircraft must be able to make immediate radio contact with those aircraft.

Human Error and Aviation Qualifications Human error still accounts for most aviation mishaps. Do not blame aviation accidents on fate, the weather, or the inevitability of equipment malfunctions. Responsibility for aviation safety rests with all aviation personnel from the first year helitack crewperson to the unit Aviation Officer and beyond. Unqualified personnel cannot be tolerated, particularly in positions of authority and decision Picnic Rock Fire making. Photo provided by the BLM The position task book (PTB) replaced what could sometimes be described as the “good old boy” method of ICS qualification ad- vancement, and the change has generally succeeded in documenting training and experience. Fortunately, evaluators have felt em- powered to decline certification of trainees because the trainee lacks quality in their experience. If we do not honestly evaluate task books we are no better off than before they were used.



8