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Tour Operators Program of Safety (TOPS) is changing its membership program to include a much broader segment of operators than just its traditional part 135 rotorcraft base, in an effort to raise the level of safety among air tour operators.
The expansion of the program has been coined the “Rising Tide Program” as a reflection of its inclusive nature.

“The rising tide raises all ships, which is exactly what TOPS aspires to do for the air tour industry,” said TOPS executive director Stan Rose. “We’re no longer willing to sit back and just say we’re glad it wasn’t one of our members that had an accident. We are taking a proactive role in leading this change and delivering a better outcome for everyone.”
Rose said the general public classifies all air tour operators as one, and the benefits of the TOPS membership have historically been limited to a small subset of part 135 operators.
Standards developed within the TOPS organization are designed to go above and beyond what is required by the FAA. With the Rising Tide Program, TOPS is creating provisional membership opportunities for part 135 operators who don’t fully meet the TOPS standard, but can demonstrate an equivalent level of safety. Through the program, these operators will receive guidance and mentoring to elevate their operations to the TOPS standard.
The program will also extend provisional membership opportunities to part 91 air tour operators that are prepared to fly to a higher safety standard. Rose added that the company hopes these part 91 operators will eventually work toward part 135 certification.
“We had a secondary goal for the organization, which was to raise the level of safety for the whole industry,” said Rose. “Not all companies can meet the standards, and the standards are high. So we have developed a ladder.” Rose used the example of doors-off operations, which are not against FAA regulations but are not permitted in the TOPS program. “Other companies with good operating standards can show that they have training and equipment or policies and procedures to demonstrate that they have an equivalent level of safety.”
While part 135 operators are required to write an operations manual that demonstrates how they will meet all part 135 requirements, Rose said TOPS is in the process of creating its own manual for part 91 operators that will allow them to demonstrate an acceptable level of safety, eventually to become a TOPS member. “We’re going to do an outline, and it’s going to include what we think are the important parts of part 135, our standard, and good operating practices — a safety management system [SMS],” said Rose.
Under this portion of the program, TOPS will give these part 91 operators 24 months before they will be officially audited. In the first year, the part 91 operators will have a mentor (an existing TOPS member) that they can turn to during the process of writing their own operations manual. At the end of the first year, Rose said an auditor will look at each operator and their manual, and perform a gap analysis that compares what is written in the manual to what the operator is executing.
He added: “The second year is where you get things going and start practicing what you preach. So at the end of the second year [the part 91 operator] would be audited to their own manual. And no two of those manuals will be exactly the same, but it still gives them a reference [and] a way of implementing safety practices that we consider basic.