yes depending on ichigo's mental state Also depending on his physical state. Please attempt to remember the fact that almost everytime his hollow side takes control, he is severely injured. Not to mention, his hollow is part of Zangetsu, meaning everytime he uses his Zanpakuto, he is making it easier for his hollow side to take control of him in his waking state. Thats my opinion. Ichigo's inner Hollow can come out in the middle of a fight of his even before/if he's not injured at all and just want to help him destroy his opponent(s). (As seen in Chapter 193, page 16-19 and Chapters 211-212)