US EMS FAA Safety Proposals

[havoc]

Senate Aviation Bill Would Mandate Safety Changes for EMS

Legislation, S. 1300, has been introduced in the U.S. Senate to authorize appropriations for the Federal Aviation Administration (FAA) for fiscal years 2008 through 2011 to improve safety and capacity and to modernize the air traffic control system. In addition to the issues previously discussed concerning user fees and surcharges and an increase in the fuel tax, S. 1300 also would mandate significant changes for helicopter emergency medical service operators.

Section 508 of S. 1300 would mandate compliance with Part 135 regulations whenever medical crew are on board, without regard to whether there are patients on board the helicopter. Within 60 days of the date of enactment of S. 1300, the FAA would be required to initiate rulemakings to create standardized checklists of risk evaluation factors and require helicopter EMS operators to use the checklist to determine whether a mission should be accepted. Additionally, the FAA would be required to complete a rulemaking to create standardized flight dispatch procedures for helicopter EMS operators and require operators to use those procedures for flights.

Any helicopter used for EMS operations that is ordered, purchased, or otherwise obtained after the date S. 1300 was enacted would also be required to have on board an operational terrain awareness and warning system (TAWS) that meets the technical specifications of section 135.154 of the Federal Aviation Regulations (14 C.F.R. 135.154).

To improve the data available to National Transportation Safety Board (NTSB) investigators at crash sites, the FAA would also be required to complete a feasibility study of requiring flight data and cockpit voice recorders on new and existing helicopters used to EMS operations. Subsequent to the feasibility study, the FAA would be required within two years of S. 1300’s enactment to complete a rulemaking requiring flight data and cockpit voice recorders on board such helicopters.

All Helicopter Association International (HAI) operators conducting EMS operations are strongly encouraged to review the provisions contained in *Section 508 of S. 1300. HAI is interested in hearing from you with respect to any concerns you might have over the requirements contained in this legislation. Please contact David York or Ann Carroll via email at [email protected] or [email protected].

HAI continues to analyze legislation in the U.S. House of Representatives and the U.S. Senate with respect to FAA reauthorization and general aviation user fees, surcharges, and other safety provisions. More information will be provided on the HAI Web site as developments occur in Washington.
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*Section 508 of S. 1300

S.1300
Aviation Investment and Modernization Act of 2007 (Introduced in Senate)

SEC. 508. INCREASING SAFETY FOR HELICOPTER EMERGENCY MEDICAL SERVICE OPERATORS.
(a) Compliance With 14 CFR Part 135 Regulations- No later than 18 months after the date of enactment of this Act, all helicopter emergency medical service operators shall comply with the regulations in part 135 of title 14, Code of Federal Regulations whenever there is a medical crew on board, without regard to whether there are patients on board the helicopter.
(b) IMPLEMENTATION OF FLIGHT RISK EVALUATION PROGRAM- Within 60 days after the date of enactment of this Act, the Federal Aviation Administration shall initiate, and complete within 18 months, a rulemaking--
(1) to create a standardized checklist of risk evaluation factors based on its Notice 8000.301, issued in August, 2005; and
(2) to require helicopter emergency medical service operators to use the checklist to determine whether a mission should be accepted.
(c) COMPREHENSIVE CONSISTENT FLIGHT DISPATCH PROCEDURES- Within 60 days after the date of enactment of this Act, the Federal Aviation Administration shall initiate, and complete within 18 months, a rulemaking--
(1) to create standardized flight dispatch procedures for helicopter emergency medical service operators based on the regulations in part 121 of title 14, Code of Federal Regulations; and
(2) require such operators to use those procedures for flights.
(d) IMPROVING SITUATIONAL AWARENESS- Any helicopter used for helicopter emergency medical service operations that is ordered, purchased, or otherwise obtained after the date of enactment of this Act shall have on board an operational terrain awareness and warning system that meets the technical specifications of section 135.154 of the Federal Aviation Regulations (14 C.F.R. 135.154).
(e) Improving the Data Available to NTSB Investigators at Crash Sites-
(1) STUDY- Within 1 year after the date of enactment of this Act, the Federal Aviation Administration shall complete a feasibility study of requiring flight data and cockpit voice recorders on new and existing helicopters used for emergency medical service operations. The study shall address, at a minimum, issues related to survivability, weight, and financial considerations of such a requirement.
(2) RULEMAKING- Within 2 years after the date of enactment of this Act, the Federal Aviation Administration shall complete a rulemaking to require flight data and cockpit voice recorders on board such helicopters.

[SASless]

Either you clean up your own house or the guvmint will do it for you.

I never thought I would argue "for" more government meddling but in this case it is about time someone step in and stop the killing.

Anyone notice how few EMS crashes there have been this year as compared to last year? Perhaps the changes implemented recently have had a positive effect.

[Revolutionary]

All fine and dandy except for adding FDR and CVR equipment to EMS aircraft. I mean, it's not like EMS crashes are great mysteries or anything. Most accident reports could start with "It was a dark and stormy night..." and from there you could just fill in the blanks.

[JimL]

Revolutionary,

In fact congress' wish appears to be in line with the International Helicopter Safety Team (a body that consists of representatives from all parts of industry) thinking - as expressed in one of their interim recommendations from their first year of analysis.

It would appear that it is extremely difficult (for other than PPRuners) to establish the root cause of accidents and serious incidents.

Recommendation No. 6. - Flight Recording Devices and Cockpit Image Recording Systems for Helicopters

Currently, the FAA does not required CVR/FDR installation for light aircraft and most helicopters. In the commercial world Cockpit Voice Recorders (CVR) and Flight Data Recorders (FDR) serve as critical aids in understanding airline accidents and incidents.

Understanding helicopter accidents with a high degree of confidence is often impossible given the lack of utilization of recording devices. Additionally, due to the FAA’s Technical Standard Order (TSO) requirements for crash survivability, traditional recording devices have been priced out of most helicopter markets.


Technological advances, in some cases, have also hindered the ability to understand causal and contributing factors of helicopter accidents:New cockpit configurations utilizing digital displays and LED illumination have reduced the ability of investigators to perform time honored assessments of passive indicators such as needle slap, bulb filament deformation and analog gauge positions at impact. Increased use of composite material construction, which is susceptible to fire, masks or destroys post crash evidence; mature post crash analysis methods of composites have not yet been developed.The JHSAT recommends that new technologies be adopted to increase information available to accident investigators. Advances in miniaturization in digital storage, non-volatile memory (NVM), digital imaging and GPS systems have allowed for development of mini-flight data recorders which are relatively inexpensive. In today’s market, cost varies from $1000 to $5,000 as opposed to $50,000 to $150,000 for traditional TSO compliant equipment.

The IHST/JHSIT should promote work between industry and the FAA to develop recording standards and work to ensure that installation of these devices is not hampered by over burdensome government or industry requirements (i.e., TSO requirements which drive cost/complexity to unacceptable levels).

Experience with several manufacturers’ products over the last five years has demonstrated an approximate 97% data recovery capability from non-hardened NVM devices.

A variety of recording devices should be considered, the spectrum of operational and cost environments will need to be optimized with the various technologies:

1. GPS Positional Flight Recorders-no aircraft interface.

2. Performance Monitoring Devices-recovers aircraft information.

3. Cockpit Image Recording Systems – digital imaging

Adoption of these technologies could also have beneficial implications in day to day operations. All three types of units have the added capability of acting as mini flight data recorders and are capable of being used as training devices, where flash card memory can be removed and the flight can be “re-flown” on a computer. Performance Monitoring Devices can also record up to several thousand hours of aircraft time and could act as electronic aircraft and engine logbooks.

All of the devices are useful for the aircraft owner, to enable monitoring of aircraft utilization and the pilot performance. The devices should not be accessible from the cockpit, thus prohibiting the pilot from turning them off or disabling them.

To summarize, technology can be a double edged sword relative to understanding helicopter accidents. Some traditional tools used by investigators have been compromised; however, other technological advances should be used to develop recording devices for all helicopters, new and old. Significant work will be required to develop standards, correctly adopt technology to the needs of varied operations and meet the cost constraints of smaller operations. The benefits will be many, ranging from more complete understanding of accidents, especially fatal accidents, where no survivors are available, and the potential to use recording devices as simplified HUMS/HOMP devices.

Jim

[Devil 49]

I'm afraid there's not a lot of progress in this. In order of importance, those of us in the U.S., flying helo EMS need:
1. Some science and oversight in scheduling, especially night duty assignments. Flying nights has proven to be the most dangerous part of the job, but the industry continues to overlook the well proven issues with sleep disruption and circadian upsets;
2. Weather data on board each aircraft;
3. Night vision.
I'd also love to see autopilots, but having seen where universal GPS has taken nav skills, I think it's realistic to expect a deterioration in basic pilot competence if the machine stirs the stick as well.

Risk assessment "tools", CVR/FDR (Yep, flew into the ground. As if the huge scar on the earth and the smoking pile of parts didn't already prove that...) and attention to dispatch do squat when the pilot: has diminished mental abilities; is functioning with poorly recalled data that's hours old, and can't see the environment operated in.

Help the pilot function better and you'd see MASSIVE improvements in safety.

[SASless]

JimL,

Perhaps we ppruners are a bit ahead of the curve in assessing blame and assigning causes of crashes however I would submit those opinions in some cases are based on a very large knowledge level. Supposition it is in some cases and types of accidents but when it comes to CFIT or Loss of Control events the cracker barrel jury usually is found to be quite correct in their determination of what caused a particular accident.

In most cases, the only difference between ppruners and accident investigators is ppruners are thinking like pilots and the investigators are trying to think like pilots as all investigators are not pilots.

Basically, we can put ourselves into the scenario and draw from our experiences where fate intervened and allowed us to survive for another day. That is something a non-pilot investigator can only do vicariously.

The one thing we ppruners and pilots have in common with the investigators is we are all reading tea leaves while trying to re-create what was going on in the cockpit during a flight that resulted in a crash.

Adding the electronic monitoring systems will go a very long ways to curing that inability for investigators to know what actually was going on.

[JimL]

Devil49,

Interestingly enough, Section 507 (the one before the Section on EMS) is a requirement for the FAA to have NASA conduct more research on Flight Crew Fatigue.

It is not clear that you need more science - the subject of crew fatigue/duty cycles/circadian patterns has been well researched over the last 30 years and the problems and answers are well know. It is the lack of resolve of pilots, operators, regulators and the like to bring about a change that is the problem.

Even in Europe it is almost impossible to sit all these parties in a room and come to an agreement - there is too much at stake for any/all to move towards a common solution.

What's wrong with using ASRS to bring your plight to the attention of NASA/FAA?

Jim

[JimL]

SASless,

I'm not sure I share your view of accident investigators, the ones who I know and work with (mostly from the AAIB UK) are ex-pilots - both helicopter and fixed-wing. However I do agree with you that once all the facts are on the table a multi-discipline team, including current operational pilots, can provide additional insight into root causes of accidents.

In fact the recommendation that I posted earlier comes from the JHSAT who are a multi-discipline team re-examining accidents from the archives - starting with the year 2000 and then moving to later years. The recommendation on data recorders was produced after they examined all accidents for the year 2000, had to drop a number because of insufficient data and were frustrated on a large number of the others because of sparse data.

However, there is another interesting point in your post which I would like to pick up on - what did or did not happen in the cockpit should be only one part of what is considered. Most causal chains have links which might precede the accident by days, weeks and even months. Only when these other issues are considered are we in a position where we could address all causes.

The most effective way to reduce the number of accidents - and the aim of the IHST/JHSAT is to reduce the number by 80% within 10 years - is to attempt to break the causal chain at as many links as is possible.

We have no chance of meeting such a target unless we have a sea-change in attitudes; with up to 80% of accidents being as a result of human factors the target is impossible to achieve unless we can find a way of making all members of our community more risk aware and making our operations more error tolerant.

As you have also remarked, with the capture of operational data comes the ability to better understand the operational environment; with this understanding - and with the help of ASRS, CHIRP and in-house reporting schemes - comes the ability to address unsafe acts and latent conditions at the time when 'abnormality' or incidents first manifest themselves.

Lastly, consideration of the accidents leads one to believe that we bandy CFIT around too lightly; a large number of accidents that are seen - certainly in the lighter helicopters - are as a result of Loss of Control resulting from flight in a reduced visual cue environment. Before loss of control, and accident, occurs we are past the point where any internal instrument could prevent the event. It is unlikely that many of such accidents could be addressed without either improving the handling qualities of the helicopter or pilots being aware that flight in such conditions is likely to result in (their) death.

...and so we return to EMS.

Jim

[SASless]

JimL,

I agree with what you said.....however getting the guilty to fess up and make changes is the hard part of cutting the chain.

Now that we are back to EMS....care to throw out some examples of the accident chain other than the pilot which have been proven to be a very real and important link in the chain.

Those being things like regulations (or the lack of...), management malfeasance or misfeasance, commerical pressure, and similar issues that are much easier observed but never really curbed by those involved as it has a negative impact on profitability and flexibilty of operations.

We all know flying JetRangers at night on EMS flights during inclement weather is a made to order recipe for disaster.....but yet that is a very popular economic model for EMS in the USA. Why is it we continue to do that despite it not taking a rocket scientist to know that is so?

[Gomer Pylot]

I don't think flying 206s at night is going to stop, but there are things that can be done to help the pilots. Weather data is available through XM radio to a Garmin 396 or 496, and this can be easily and relatively cheaply installed. The hard part is getting the Feds to allow the installation. All they want to see is panel installations, which aren't optimal in all cases.

CVRs and FDRs can help in the long run, I think. It's easy enough to say "Yep, flew it into the ground". The hard part is understanding why it was flown into the ground. If we don't understand why, we can't make much progress in preventing it from happening again. We'll just keep on saying "Yep, flew it into the ground". That doesn't help anyone. We need to know why, and do something to keep it from happening to others.

Flying to Part 135 standards all the time can also help, I think. It's not always convenient, but it makes sense to me. The usual reason for operating under Part 91 is duty time exceedance, and that can be managed better than is often is.

Devil49 is right about the consequences of circadian rhythm disruption. It can be both insidious and overwhelming, and probably causes many of the accidents that occur in EMS operations. I prefer flying nights all the time to constant switching, especially in the middle of a hitch. Changing over after only a day off is begging for trouble. I have no idea why companies do that.

Having flown several models with flight directors (autopilots) over the years, I think they add much more safety than many people think. They don't degrade flying skills that much, and let the pilot do more than just keep the rotors on top. When you have time to actually think about what is happening it makes things much safer, because you can make better decisions with more time to sort through the relevant information. I'll take a flight director every time if I can get it.

[Devil 49]

Jim L-
Your suggestion regarding ASRS is an action I haven't considered. I'm going to use it and encourage others to do so, as well.
I'll agree there's little use re-inventing the wheel, re:science and duty assignments. I'm ashamed to say, there MUST be a regulatory requirement to drive the application of known science to scheduling, or we won't do it.
As to spatial orientation being a primary cause of night accidents- I'll argue that's only true in the broadest sense. My opinion- The commonest scenario is NO reference and CFIT on departure/approach- the poor slob doesn't even recognize that it's IMC. Also my best guess, the second most common night accident scenario is loss of reference and an attempt to recover with a descent, which is pure and simple suicide through stupidity. Third and fourth are ties- IFR/VFR cruise CFIT. Pick one.
ALL stupid, but stupid's easy when you're mentating as though you'd 3 drinks (or better, that's one result of sleep/circadian disruption); blind; ignorant of conditions; and finally, poorly equipped. Consider, there's NO regulatory requirement for a directable searchlight to do night scenes (that's "off airport" work) in the US...
As to why the industry "splits shifts", flipping from days to night duty mid-week with 24 hours off, it's easy- Look at a calendar. Between days and months, there's one unit of measure- a week. We'd rather have a schedule that "fits" that habitual unit than an odd schedule, starting on varying days. Final factor, some guys can't do 7 nights in a row. Michelle North of the "Wisdom Well" used to preach it, and I've seen that, too.
Fix the problems that'll kill me tonight:
Pilot error- That'll do you, single/twin, IFR/VFR, 121/135/91, day/night, off airport or on;
WX data to my Garmins;
And, NVGs!!! which are coming, but twenty years too slow.

[havoc]

I found this interesting in that I agree with the main points of the Senate Bill except the CVR thing but I guess AAMS has effective alternatives.


AAMS MEMBER ALERT-
HEMS SAFETY PROPOSAL IN SENATE FAA REAUTHORIZATION BILL
Upon reviewing the recently proposed Senate bill for the reauthorization of the FAA, the “Aviation Investment and Modernization Act of 2007” or S. 1300, AAMS found a section devoted entirely to helicopter emergency medical services (HEMS) safety. This section, referred to in the bill as Section 508, Increasing Safety for Helicopter Emergency Medical Service Operations directs the FAA to enact a plan, within 60 days from the enactment of the Act, to require HEMS operations to:
1.) Comply with Part 135 regulations on all flights in which medical crewmembers are on board.
2.) Comply with a standardized Risk Assessment checklist based on Notice 8000.301.
3.) Comply with an FAA standardized “flight dispatch” program based on Part 121 regulations.
4.) Require that all aircraft ordered or purchased after the date of the enactment of the Act be equipped with helicopter terrain alert warning systems, or H-TAWS.
5.) Equip all HEMS aircraft with Cockpit Voice Recorder /Cockpit Data Recorder (CVR/CDR) within 2 years.
The full text of the bill is available on the Library of Congress website http://thomas.loc.gov/ and entering the bill number, S. 1300 in the search line. The bill will also be made available on the government relations portion of the website, along with supporting information, in the coming days.
These requirements are precisely, except for the CVR/CDR provision, the safety recommendations made by the NTSB last year. A copy of the AAMS response to those recommendations is available on the AAMS website at www.aams.org. In that response, AAMS made clear its position against these proposals, while maintaining a commitment to safety and suggesting numerous more effective safety alternatives.
This bill was introduced by Senator Rockefeller of West Virginia and is co-sponsored by Senators Lott of MS, Inouye of HI, and Stevens of AK. AAMS is currently scheduling meetings with these Senate offices in order to develop an understanding among Senate staff of the cost, implications, and unintended consequences of these proposals. AAMS is also drafting a response to this proposal and is considering offering alternatives to these proposals based on the AAMS legislative agenda. Both the AAMS Government Relations Committee and the AAMS Safety Committee have been alerted to this situation since the bill was released and are working to resolve the issue.
As this bill progresses through the Senate Commerce, Science, and Transportation Committee and the Subcommittee on Aviation Operations, Safety, and Security, AAMS will keep the membership informed and call upon members for grassroots support. Please refer to the government relations portion of the AAMS website for more information on the AAMS response to the NTSB recommendations, the AAMS Congressional issue papers, and more information on this proposal.
Thank you,
Christopher Eastlee
Government Relations Manager
Association of Air Medical Services