Originally Posted by
JimEli
Compliance with 135.607 would be met by an FDR-like system installed and recording on the helicopter.
Unfortunately, after the date of the final ruling the FAA released it's guidance to enforce that ruling. Here are excerpts from the 2 most referenced. As I've been involved in the install of a number of these units, I can vouch that while most do include additional data, none in my experience reach anything close to "FDR-like" levels as it is at the discretion of the operator.
FSIMS 8900.1:
VOLUME 4 AIRCRAFT EQUIPMENT AND OPERATIONAL AUTHORIZATIONS
CHAPTER 5 AIR AMBULANCE OPERATIONS
Section 3 Safety Assurance System: Air Ambulance Service Operational Procedures
E. Flight Data Monitoring.
After April 23, 2018, in accordance with § 135.607, all HAAs must be equipped with an FAA-approved Flight Data Monitoring System (FDMS) capable of recording flight performance data. The regulation intentionally does not prescribe retention or use of the FDMS recordings. These decisions are at the discretion of the air ambulance operator.
Beyond the minimum flight performance data stated below, the type and frequency of data recorded is at the discretion of the operator. The current edition of AC 27-1 MG 6, Miscellaneous Guidance (MG) for Emergency Medical Service (EMS) Systems Installations, suggests flight data that should be considered for recording; however, this is a recommendation, not a requirement. The minimum requirements are:
· The FDMS must receive electrical power from the bus that provides the maximum reliability for operation without jeopardizing service to essential or emergency loads.
· The FDMS must be operated from the application of electrical power before takeoff until the removal of electrical power after termination of flight.
· FAA approval will be granted to an FDMS which has the capability of recording flight performance data including,
at a minimum, altitude (mean sea level (MSL)), time/date of sampling with a minimum sampling rate of one record per second, and sufficient memory to record an entire flight. The FDMS must also be installed securely and must be powered as stated above in the regulation. The installation must be approved under the authority of a Supplemental Type Certificate (STC), an engineering review conducted by the Aircraft Evaluation Group (AEG), or a field approval.
AC No: 135-14B
c. FDMS Capable of Recording Flight Performance Data. To meet the requirements of § 135.607, the operator must install an FAA-approved FDMS in each HAA. In this context, “approved FDMS” means only that the installed FDMS be capable of recording “flight performance data”
including at minimum: Latitude, Longitude, Barometric Altitude, and Date/time of recording, once per second and have sufficient memory to retain these data over 4 hours of flight time. The FDMS is approved by Supplemental Type Certificate (STC), design review, or field approval, depending upon the complexity of the installation, the interface between the FDMS and other systems installed aboard the aircraft, and that it poses no hazard to other onboard equipment, nor any hazard to occupants. Beyond the minimum parameters, additional parameters recorded by the FDMS are at the discretion of the operator. Retention and use of recorded data is also at the discretion of the Operator. The FDMS requirement becomes effective on April 23, 2018.
The FDMS is not to be confused with a flight data recorder (FDR) certified under § 27.1459, though an FDR would be acceptable to meet the FDMS requirement.