I think that treating HEMS/air ambulance as public transport ops is fraught with danger; if exceptions cannot be made for the immediate saving of life then what next. When SAR ends up in civilian hands will we not be allowed to rescue people because we cannot guarantee to be safe single engine while we winch them in? It is a question of balancing risk against benefit and unfortunately there are many for whom the risk of litigation greatly outweighs the benefit of saving lives. The HSE started out as a good idea to improve safety in the workplace but has become just another very complicated layer of bureaucracy to make getting difficult jobs done almost impossible.