Brainstorming HEMS

[JimL]

Helmet Fire,

It is clear what you are attempting to do but changing the culture by (pseudo) enforcement of an existing system is probably not the best approach. What might be required is to break out the various elements of the existing IFR system into its constituent parts to see what might be usefully employed. If you examine the ICAO Rules of the Air you will see that they are almost exclusively procedural - i.e. fly at a minimum level that achieves obstacle clearance; comply with the ATS system; when not within the ATS system (class G) fly at the correct quadrantal, submit a flight plan, maintain communication and give position reports. Only the first rule - that the aircraft should be adequately equipped with instruments and navaids - is outside the procedural approach. For those reasons, I agreed with Gomer that a wholesale application of the IFR system was not appropriate.

As is clear to most observers, there is a need for a culture change; however, this is made extremely difficult by the business (and political) model that is employed in some States. For the US, the FAA, although wishing to solve the problem, appear not to be able to modifiy FARs and therefore have to resort to exhortation and the provision of guidance. However, there has been a change of tack recently and the FAA have used the OpSpec method of enforcing more appropriate weather limits and departure criteria. Industry have contributed to the discussion of amendment to the OpSpec and their representatives have endorsed the changes. (We will have to see how this revision of the OpSpec plays out.)

One of the main problems that we face is that helicopters are intrinsically unstable. Without improvement in the basic handling qualities (usually provided by control augmentation), helicopters become progressively uncontrollable as the visual cue environment degrades. This is not so for fixed wing, and is the reason why they can be certificated for flight on instruments without the additional (handling quality) requirements that are contained in Appendix B of Parts 27/29. This is particularly an issue when flying at night; although the above codes do specify that flight at night/in IMC does require additional attention, it does not appear that additional rules are specified for flight at night. In fact, it is slightly worse than that because flight in daylight with a degraded visual-cue environment (DVE) is also problematical (but not when the weather limits are observed). For a reason which I have not yet fathomed, accidents that result from these circumstances are still categorised as CFIT when, clearly, control has been lost (perhaps the first thing that needs to be addressed).

What will not improve this situation (unless accompanied by an enhancement of handling qualities) is the addition of sophisticated synthetic vision systems (SVS) or enhanced vision systems (EVS) into the cockpit. Whilst SVS might have prevented the recent accident - where there was a flight into mast wires - it will do nothing for loss of control due to DVE. (Look to the discussion of the addition of GPS to the cockpit and the probable effects on safety.) If obstacles cannot be seen and avoided, then the flight is probably not being conducted under Visual Flight Rules.

Crewing is another issue; although HEMS can be undertaken single pilot, we, in Europe, have implemented a system where the second pilot seat has to be occupied (it is the primary role of the Hems Crew Member (HCM) to assist the pilot; it is this requirement that forces the necessity for adequate aircraft and not just performance - hence the replacement of the 'squirrel' in most European States). There is also a basic rule that, at night, there should be two pilots (although that can be alleviated for local operations - generally accepted to be 20-25nm where there is good cultural lighting). However, the latest HEMS twins are equipped for SPIFR and do not (necessarily) have a full two-pilot panel. There is also a (licensing) rule that requires one of the pilots to have an ATPL when two pilots are required by 'certification' or an 'operational' rule (this is way above the ICAO Standards). In the recent past, the ATPL has been a licence with an IR requirement - thus making the two-pilot rule very expensive.

So far this has been negative and, apart from the mention of improvement in the OpSpecs, doesn't provide many positive messages. However, the first part of the provision of any solution is to really understand the problem (and is the reason why the research being undertaken by the JHSAT was mentioned earlier).

There is no magic bullet but, If I were asked to provide a list of elements that might improve the HEMS accident record, these might be some:

1. Pilots should be educated on the dangers of not observing the weather limits for VFR.
2. Where the operation is such that reduced visibility/cloud-ceiling may be encountered (and in any case at night), the helicopter should meet the stability requirements of Appendix B to Parts 27/29.
3. The European rule for two-up-front should be adopted (and enforced) - any downgrading to one should result in the filing of a discretionary report.
4. The HCM should be regarded as a crew members and receive appropriate training and checking.
5. Every HEMS helicopter should be equipped with a full panel for at least the P1.
6. Every HEMS helicopter should be equipped for SBAS or GBAS.
7. Every HEMS pilot should be trained and checked for flight in IMC (without the procedural elements) - this should include three monthly refresher training.
8. All HEMS flights that include a landing at a HEMS Operating Site (scene) at night should be NVIS equipped (scene flights without NVIS should be prohibited)
9. All HEMS post holders should attend a HEMS management course (run by industry) and be accredited - this should a requirement under provisions of the AOC.
10. All HEMS operators should provide evidence that they meet the minimum requirements for performance and operations establish by the State.
11. HEMS operations should have appropriately constructed flight and duty times schemes (standby duties should receive appropriate treatment - i.e. not necessarily counted as full time).
12. HEMS operations should require a specific approval.

EASA have recently proposed an Operational Suitability Certificate to include a number of the elements mentioned above; although not yet published, it is expected next week. HEMS is a prime candidate for the application of such a certificate.

Jim