A response to the list above from the FAA recommendations with some thoughts based only my opinion (knowing that opinions are like arseholes - everyone has one!) and tempered with my limited experience:
1. Fit Helicopter Terrain Awareness and Warning Systems (HTAWS).
Agree with inference of terrain awareness systems, but do not agree with common manifestations of HTAWS such as EGPWS for HEMS. Aural warning systems work very well for interhospital IFR programs and off shore, but the constant aural warnings from low level operations during primary response missions can be often counter productive. Rather, I would push for visual aides, and preferably for systems that require very little interpretation with little or no false warnings. Check this out from Garmin to see what I am talking about
:
G600 MFD info and an interactive demo here:
G600 demonstration
No interpretation required. Visual. This is the TAWS systems that should be mandated. Well done Garmin!!! Just need the helicopter ceertification to be completed now!!
Add EVIS to this for the ideal cockpit capability..
2. Comment on light-weight aircraft recording systems (LARS).
Agree. Non tamper proof. Tracking systems employed to show track, hieghts and speeds.
3. Conduct operations under Part 135, including flight crew time limitation and rest requirements, when medical personnel are on board.
Agree only if some of the more restrictive Part 135 issues are resolved before mandating requirements. SAR ops to be added to this.
4. Establish operations control centers if they are certificate holders with 10 or more helicopter air ambulances.
Situation dependant upon nature of tasking control.
5. Institute pre-flight risk-analysis programs.
Only agree if this is not a "Pre Take off" risk system where take off is delayed for a game of guesstimating risk values to see if take off is allowed. My experience with this is that invariably (yep, that is invariably) the numbers or ratings or whatever are just altered until take off is permitted, meanwhile take off is delayed and brain power diverted from building Situational Awarenss. I agree however that a comprehensive risk management system is implemented considering missions and implementing controls well before the phone call comes.
6. Conduct safety briefings for medical personnel.
There are really operations out there that do not brief the crews???
7. Amend their operational requirements to include Visual Flight Rules (VFR) weather minimums, Instrument Flight Rules (IFR) operations at airports/heliports without weather reporting, procedures for VFR approaches, and VFR flight planning.
There are really operations out there that have not established such things?
8. Ensure their pilots in command hold an instrument rating.
Agree. Regardless of terrain and environment precluding IFR use, the skill sets provide a coping mechanism for all sorts of unexpected situations: NVG failures, lighting failures, dust out, white out, as well as IIMC. I also personnaly believe that an IFR rating should be required to fly patients at night - even where flown under VFR.
And I have added a few extras as per previous posts:
9. Operate PC2 compliant.
10. Comply with EASA rule of two upfront - either two pilots or pilot plus HEMS Crewmember meeting specified aviation course.
11. Ban unaided HEMS/SAR
12. Conduct NVG primary response only when trauma rates require it, geography and equipment levels translate into low road coverage by ground responders, and where helicopter brings demonstrably higher medical care levels than those deployed by ground.
13. Proper CRM training for ALL crew (including medical crew on board).
14. Never going to happen in the USA: HEMS operators run by NGO with strict and policed governance guidelines and protocols.
