EMS under-slung rescue question

[BigMike]

A question for EMS operators flying under JAR rules. Does anyone use crew on the end of a strop to rescue someone from an inaccessible area? The 2 "private" EMS operators in Czech, who have used this method for a long time, are about to have there approval pulled by the local CAA. This is something that we rarely do, but train for if needed.

[alouette]

An approval pulled because of fixed rope evacuations?!? As far as I know the OAMTC in Austria is the specialist for fixed rope operations HEMS wise. What went wrong in the Czech Republic?:confused:

[tecpilot]

BigMike,

in JAA words "HHEC" (Helicopter Human External Cargo) it's a part of my job under JAA guidelines. Feel free to ask anything you want.
http://img.photobucket.com/albums/v674/tecpi/r-1.jpg

For the first, if short-haul is part of your operation you need in any case an approval including operating and training manual.
In the past some CAA's had different ways to accept or better ignore such flights.

Airshow Hradec Kralove?

[Thomas coupling]

Not allowed in the UK

[tecpilot]

TC, why it isn't allowed?

You can have a complete and JAA aproved Kit by EC for your police ships.

[BigMike]

Hi Tecpilot. Yes we have operating and training manuals for this, but they have now decided JAR rules don't allow it?! Any info on your operation and procedures would be welcome. I'm new to the Euro rules and regs. The OPs manager threw this task to me yesterday!

Yep, the Hradec Kralove show was interesting. The authority was all smiles there.

BigMike

[JimL]

I'm not sure that you are correct in stating that JAR operational rules prevent this type of operation. JAR-OPS 3 provides the regulations for Commercial Air Transport (CAT), it does not provide for Aerial Work (AW) or Seach and Rescue (SAR - when these are not considered to be AW).

The same is true of ICAO Annex 6 which provides the Standards and Recommended Practices for CAT and General Aviation - but not AW (or SAR).

In fact when we were drafting operational rules for AW (JAR-OPS 4), it was considered that there was such a diversity of SAR in the member States that to provide a single set of regulations covering those operations would be difficult-to-impossible and there was a recommendation that both SAR and Fire Fighting be left to individual States to regulate.

It is clear that for some type of cliff face incidents, the only rescue method available is the long rope. Provided the procedures, and equipment, meet the highest possible standard, there is no reason why these operations cannot be envisaged; the alternative would be to countenance death (or a dangerous ground led rescue) when a perfectly good and well demonstrated method of helicopter rescue is available.

However as was stated at the start of this post, this should be regarded as SAR and not as HEMS and therefore outside the scope of Commercial Air Transport regulations.

Jim

[SASless]

JimL....

That begs the question....if a recognized EMS provider engages in Short Haul ops....when does one cross the line between EMS and SAR? Do "scene" pickups constitute SAR ops? If not....does doing a remote area pickup of an injured mountain climber remain EMS or is that considered SAR if conventional means of retrieval not fit the situation? Can an EMS operator conduct SAR operations?:confused:

Remember the man trapped on top of a construction crane in Atlanta, Georgia.....raging fire around the crane....crane bound to be destroyed....certain death for the trapped man.....along comes the Fire Brigade....short haulled a firefighter to the victim....and saved the guy.

No training...no protocols....no practice....complete ignoring of all the rules...regs.....but one more of us still alive because a helicopter pilot and fire fighter were capable of doing the job based upon experience and skill and ignored the risks to themselves.

Second question.....do we legislate away these humanitarian acts by force of regulation?

http://www.cnn.com/US/9904/12/atlanta.mill.fire/

[tecpilot]

As JimL wrote

i believe BigMike you are operating under JAR-OPS3? Some years ago some wise guys at the JAA decided to describe HHEC under JAR-OPS 4 and not under JAR-OPS 3. Nobody knows if we will see JAR-OPS 4 in the future. My personally opinion is "NO".

Therefore the HHEC regulations are not described by JAA at the moment.

In the later amd. to JAR-OPS 3 we find the HHO (Helicopter Hoist Operation) section. I'm not sure which amd is in law in Czech?

But you can try to find an arrangement with your CAA to fly HHEC in the same way as described on HHO. Means crew qualification, training, competency check, current times,...

Be sure your equipment fullfills the requirements on JAR/FAR 27/29.865 and .303 Altogether you need a safety factor of at least 5,0! with the needed papers to all components including textile components. Don't forget that a normal external load hook is normally only certified to 2,5.
An other way is to bring the "Code of Practice" JAR-OPS 4 on the table. But this paper isn't in law and only a guide.

Some countries have due to the lacking JAR-OPS 4 now their own fresh regulations. Switzerland as example. If possible don't go to this rules, because Switzerland is full of extremly high experienced longline pilots and in the other countries there are not so many pilots could fullfill the switzerland requirements. You need many flight hours, many load cycles to qualify to HHEC in Switzerland.

As SASLESS wrote, where is the frontier between HEMS and SAR? I cannot find the difference and i couldn't understand that a HEMS operator normally at first at accident scene should be wait for the next SAR a/c because the JAA and some CAA's couldn't find a way to certify the operator. HHEC is a difficult business but it is to handle.

In case like the atlanta incident there is anyway no need and no time to ask the next authority, just to try to save a life!

[BigMike]

Hi Tecpilot. Thanks. Yes we operate under JAR OPS-3 as a HEMS organisation. What are the JAA guidelines your operation uses? The ones mentioned, or do you have a special arrangement with your authority? Any info on your equipment, training etc, would be appreciated.

PM me if you like.

Cheers BigMike

[JimL]

tecpilot,

It might be of use if we can examine what the various regimes were supposed to achieve: JAR-OPS 3 was only intended to provide regulations for CAT.

JAR-OPS 0 (or general) was intended to provide baseline regulations - i.e. General Aviation (both fixed wing and rotary), eventually CAT, and AW.

JAR-OPS 2 was intended for Corporate Aviation (business aviation would have been dealt with in JAR-OPS 0).

JAR-OPS 4 was for AW (once again both fixed wing and rotary).JAR-OPS 3 has no preconceived view on Heli-Hoist work and provides regulations only for CAT operations. If those CAT operations are undertaken with the use of a hoist then they must be conducted within the requirements of JAR-OPS 3 as amended by the HHO Appendix. The exception to this is that if heli-hoist is used at a HEMS Operating Site the requirements for OEI HOGE performance are waived (as are all other performance requirements at that site).

Similarly, JAR-OPS 4 (in its draft form as published for NPA) also had no preconceived view on HEC and only provided the base line regulations. Where there might be confusion is that JAR-OPS 4 made no attempt to describe every AW activity (wisely) but provided a mechanism by which such operations could be described and conducted. As you have rightly pointed out, this was the 'Code of Practice'. The draft contained the framework for the provision of 'Codes' but went no further; it was expected that industry would populate such codes and then provide them as 'best industry practice' - before JAR-OPS 4 became a requirement.

Now whether an operation is CAT or AW or SAR is either in accordance with the definition contained in JAR-OPS, by custom and practice, or prescribed by the State. In accordance with ICAO and JARs, European States require AOCs for CAT, some have a lighter form of AOCs (or AWC) for Aerial Work and a number have the requirement for Approval for SAR operations.

It is therefore within the State's gift to decide whether and how SAR can be conducted and what type of approval is required. For maritime States, the provision of SAR is part of the ICAO obligation and will be well described and regulated. Where there might be confusion is when SAR is conducted inland - and most likely in mountainous regions. In a number of States, this mountain rescue is also well described and regulated, and formal Approval is required.

Because the cost of operating helicopters is relatively high, it is not unusual for an operator to have CAT and AW approval (and in some well known cases like Bristow Helicopters CAT, AW and SAR). What is unusual is for a HEMS operator, with his specialist role and equipment, to stray into other territories. That is not to say that, if presented with a well argued case, an Authority would not provide approval for 'short haul' or long rope rescue under the umbrella of AW or SAR - for a HEMS operator. As tecpilot has indicated, a kit meeting the requirements of JAR 27/29 in respect of HEC together with operational procedures to provide a JAR-OPS 3 equivalent safety for crew members and casualty (operational procedures, training & checking, equipment standards and MELs) would be a good starting point.

Most States regulations provide a force majeur clause for incidents such as that provided by SASLess. Attempting to write regulations for such as those will always defeat the regulator as their scope can never be encompassed in a simple text.

Jim

[tecpilot]

JimL

You are right. The problem is that BigJim is operating under JAR-OPS 3 as a HEMS Operator. I don't know if his company is also active on "outside" JAR-OPS 3 operations. Because HHEC isn't described in OPS 3 the operator and his CAA have to find a way to certify HHEC operations. Some countries in Europe still operating under OPS 3 amd. 1 and in amd. 1 you can't find HHO. In this countries the HEMS operators have the same problem with hoist operations. That's the situation in Germany as example. The HEMS hoist operators are certified to hoist work but completely different to HHO because HHO doesn't exist in german law. But on the other side the german CAA have accepted the "not in law" HHO section plus a mix of "Code of practice" OPS 4 as basic rule to certify an other german HEMS operator to HHEC. :confused: :confused:
I don't know on which amd. Czech operators have to work.
If they have the HHO section, it's a good way to deal with the CAA.
If operating under rules without HHO and HHEC the situation is difficult.
I'm on your side that a HEMS operator works usually within the area of his own CAA. Therefore it's possible to find national ways. But also some austrian HEMS ships doing sometimes HHEC in Germany on austrian rules.
Unfortunately due to the lacking papers on JAA level we find the situation that years after implementing JAR's nearly every country will go his own way on this kind of tricky operation.
There is therefore no golden way to deal with the CAA, only possibilities.
May be the Czech CAA is ready to accept a way found in other Countries?

Eurocopter offers with the double hook system EC 135, supplement 9.2-47 a technical system HHEC conform. But it's only the technical part and EC is right to write under "Limitations":
"HEC operations with the "Double Hook Beam" require special training for the involved personal and shall not be conducted without approval by the responsible authority in accordance with national operations regulations".

[GenuineHoverBug]

I know one authority has decided that under-slung medic/doctor is generally not allowed, as the equipment involved (ropes, fasteners etc) used, does not have an airworthiness certification/approval (as is the case with a hoist).

But probably realising that formalities should not get in the way of common sense, the same authority has stated in writing to the operators that it has no objection to such an operation, when performed only exceptionally, over short distances when no other means of getting to/assisting the person in distress is readily available and time is critical for the person’s life and health. These are conditions that are borderline to "force majeur", but at least the authority does not turn a blind eye, or stop it.
Use of the procedure requires the operator to have an adequate SOP, proper training, a system for maintaining the non certified equipment and a reporting system to monitor the use. (And -probably due to someone showing off, it also states that the procedure is not allowed for display purposes.) It is categorised as SAR, and not HEMS.

I believe the definition states that HEMS as such, only involves the transportation part. If other measures are required, such as hoisting, under-slung rescue, it probably turns into something else. You would then need an SOP and the proper training and equipment, and your authority might allow you to do it, or at least turn a half open eye to you.

[Oogle]

BigMike

Throw a winch on your aircraft and be done with it. This underslung stuff looks a bit scary to me.

I assume you only do it if there is not a long transit of the survivor required otherwise they would turn into an ice block.

[Thomas coupling]

Things could change though. Maybe not for JAR Ops operators (poor souls!) but for us nationally operated a/c (police) the fitting of a winch for reasons other than HEMS is now being challenged where the police officer onboard will not need to be a crew member.

[SASless]

Anything prevent you from training up Plod and calling him a "crewmember"?

[BigMike]

Thanks very much for the replies and PM's. Hopefully we can work something out with the authority. As I said, we rarely do this as the Czech Police, and Military have winch equipped machines for this purpose, but there have been times when we were "it". I hope common sense prevails.

Cheers BigMike