NTSB Hearing on Most Wanted: Improve the Safety of EMS Flights

[zalt]

This seems to deserve a thread in itself. A public hearing is due next month: NTSB - Safety of Helicopter Emergency Medical Services (HEMS) Operations (http://www.ntsb.gov/events/Hearing-HEMS/default.htm)

The NTSB statement on their most wanted (with my underlined emphasis) is below:


EMS aviation operations (conducted with either helicopters or fixed-wing aircraft) provide an important service to the public by transporting seriously ill patients or donor organs to emergency care facilities. The pressure to quickly conduct these operations in various environmental conditions (for example, in inclement weather, at night, and at unfamiliar landing sites for helicopter operations) continues to result in an increasing number of accidents.

Although the Safety Board issued recommendations in 2006 to improve EMS helicopter operations safety, 9 fatal helicopter EMS (HEMS) accidents occurred between December 2007 and October 2008, killing 35 people.


December 3, 2007: Whittier, Alaska – BK117
December 30, 2007: Cherokee, Alabama – Bell 206
February 5, 2008: South Padre Island, Texas – AS350
May 10, 2008: La Crosse, Wisconsin – EC135
June 8, 2008: Huntsville, Texas – Bell 407
June 29, 2008: Flagstaff, Arizona – Bell 407s
August 31, 2008: Greensburg, Indiana – Bell 206
September 28, 2008: District Heights, Maryland – AS365
October 15, 2008: Aurora, Illinois – Bell 222


The Safety Board is concerned that these types of accidents will continue to occur if a concerted effort is not made to improve the safety of emergency medical flights.

Specifically, the following actions would help to improve the safety of EMS flight operations:
(1) implementation of a flight risk evaluation program for EMS operators,
(2) establishment of formalized dispatch and flight-following procedures including up-to-date weather regulations,
(3) installation of terrain awareness and warning systems on aircraft, and
(4) conduct of all flights with medical personnel on board in accordance with stricter commuter aircraft regulations.


Summary of Action
In August 2004, the Federal Aviation Administration (FAA) convened a Helicopter Air Ambulance Accident Task Force to make recommendations to reduce HEMS accidents; however, in spite of numerous actions to address this issue through notices and guidance, little progress has been made by the FAA in improving the safety of EMS operations.

In 2005, the FAA issued three notices addressing HEMS safety; however, all three of the following notices expired after 1 year:

Notice N8000.293, “HEMS Operations,” contained information that FAA inspectors could provide to HEMS operators “for a review of pilot and mechanic decision-making skill, procedural adherence, and crew resource management.”
Notice N8000.301, “Operational Risk Assessment Programs for HEMS,” identified possible risks and dangers to flight crews and patients and encouraged aircraft EMS operators to promote the use of risk assessment models. The contents of N8000.301 have since been incorporated into Order 8900.1.
Notice N8000.307, “Special Emphasis Inspection Program for HEMS,” provided guidance to aviation safety inspectors for the examination of operational factors that were indentified as causal to EMS accidents such as operational control, safety culture development, and access to and use of weather information by flight crews, management, and in-flight communications specialists. (1)


In January 2006, the FAA issued revised guidance to inspectors regarding HEMS Operations Specifications (OpSpecs), amending the visual flight rule (VFR) weather requirements for HEMS operations, including consideration of the adverse affects of reduced ambient lighting at night and mountainous terrain (HBAT 06-01 Helicopter Emergency Services; OpSpec A021/A002 Revisions).



In January 2006, the Safety Board issued four safety recommendations concerning EMS flight safety. In June 2006, at the FAA’s request, the Radio Technical Commission for Aeronautics (RTCA) established a special committee to develop Helicopter TAWS (H-TAWS) standards. The RTCA, in March 2008, completed the development of a set of minimum operational performance standards for H-TAWS. The FAA anticipates publishing in early 2009 a Technical Standards Order that is based on the RTCA standards. The FAA will still need to consider rulemaking to require H-TAWS on EMS flights.



In August 2006, the FAA revised the Aeronautical Information Manual to provide guidance to pilots on assessing ambient lighting for night VFR operations and for off-airport/heliport landing zone operations.

Most recently, in May 2008, the FAA published Advisory Circular (AC) 120-96 regarding operations control centers (OCCs) for HEMS. The AC provides a list of tasks that should be completed by OCCs. Although the AC is responsive to Safety Recommendation A-06-14, the FAA has not yet incorporated a requirement for an OCC into HEMS regulations.

Despite the FAA’s efforts to improve EMS operations safety, the FAA has not imposed any requirements on aircraft EMS operators regarding flights conducted without patients on board, risk management, flight dispatch, or the use of such technology as TAWS or H-TAWS.

The FAA’s published notices simply constitute information that principle operations inspectors may provide to their operators and encourage the operators to incorporate.

The Safety Board concluded in its 2006 report (2) that the implementation of a flight risk evaluation before each mission, such as the action Notice N8000.301 proposed, would enhance the safety of EMS operations. N8000.301 expired in 2006; however, its contents were incorporated into FAA Order 8900.1. This inclusion was a positive step; however, the FAA still does not require EMS operators to take the actions recommended by the Board. The guidance provided by the FAA has not been widely adopted by EMS operators; accordingly, the Board is concerned that until the FAA institutes our recommended requirements, some EMS operators will continue to operate in an unsafe manner, which could lead to further accidents.



Actions Remaining

Require all EMS operators to comply with 14 Code of Federal Regulations Part 135 operations specifications during the conduct of all flights with medical personnel on board.

Require all EMS operators to develop and implement flight risk evaluation programs that include training all employees involved in the operation, procedures that support the systematic evaluation of flight risks, and consultation with others trained in EMS flight operations if the risks reach a predefined level.

Require EMS operators to use formalized dispatch and flight-following procedures that include up-to-date weather information and assistance in flight risk assessment decisions.

Require EMS operators to install terrain awareness and warning systems on their aircraft and to provide adequate training to ensure that flight crews are capable of using the systems to safely conduct EMS operations.



Safety Recommendations
A-06-12 (FAA)
Issued: February 7, 2006
Added to the Most Wanted List: 2008
Status: Open—Unacceptable Response
Require all EMS operators to comply with 14 Code of Federal Regulations Part 135 operations specifications during the conduct of all flights with medical personnel on board. (Source: Special Investigation Report on Emergency Medical Services Operations.
[NTSB/SIR-06/01])


A-06-13 (FAA)
Issued: February 7, 2006
Added to the Most Wanted List: 2008
Status: Open—Unacceptable Response
Require all EMS operators to develop and implement flight risk evaluation programs that include training all employees involved in the operation, procedures that support the systematic evaluation of flight risks, and consultation with others trained in EMS flight operations if the risks reach a predefined level. (Source: Special Investigation Report on Emergency Medical Services Operations. [NTSB/SIR-06/01])



A-06-14 (FAA)
Issued: February 7, 2006
Added to the Most Wanted List: 2008
Status: Open—Acceptable Response
Require EMS operators to use formalized dispatch and flight-following procedures that include up-to-date weather information and assistance in flight risk assessment decisions. (Source: Special Investigation Report on Emergency Medical Services Operations. [NTSB/SIR-06/01])



A-06-15 (FAA)
Issued: February 7, 2006
Added to the Most Wanted List: 2008
Status: Open—Unacceptable Response
Require EMS operators to install terrain awareness and warning systems on their aircraft and to provide adequate training to ensure that flight crews are capable of using the systems to safely conduct EMS operations. (Source: Special Investigation Report on Emergency Medical Services Operations. [NTSB/SIR-06/01])





October 2008


National Transportation Safety Board, Special Investigation Report on Emergency Medical Services Operations (NTSB/SIR-06/01) (Washington, D.C.: NTSB, 2006).
National Transportation Safety Board, Special Investigation Report on Emergency Medical Services Operations (NTSB/SIR-06/01) (Washington, D.C.: NTSB, 2006).

[Foggy Bottom]

In my opinion the only way to solve this problem is to make the direct managers much more personally responsible for the actions of their crews. If it can be shown that the pilot of the Evergreen aircraft (just an example, not meant to single this one accident out) was not properly trained in the use of NVG's, and that he was expected to use the NVG's then pull the Chief Pilots certificate for at least one year. Pull the DO's certificate for at least 6 months, AND do not allow him to act as a DO or any managment position for any certificate holder for one year. Do something this simple and you would be amazed at how fast training programs are brought up to date and oversight becomes commonplace. Hit managment in the wallet and things change!!

You can require any equipment combinations that you can imagine but if decision making is not enforced, if "get it done" attitudes are the norm, preventable accidents will continue to occur with regularity.

[alouette3]

This is a turf war between the NTSB and the FAA. If Moses had held hearings and committee meetings the Israelites would still be in Egypt.
'Nuff said.

Alt3

[zalt]

Well EMS the accident record makes BOTH the FAA AND the NTSB look bad. no doubt they will be keen to make each other look ineffective or unrealistic.

[Revolutionary]

Here's an improvement:

Reduce the number of EMS aircraft from the current (ridiculous) number of, what, 800? to something like 200, strategically placed aircraft that are not in competition with each other to fly every flippin' ankle fracture but are only used when there's a real medical need.

Et voila! Accident rate cut by 75 percent.

[Gomer Pylot]

Or just eliminate all of them and reduce the accident rate to zero. :rolleyes:

[Revolutionary]

Gomer, if you think I'm joking -I'm not.

The accident rate in the US -in absolute terms- is at least partially a function of the high number of hours flown, not just a function of poorer training or less capable aircraft in comparison to, say, Europe. In fact I'm willing to bet that in relative terms the accident rate of European night and day VFR EMS aircraft per flight hour is about on a par with the American rate.

Any EMS program worldwide can benefit from improved training; EGPWS; NVG; Radalt; TAWS etc. etc. I mean, duh!

But any kind of comprehensive review of EMS safety has to include a good long look at the way the entire EMS helicopter system is structured, and the way this structure contributes to dozens and dozens of helicopters being in the air every day at all hours, flying everything from traumatic amputations to bruised ankles.

Hell, maybe we'll collectively conclude that having 800 EMS helicopters is worth it in terms of reduced mortality rates of patients flown versus patients transported by road. But if that's the conclusion then maybe we should just accept the occasional accident and shut up about it.

[SASless]

Foggy hits the nail on the head....do the senior management attend the funerals even?



Perhaps we should just shut up and get on with the job....after all you cannot be a hero if no one is dying!

I am like Will Rogers....."We can't all be Heroes....someone has to sit on the curb and applaud as they parade by!"

[WhirlwindIII]

SASless

Yes, senior management do attend funerals - no idea how many, but I've fortunately/unfortunately seen it. For what reason/s other than to limit legal exposure would be a rather cynical viewpoint, but it does come to mind, and what is taught to possibly minimize operator financial liability.

Amazing how everyone these days is a hero - I've only met one real such person in my lifetime. The rest of them were just doing their job! I think this hero stuff is just a fascination with adrenalin.

Accountability is a big deal, the more the merrier, in the direction of the shakers who put the movers in harm's way.

Seems we have exercised the heads-down approach to fixing HEMS for far too long - you know, all the IHST, FAA, NTSB, HAI and voluntary operator sponsored bandaids, etc.

How about the tails-up approach - i.e. how many tails are wagging the pilot-dog to do flights that shouldn't be done? How many flights are taken that don't hardly qualify for an ambulance because the first responders on-scene want to dump the patient on to a helo crew so the former can get back to barracks and off for the day? Don't think it doesn't happen? Do the homework. How many flights actually reduce mortaility or morbidity? I bet the numbers would be a shocker, excepting possibly in the cost of morbidity category and timely transport to a surgeon with an open operating room. How many pilots do flights because they really don't want to get that nagging email from the boss pointing out his/her status as the operation's pilot with the lowest completion rate? How about the pilot who has maintenance up his tail pipe every time he writes up a discrepancy so the straw breaks an off he/she goes with a defective AHRS in to a black hole. And on it goes with the things HEMS pilots have in the back of their minds just prior to saying yes, or no, to that ill-fated flight.

WIII

[JimL]

The accident rate is not altered by removing operations only the number of accidents. When someone provides the accident rate, we can start to compare it to other world-wide figures.

It is a commonly held view that removing the night operations (at least those unaided) would reduce the accident rate.

Applying a realistic dispatch criteria might also reduce the accident rate.

However, all that is speculation until the JHSAT provides the analysis that can pinpoint the specific type/area of operations that results in unacceptable risk. Problem is that most accidents/incidents have a chain of causal links - some of which are complex and which may lay dormant for months or even years.

Most of what has been discussed here (and on other threads) points to a cultural issue which can only be addressed once there is acceptance that there is a problem.

Jim

[WhirlwindIII]

JimL

Agree, and thanks for the input.

It is amazing to watch a group of people within a HEMS culture when the subjective light bulb goes on (their point of recognition and acceptance they had a problem) concerning some macro type practice they had faith in which is proven incomplete, wrong, or not applicable, etc.

There is a certain smugness as to the simplicity of historical success amongst some HEMS cultures (to include first responders on the ground, dispatchers, etc.) operating without an incident or accident for an increasing period of years that grows and becomes more impenetrable right along with their weaknesses - to the point where a problem arises or a magic phrase catches someone's attention within the group. Hopefully it is a phrase that starts things going down safer operating paths.

I watched a HEMS operation practice a culture of avoidance. It was characterized by "don't do this, don't do that, don't, don't, don't" sort of orientation as to what they would or not undertake in flight operations. Their belief was that by doing so all incidents and accidents could be foreseen and would be avoided. What caught their attention was a phrase "you folks haven't scratched the surface of the anxieties available to yourselves in HEMS operations". This led to they wanting to know more about such things similar to your statement "most accidents/incidents have achain of causal links - some of which are complex and which may lay dormant for months or even years". They just never really thought there could be little insidious and slippery time bombs growing in the midst of their history and practices just ready to accumulate and/or align to cause a major problem they would have to deal with, without fail.

After the bulb went on the reviews began, more attention to real world requirements increased, confidence went up, and overall professional results became measureable.

We can be fascinated with technology and potential remedies such as autopilots, EGPWS, night vision, etc., as we are, but it would be far more useful to become fascinated with the frailty of our human systems and intereactions amongst all ourselves from company management, to dispatchers, ground first responders, maintenance, pilots, etc. in HEMS, first, before we take the leap to relying upon more expense and complication of the ever-increasing use of technology in this business.

Horse before the cart sort of thing.

Off box!

WIII

[SASless]

Get back up there WWIII....you are on a pretty good roll there.

My recollection of a point Nick Lappos tried to make that got glossed over in the past discussions we have had on this matter is the one he made about the effectiveness of our training system and the goals it sets out to meet. I agreed with Nick the current system uses a pretty odd matrix of elements that in the past seem not to have made an improvement in the safety record.

That falls right in line with what you are saying about the "human" element needs to be looked at first and in all probability will have the greatest positive effect for postive change.

If we don't know how to use our toys....both switchology and strategy....the toys will be just that and not provide that much benefit.

[Shawn Coyle]

SASless and WWIII:
excellent points. We can all slice and dice the data to fit our own pet peeves (one of mine is autopilots and the lack thereof, and the lack of use thereof when fitted), but we need to really look at the training and information and a whole host of other factors before we start making any major changes.
I've started a series in Vertical about the differences between fixed wing airline operations and helicopters that has led down some unexpected paths. I hope it starts more discussion on the current situation.

[WhirlwindIII]

Shawn and SASless

Paradigm shift comes to mind.

Yes, Nick has an eye for the start and finish of a race, and everything in-between. I bet flying that C/L Ringmaster or the like in many circles at a young age developed vision for completing the circle of effort to finish projects in grand fashion.

I like Toys, they are good. I like HEMS toys too, especially TCAS, EGPWS, Radar, XM-weather, cross talking UNS-1D FMS, or GNS530s in a pinch, and MLS, and SPZ 7600, and dual radalts, Full FADEC, with five full span MFDs, and the nice lady who announces when I'm approaching Vne, or "low height, low height" upon entering a somehwat dark hole at night to pick up a broken arm whilst the med crew announce "STOP STOP STOP" to which I respond "did you say STOP STOP STOP?"

Complex toys in a complex single pilot operating environment like HEMS can be good, but more often coupled to all the FAA matrices of decision making etc., high and low light factors, what the phase of the moon is going to be for the flight, the angle of the dangle of the cultural lighting, coupled to four octas or more inbound mid-altitude cloud layer over the last 1/3rd of the route (oh, bugger, excuse moi, wrong route, gotta start over), chart the route and make sure the very ancient and multiple MEL'd status rotary winged flying machine is X feet above all obstacles, coupled by late in preflight planning the on-scene commander hollering "where the *&^% is the helicopter, call YZX operator and GET ME A CHOPPER", followed by the inevitable med crew adrenalin level (truly an annoying drug) leading to obvious signs of 'get it going, will ya?' type fidgeting communications creating some level of confusion and frustration in Captain I'm An ACE's mental prioritization skills which morphs to the statement "to heck with it, let's get out the door, we'll sort this out enroute (yeah, sure - been there, got the T-shirt) we've got to keep the customer happy" but of course ACE still has to do a few phone calls to security to let them know (as well as every other uncle on the planet) they are out-the-door to do CofG calculations for entry to paperwork, take out heaters, untie the blades, do another walk around to hop in and do the 100 item checklist, sets the stage to encourage the differing layers of safety filtering Swiss cheese coming in to alignment to let the arrow through such that Captain Ace is right next to his/her first or next incident or accident. Any wonder why? Too many fingers in the pie?

The question is, who set up this mess? The shaker or the mover?

Some things are easy, some almost impossible, but focusing on ourselves working together in the field from the bottom up has got to be the start of realizing the solution to our abysmal accident rate in HEMS. It's obvious the route we've been on for the last 30 years, and at present, is just not the primal answer - good effort, no cigar.

With due respect I hope JHSAT and IHSAT or whatever top down approach we are presently pouring our lives in to comes to the same conclusion.

What's that? KISS? Never hear of it. Works everywhere else, especially the airlines, but let's just realize this is HEMS! This is emergency services, and we best be acting like it, so hurry up and get out there and save lives.

Yes, I'm cynical, and disappointed in all this HEMS stuff, but I'll keep plugging and maybe, just maybe, I'll be part of the solution and can then retire in peace.

WIII

[FFF]

On a thread some time back, someone attached a paper by Sidney Dekker about the basic concept of safety.
In simple terms, he suggested that we should not think of flying as inherently safe and that an incident or accident has an active cause, but instead to think that flying is inherently dangerous and in fact it is the systems we adopt that prevent an incident or accident. When the system is not correct, or we do not action the system correctly, then failure has the opportunity to succeed, and we have an incident or accident.(OK, it goes deeper than that, but this message is what I took away from it).

Looking at the HEMS industry from this angle, and reading or listening to the stories about what is happening, it is often clear where the systems adopted are not appropriate to prevent failure from succeeding.

[Gomer Pylot]

The NTSB sometimes issues recommendations without completely thinking them through, ISTM. The one requiring flight above all obstacles is a case in point. It just requires flying above all obstacles, but doesn't say how much lateral distance we have to check for obstacles. Do we have to account for every obstacle in the US, 100 miles on each side, or just the same lateral distance as vertical distance? We have no idea, but we are being required to comply, even though they don't say what we have to comply with. Too often the government, and private companies, just take knee-jerk actions so they can say they did something, whether it makes sense or not.

The TAWS software needs tweaking to be really usable. Bitchin' Betty gets really excited every time I try to land, demanding that I "PULL UP, PULL UP!!" because of terrain, when I know full well terrain is there, and I intend to land on it. Consequently, she gets shut up more than she really should, because everyone gets tired of the unnecessary bitchin'. TAWS is certainly a good idea, but poor implementation means it's not really that much help. Too much stuff really hasn't been thought through from the perspective of the pilot sitting in the seat, and it's just not possible to do this from an office seat, or even from the seat of an aircraft that's doing other things, but that's what we're getting.

[WhirlwindIII]

FFF and Gomer Pylot

Excellent - well put.

WIII

[SASless]

Whirlwind has been there and done that!

The truth that your post contains is way beyond descriptive of the real world of American EMS.

I had flashbacks reading your post!

Gosh....it is beer time already....need to peer into a brown bottle and congratulate myself upon taking up other employment!

[Shawn Coyle]

TAWS / EGPWS has been developed for helicopter use. Blue Hawaiian got their system modified to provide very good information that was suitable for their operation. Not sure if anyone else has ever used that same format.
Why not?
I'm reminded of the comment from the Commanche team about the stated requirement to meet the handling qualities laid out in ADS-33. They said that they would make a helicopter that flew well, regardless of what ADS-33 said.
We need information that is useful to helicopter operations, (regardless of what a spec for TAWS / EGPWS says), that is quick and easy to set up, and gives us the information we need - not what some spec says it should.
But we need to have informed, technically savvy people specify what we should have. Folks who are knowledgeable about what can and should be done. Don't see too many of those around, unfortunately.

[Brian Abraham]

Item from Aviation International News today

HEMS Crash Documents Reveal Varied, Complex Causes
Not surprisingly, there is no “magic bullet” solution to the spate of fatal helicopter emergency medical service (HEMS) crashes over the last two years. Rather, investigation documents, released by the NTSB Press Advisory (http://ntsb.gov/Pressrel/2009/090113b.html) late last week, reveal a complex mosaic of multi-level human and technology failures behind nine of these crashes in the past two years. Page upon page of interviews, transcripts and forms unveil myriad indirect and direct causes, including “helicopter shopping” by dispatchers–when one HEMS company rejected a flight, generally due to weather, they kept dialing until another operator accepted the flight. Other factors include pilots assigned, or voluntarily taking, excessive duty time; pilots flying into marginal weather or below safe performance envelopes; a pilot flying injured; and, in at least one case, a pilot with a vision restriction apparently flying without wearing his glasses. Organizational problems also loom large as at least contributory factors: morale problems; high personnel turnover; maintenance issues; old equipment; failure to install modern safety enhancements such as TCAS, TAWS and NVGs; and instrument-rated pilots flying IFR-equipped helicopters, but not being allowed to fly IFR under the terms of the operator’s Part 135 certificate.

[SASless]

Ah....but by God we have some fancy nomex flight suits and wear spiffy shiny helmets to pose with! Besides....we saving lives Man!

[WhirlwindIII]

Sooner or later (probably MUCH later at the rate things go here in America these days) a shaker in the powers-to-be is going to see through all this hype and get some rationalization going, and/or put the professionalism in to the systems required to interface and deal with HEMS. We can only hope and continue to work on it bit by bit.

[Brian Abraham]

From Aviation International News today.

AAMS Pushes Mandated NVGs, IFR for Helo EMS
The Association of Air Medical Services (AAMS) is recommending the FAA mandate night vision goggles, enhanced vision systems or IFR-only operations for all night flights of EMS helicopters. The recommendations come on the heels of nine fatal helicopter EMS (HEMS) accidents since December 2007 and one week before the NTSB is scheduled to hold what promises to be highly charged public hearings related to those accidents and overall HEMS safety. AAMS also wants the FAA to mandate recording devices and prioritize and accelerate the implementation of Automatic Dependent Surveillance-Broadcast (ADS-B) infrastructure to HEMS operating environments and implementation of associated weather reporting and communications enhancements. The FAA also is encouraged to produce materials for community emergency response services and medical facilities within the operating area of an air medical service to address issues of “helicopter shopping” and study flight crew fatigue factors. AAMS seeks congressional approval to make AIP money available for the construction of HEMS heliports, low-level special IFR-GPS routes and approaches and AWOS at hospital heliports. The association also recommended that all HEMS operations (commercial and government) be conducted under Part 135 and that all operators adopt flight operations quality assurance programs.

[WhirlwindIII]

Having listened to three days of ice melt at the NTSB HEMS hearings I'm still of mind there's little in our future to identify and fix real HEMS problems - too many pseudo-expert fingers in the pie that need to butt out.

It is nice to see all the players in the same room at the same time though.

[Brian Abraham]

there's little in our future to identify and fix real HEMS problems
Interesting to see that in evidence given the Canadians have never had a fatal HEMS accident since beginning operations in 1972. What is it that they do that gives them such an enviable record?

[Civis]

HEMS Reports, Days 1 -3 (http://www.verticalmag.com/exclusives)

[SASless]

“The regs force people to fly VFR,” he said, giving the example of a flight in marginal weather that could legally be flown under visual, but not instrument, flight rules. “We must evolve to a point were we encourage IFR flight,” he said, also noting the need for more extensive low-level IFR infrastructure.

Bruce Webb, Chief Instructor, American Eurocopter



He is right around the corner from Nick Lappos....perhaps they need to get together in a joint effort.

Nick has done some very interesting work on improving helicopter IFR.

[aspinwing]

Brian Abraham

"Interesting to see that in evidence given the Canadians have never had a fatal HEMS accident since beginning operations in 1972. What is it that they do that gives them such an enviable record?"

Simple, in my province.

Twin engines, two pilots, single (single payer insurance) :ok: dispatcher (including fixed wing) source which filters the requests and pays the bill - no shopping.

[WhirlwindIII]

All

HEMS is an aviation activity. In the states there are a lot of tails wagging the dog (medical types pretending to be the authority), and the dog is letting it happen, on all levels. That's our primary problem.

Canada simply looks at the 24/7/365 nature of the beast and equips/staffs appropriately. The US simply tries to get the most bang for the buck - which is wrong, but the industry and government won't admit it.

I was a bit shivered to hear one witness from a prominent operator say they decided VFR is the only way and they were spending on TAWS etc. rather than IFR. So, we take the chances that TAWS will keep us out of CFIT than using IFR and being up and away from it all.

The US operators are simply FAR too shy of IFR operations, keep looking only at the number of pure IFR flights they do as a result of equipping to that standard, and forget the VFR flights that get done whilst prepared to go IFR should the weather deteriorate whilst enroute, etc.

:ugh::ugh::ugh:

Low level helo type IFR infrastructure is very possible, particularly with ADS-B. Probably never see it in my life-time.

WIII

[SASless]

WWIII,

Slow down Lad, read who it was that said that.


That operator relies upon the trusty Jet Box....and it is far cheaper to add NVG's and TAWS on a VFR machine than to replace the entire machine with an IFR machine with NVG's and TAWS.

Now think about what he said and why!

There are some other issues he skipped over....like takeoff performance in high places, and hot not so high places.

[WhirlwindIII]

SASless

Think we're talking about different operators.

One I'm talking about has a lot of IFR machines being flown VFR-only thus the pilot proficiency is not to 135.297 standard. Bit wasteful considering the IFR option really can't be routinely exercised when prudent and useful excepting in the case of IIMC. The future sees more IFR machines for this operator, being flown VFR-only, as well as new and retrofit VFR machines with NVG, HTAWS, etc.

Not allowing pilots the training to meet IFR proficiency standards whilst assigned to an IFR machine doesn't make sense. They need to spend on IFR pilot training and take full advantage of options that could have prevented some previous problems.

WIII

[Gomer Pylot]

IFR for hospital transfer flights is certainly doable, eventually. But I do about 70% or so scene flights, and there is no way to do those IFR, in any really meaningful way. If the scene is 10 miles away, on a road or out in a field, trying to get there IFR takes longer for just the planning than it would for the fllight, and then how are you going to do an instrument approach to an unprepared scene for which you don't even have precise coordinates on departure? IFR from the scene to the hospital is possible, if the regs are changed to allow departure from a scene, and there is an instrument approach to the hospital, but with current equipment and procedures, it's out of the question. The US is too large, and has too many different areas and environments for a one-size-fits-all solution. I enjoy IFR flying, but it's not suitable for the EMS flying I do. It may be for other type operations. There has to be some amount of flexibility.

[WhirlwindIII]

Gomer

All true. I definitely agree flexibility is the key. Getting operators to view it that way is another thing. Bottom line is IFR capability may just be the price for the safety we need - most likely far cheaper and obviously better than the accidents we have seen of late.

WIII

[OBX Lifeguard]

My approach to this problem has been to hire pilots with demonstrated competence in IFR operations and to require they maintain that competence. To that end I make it easy for my people to get simulated instrument time by availing myself to be in the left seat at their convenience. We also try to make an effort to have some of these training flights at night and when possible under actual instrument conditions.

We are not an IFR operation, but inadvertant IMC at night is a when not an if in my experience. And when inadvertant IMC happens, the sudden transition to IFR flight requires recency of experience.

I'm still on the sidelines concerning NVDs. My military experience with them in over water flight leaves me less than exuberant and over water is a fact of life in my location. I've requested funds to convert our cockpit to NVD compatibility and to secure NVDs for next year nevertheless.

I fail to see where TAWS would do a thing to help the situation. A half dozen instruments are already telling the pilot in your typical CFIT accident he's screwing up; how is one more going to help. The problem is instrument competence, not instrument quantity.

The two other things we do that have helped is 1) review of patients transports to make sure we are not flying innappropriate patients and 2) pre-designating landing areas to decrease the number of pure scene landings.

A last point. If you go back to my first sentence... I also pay my pilots very well to keep those competent pilots working for me :ok:.

[Brian Abraham]

Simple, in my province.

Twin engines, two pilots, single (single payer insurance) dispatcher (including fixed wing) source which filters the requests and pays the bill - no shopping
aspinwing, just how its done in my neck of the woods in Auz, except single pilot Bell 412. Crews tell dispatch after consulting weather what they are capable of doing so there is then no fecking about getting the correct resources to the task eg ground ambulance if flying is out. No going to have a look see, finding you can't do the job and then having to resort to alternatives, not doing justice to the patient by delaying aid, or killing them in the process as seems to be the US want in its competitive drive to turn a buck.

[ramen noodles]

Imagine that, on the Planet Mongo, a great percentage of car accidents are occurring. The Mongoians are concerned, and they launch a scientific team to find out what is happening. The accident team finds that surprised drivers suddenly strike unseen trees. “The cars needed good tree detectors,” they decide, and they set about developing new tree detectors for car dashboards. The Mongoians discovered that drivers are driving into ponds. They state that “There is a great need for better pond detection, and even map displays to show the ponds, and better driver training to be sure drivers read the Pond Digest” and so a great effort is launched to plot the ponds on the new dashboard navigators and to train drivers to avoid those pesky ponds. The Mongo dwellers also find that “Drivers were not studying their weather reports and sunset charts, and were therefore driving into snow drifts and across plowed fields in the darkness.” The accident investigators determine that much training time and money must be spent making sure that drivers carefully plan their drives, and consult the known snow, weather and sunset data.

But one safety expert on Mongo said, “By systematically noting every accident, we could piecewise fix each direct cause, and miss the major, fundamental problems that our system presents to us.” “When you re inside a box, it is hard to know the color the box,” she said, wisely.

You see, on the planet Mongo, where all those car accidents occur, and where the investigators find the need to make the drivers better, and where they are burdening the cars with more and more equipment, there are no roads. Not a road, not a highway, no white stripes, no Motorway signs, no traffic lights. No Jersey barriers, no off ramps, no banked curves. Each driver starts his car and drives into fresh new ground, heading wherever he wants, unmarred by any large scale path planning, unworried about speed limits, planned maneuver radius, traffic control, stop signs and the like. This lack of roads (which have not been invented on Mongo) is a stunning problem to the accident investigators, because they don’t even know that roads could exist. With no roads, the driver bears the responsibility for avoiding all trees, snow drifts and ponds. With no roads, every drive is fresh and new, and cannot learn from the last drive. Without roads, every driver’s judgment is all that stands between success and failure, each tree avoidance relies on a new, fresh judgment, and every driver must make thousands of these judgments on every drive. To miss one such judgment means an accident, and to a Mongo Investigator, it means the need for new driver training and new dashboard equipment.

What is our point? Helicopters desperately need Helicopter Flight Infrastructure, with routes, approaches, departures. If we are not careful in our accident investigation, if we settle for the low-level intermediate causes, we could miss this potentially big finding.

What did route and approach infrastructure bring to airplane aviation 70 years ago?

Routes bring pre-packaged navigation guidance. They relieve the pilots from the burden of planning altitudes, obstacles, and let-down points. Like canned soup, the work is done for you, by experts.

Infrastructure, especially instrument approaches and departures, relieves pilots of continuous judgment about mundane things. EMS and Offshore accidents are rife with crews that make the seemingly bone-headed mistake during critical takeoff and landing scenarios. Initial approach routes, precision approaches and standard instrument departures reduce the need for judgment, regulate the activities into trainable segments under clear airspace control. In doing so, those judgments not made allow pilot cognitive workload for the things that can’t be regulated, making the entire flight safer.

Will routes shackle helicopters and prevent our missions? No, not if they are helicopter routes that harness the awesome memory of modern flight management computers that can hold hundreds of routes and approaches. It is possible to surround every city with dozens of precision approaches to highway intersections, hospitals, businesses, and oil platforms using WAAS and little else.

The FAA crossed this infrastructure bridge years ago. The FAA realized that airplane operations required approaches and departures with firm guidance and weather minimums that support the bill-paying public. VOR’s were invented to keep airplane airliners on track to destinations, ATC was invented to prevent airplane mid air collisions and guide flights safely to touchdown. Airplane non-precision procedures for scheduled carriers were virtually eliminated in the 1960’s and 70’s when the FAA realized that the tendency for pilots to peek was too much. As a result, hundreds of ILS systems were installed at small airports and 200 and ½ minimums became the standard.

Shouldn’t we helicopter people sit down and ask ourselves, like those investigators on the planet Mongo, “What is wrong with this picture?” How can we allow night “VFR” operations offshore, into sky as black as the inside of a cow, and then wring our hands and “seek data” when we lose a helicopter airliner every few years to FITWO? How can we watch EMS operators launch on VFR flights into the darkness with low ceilings to pick up injured patients, when the ease of full instrument approaches to highway intersections and hospitals has been demonstrated in dozens of trials?

Helicopters deserve the same respect as airplanes, especially when the Satellite Nav tools are just waiting to be used. Why is radar the separation tool and 3 mile separation the rule when WAAS is accurate to within a few meters and ADS-B data packages can be swapped automatically? Why does VHF radio range set the minimum airway altitude when a company like FEDEX can track a truck and talk to its drivers anywhere on the planet? With tools like this having been available for the last ten years, why are there NO helicopter precision approaches to any heliport or hospital, and no helicopter low altitude routes anywhere?

[SASless]

Ramen,

You asked the question.....why we don't have the infrastructure and not a single helicopter precision approach in the country.

Turn your question around and tell us how to do it and get it done by the FAA and Helicopter Industry if you would?

What Role does HAI play in this quest for that change?

What Role does the individual operator play?

What Role does the helicopter manufacturers play?

What Role does the individual pilot play?

Interesting side note to consider.....the Canadians have not done what you suggest and they have not had an EMS fatality yet. Why can they do that without any accidents but the Americans cannot?

[ramen noodles]

SASless, you ask great questions!

Turn your question around and tell us how to do it and get it done by the FAA and Helicopter Industry if you would?

The Frendlie Aviation Agency has a program just signed to create low altitude routes approaches and departures specifically for helos

What Role does HAI play in this quest for that change?
The Flight Operations Committee is one of the key sparks to make it happen, come to the meeting at HeliExpo and watch the sausage being made. A ppruner is the task master for this piece of the puzzle.

What Role does the individual operator play?
establishing the initial routes requires operator help - aircraft, route and approach locations, expert guidance for operations.

What Role does the helicopter manufacturers play?
Equipment installation, flight envelope, prime advocacy, selling machines that do the job

What Role does the individual pilot play?
Usually Coco the Clown, at least in your case. ;-) Seriously, the lead pilots are key in designing the routes and approaches to be productive, safe and easy to fly. Also, the pilots can help by advocating IFR operations for all offshore and onshore commercial work. I am constantly amazed at the attitude some have that equipment and procedures are too expensive and too much bother.

Interesting side note to consider.....the Canadians have not done what you suggest and they have not had an EMS fatality yet. Why can they do that without any accidents but the Americans cannot?
The typical old solution for EMS accidents is to simply sit at home and tell the patient "tough beans, old chap." I guess the Canadians are better at that.

Seriously, the issue is not to derive safety by stopping operations, it is to make those operations safer while doing them. No?

[SASless]

Ramen,

If we in the USA are successful in accomplishing this....and meet ICAO standards while doing so....would that serve as an impetus to the UK CAA and European agencies to adopt that technology and allow their HEMS Operations to begin night operations you think?

[ramen noodles]

Sasless,
You bet. Or at least, the helos could fly overhead and drop leaflets that said, "Tough beans, old chap."

[Brian Abraham]

The typical old solution for EMS accidents is to simply sit at home and tell the patient "tough beans, old chap." I guess the Canadians are better at that.

Seriously, the issue is not to derive safety by stopping operations, it is to make those operations safer while doing them. No?
And therein lies the rub ramen. The US because of its competitive nature of EMS operations are disinclined to say NO when all the writing on the wall says DON'T DO IT. The very best of airlines have occasions when they have to say "tough beans, old chap" to their customers, and the reason for their enviable safety record is that they do things by the book and have programs in place to ensure that the aviators do things by the book, such as FOQA. The prime reason US EMS operations have such a poor record is that the word NO is not in their vocabulary. Operations are not conducted within the limits of the prevailing technology. Improved technology may be able to help but whatever is introduced will still have limitations, no matter how good, and the word NO will still have currency. Cat IIIC fixed wing operations are a case in point, the aircraft is able to land but the visibility is so poor that they can't then taxi off the runway.

[helmet fire]

SASless, many of the European HEMS operators are already doing night outlandings, and have been for more than 20 years.

I think one of the strongest impediments to the low level IFR helo structure in the US is some of the current IFR laws - and weather requirments in particular. I dont know the ins and outs of the Euro system, but I will explain the differences that I believe may be impeding the spread of IFR by contractin the situation with Australia where the EMS norm is go IFR.

Take off weather forcast is generally required at popint of depaerture. Not in Oz. We can use weather foceats from nearby airfields as an indicative and use them to recover to. I am not talking IFR take off minima here.

Alternate aerodromes rule in the USA is overly complicated and restrictive. Simplified (I know it is a little more complex) you must be able to get to an alternate airfield AND hold 45 mins cruise fuel remaining when you get there. Good fixed wing rule, very poor helo rule especially with the introduction of help specific stuff. in our environment, we plan into one helo specific approach (our hospital) and the alternate due weather and aids is the major airport nearby. You just need to get there with fuel (not fly past it for 45 minutes at cruise burn). 45 minutes at cruise has the outcome of removing all light twins (read IFR cost effectiveness) from the job. Instead of EC135, A109, B230/430, and BK117 you will need B412/EC145/Dauphin. Big cost jump when you are trying to replace a LongRanger.

The fact that you are not supposed to even try an approach if it is reported below minima, even though the approach takes 10 plus mins some times, and the pilots are all trained to "go around". Several times in Oz we would patiently conduct a couple of approaches waiting to get legally visible.

Special Alternate Minima available for helos in Australia getting HAT(Hieght above threshold) right down which means major trauma centres like Sydney have a really good low wx minima that you can be relaxed and sure about to recover too if you cannot get into the hopital. A simple road transfer from the airport is all that is required. this impediment in the US system also goes with the higher DH for pilots not specially trained and experienced. Most SPIFR autopilots are good to go down to 50 ft above the runway and level off perfectly hands free. Why then are we resticted to 200ish ft HAT?:ugh:
See Nick's dissertations on the low level WAAS/GPS autopilot coupled approaches which resulted in consistent hands off arrival decellarating through 40 KIAS and at 75ft above pad hieght with a consistency that meets all ceetification requirements.

There are some more "funnnies" that are untintentionally affecting the desired outcome of helos going to IFR. We need to start with the legislation to make it operationally attractive firstly! But it is, as we have argued many times, more than just a revamped infrastructure that will help the larger issues of "free market pressures".

[Brian Abraham]

Most SPIFR autopilots are good to go down to 50 ft above the runway and level off perfectly hands free. Why then are we resticted to 200ish ft HAT
As you know all Oz ILSs are Cat I only ie 200 feet. To allow fixed wing operations below 200 in Cat II and III requires much more in ground infrastructure and ATC procedures (where aircraft are allowed to hold so they don't interfere with the ILS signal for example - and much more). The same would apply to helo ops in the main. Do I recall correctly that USA/Canada permitted a 100 foot DA at one time but later put it back up to 200? Little attention by the authorities, despite Nicks work re approaches, has gone towards addressing the unique capabilities of the helo and forcing them to fly to fixed wing standards. Used to practice the ILS to 50 feet (in VMC) and take out the height hold and inch the collective down until near ground contact (not actual touch down due min IFR speed and touch down speed limit, but when your goose is being cooked on high heat). Was the only bolt hole we had should the worse happen. The only thing noticed was a little scalloping of the localiser, perhaps +- 20 feet at the most, about the centreline for the length of the runway. Worked fine in the sim as well.

[WhirlwindIII]

Ramen Noodles

Yes, the HAI Flight Ops Committee is a central spark point for the development of low altitude IFR infrastructure. Exactly 10 years ago that was the marching order given the new Chair to develop. I'm told it was a tough two year development but, in any case, the 'task master' was recruited because he was one of only, possibly, one in the world, who had the capability to create what has come of that committee and its quest to put low altitude IFR infrastructure products to market. One cannot imagine the arrows taken by some pioneers in this equation but at least that committee is a certified focal point as was envisioned.

Brian and helmet fire

The bottom line in EMS accidents is the pilot is the last line of defense. Either give the pilot in command all the tools, and support, to deal with the vagueries and contingencies of 24/7/365 any-point to any-point HEMS or perhaps we best not be in the business excepting the most favorable of overall circumstance.

In the Vietnam era US Army pilots (can't speak first-hand for the other services) generally came out of flight school with what was known as a Tactical Instrument Flying certificate - i.e., "stay out of the clouds because it will kill you, and use these skills if misfortune has struck - 'good luck and God speed to you' sort of thing", with no proviso to maintain currency or add to the skill/s during the subsequent year of operations in RVN.

Today, as with the RVN era pilots, the average US Army pilot coming from the service to HEMS has little or no actual IFR, and little night unaided time, but lots of what I call "crutch" flying with Night Vision Goggles. Some of these pilots, to include pilots from other services, could not pass an IFR flight check if they were trained for the next year, and some so concerned about flying at night unaided that they wash out of the industry, albeit the latter is quite few. The civilian pilots I have flown with and trained in this industry have little or no problem with night and no problem with IFR excepting proper orientation to what is required to handle IIMC.

The point to all this blather is that our military pipeline trains pilots to be dependent upon night vision goggles, and not the overall skills required to deal with all contingencies - the least proficient of which is IMC/IFR flying - inheriting these pilot's limited skill set/s is the single reason operators shy away from what they consider the complex art form SPIFR. It is complex, but not insurmountable, given the appropriate training and simple rules of the road in conducting those operations. Given a training regimen, and ongoing training regimen of simulator, hooded flight, and some actual IMC flight, over time most pilots get it down, and can pass a 135.297 check, and do quite well. It is the implementation schedule that has to be realized will be quick for some, and painfully slow for others.

With respect to support for the pilot there are so many entities with their fingers in the pie the general advice of "Lead, Follow, or Get Out of the Way", as well as "One is either part of the solution, or part of the problem - make sure it is the former in all speech and action" definitely applies. Think the solution is not this simple? Go follow a HEMS pilot for a day, and formulate your own opinion.

WIII

[zalt]

PROFESSIONAL HELICOPTER PILOTS ASSOCIATION INTERNATIONAL
Office and Professional Employees International Union


Recommendations on Helicopter Emergency Medical Services (HEMS) Operations pursuant to the NTSB Hearings of February 2009

March 5, 2009

The Professional Helicopter Pilots Association (PHPA) has a membership of over 4,000 helicopter pilots around the United States and Canada, over 1,300 of which are active HEMS pilots.

The members of PHPA are gratified that the issue of HEMS safety is receiving the acute attention from government agencies, industry, the media, and the public that it has long required. No stakeholders in this issue have more to gain (or lose) than do the men and women who fly these aircraft, and while we are certainly encouraged by the attention currently focused on our industry, we remain wary that talk will not be transformed into meaningful action.

We are all too aware that "pilot error" is cited as the cause in the majority of helicopter accidents, and recognize that "heal thyself" is often the call from those who look at this issue from outside the cockpit.

Were it so easy as to order pilots to stop crashing aircraft.

The International Helicopter Safety Team is putting a significant effort into reviewing accident reports in an effort to identify causal factors and develop recommendations based on hard statistical evidence. Unfortunately, most helicopters do not carry the type of recording devices available to investigators for large fixed wing aircraft. In the end, few investigations can determine with certainty why a qualified pilot flying a functional aircraft is involved in a CFIT accident, with the result being another "pilot error" statistic.

The members of PHPA are certain of this: pilots are more often victim than villain in this arena where good intentions are often not supported by good equipment, good training and good practices. Yet pilots have, for years, remained silent on these issues, conceding to operators who claim that the financial realities of the industry prohibit the adoption of the best equipment and training which for years has been required for our airline brethren. This silence has been born from the fear of losing a job that provides immense satisfaction as well as a source of income, and the absence of a structure such as PHPA from which we could voice our concerns as a group.

It is easy and perhaps correct to blame the pilot, operating a single engine aircraft at its maximum allowable weight, at night, with no vision enhancing system, no terrain warning system, no co-pilot or auto pilot, attempting to transition from the glare of lights at an accident scene to the pitch darkness of an overcast sky who hits wires or gets disoriented and plows back into the ground. Yet placing such blame does not make the next flight safer.

We all recognize that there is no cheap, easy fix to the issue of HEMS safety. Yet if this industry truly wants its operational safety to approach the level that has been achieved and sustained by the airlines, the model has only to be copied. Who in their right mind would subject themselves to an airline operation that resembled the above paragraph? Unfortunately, those being transported rarely have any input regarding the operator, or type of equipment that they or their family members are placed in, when being evacuated from an accident site.

It is our contention that relying on voluntary compliance for essential equipment and practices will only result in a continuation of the status quo, with perhaps a slight bias towards compliance accompanying the media glare of each "new" accident.

The recommendations below address both immediate requirements and long term goals. They represent the combined concerns of professional career pilots who simply want the tools to go along with the responsibility for insuring that every flight is brought to a safe and successful conclusion.

EQUIPMENT:

1. Night Vision Goggles or Night Vision Imaging System: Priority - Critical.

Recommendation - Require one of these systems to be onboard and functioning in each aircraft in the current HEMS fleet as quickly as equipment can be purchased, aircraft modified and crews trained. Restrict noncompliant aircraft to day-only flight beyond mandatory implementation date of 24 months.

2. Helicopter - Terrain Awareness and Warning System (H-TAWS): Priority - Critical.

Recommendation - Require installation in the current HEMS fleet within 36 months, with equipment based on the FAA's recently published TSO. Require on all HEMS aircraft purchased for replacement or expansion.

3. Wire-strike Protection System: Priority - Very Important.

Recommendation - Require installation in the current HEMS fleet where systems exist for individual models. Require on all HEMS aircraft purchased for replacement or expansion.

4. Color Moving Map GPS: Priority - Very Important.

Recommendation - Require installation in current HEMS fleet within 18 months.

5. Flight Data Recorder / HUMS: Priority - Very Important.

Recommendation - Require installation in current HEMS fleet within 48 months to include cockpit voice recorder and instrument monitoring through video (as a minimum) where full flight parameter monitoring on legacy aircraft is not practical. Data developed should be used pre-accident for recurrent training as part of a FOQA program.

6. Multi Engine: Priority - Very Important.

Probably no single issue generates more heated debate than that of the potential impact of multiple engines on safety. While we will not attempt to resolve that debate in this document, we will simply highlight several reasons for our position on the issue.

A large percentage of HEMS pilots come from the U.S. military. Practically all helicopters operated by the military today are twins. Therefore the majority of these pilots have no power-off experience or training beyond their initial qualification, and the minimal transition training required prior to their operating a single engine HEMS aircraft. Add to that the difficult environment in which these aircraft are being operated (over crowded cities, forested, mountainous, and other unimproved terrain, at night), and the results from a power failure in a single engine HEMS aircraft when the next one inevitably occurs, will likely be undesirable.

Beyond the obvious benefit of power plant and various subsystem redundancies, multi engine aircraft are larger, providing for separation of cabin and cockpit. This separation provides many important safety enhancing benefits such as:

a.) Preventing the various aspects of patient care from distracting the Pilot,
b.) Reducing or eliminating the potential for a combative patient to interfere with the Pilot or reach the aircraft's power or flight controls,
c.) Allowing for a second Pilot (either training, orienting, or acting as second in command) during patient transports.

Recommendation - Require replacement or expansion HEMS aircraft to meet ICAO Category A, Class 1 or 2 requirements.

7. IFR Certified Aircraft / Two Pilot Crews: Priority - Very Important.

PHPA takes the position that the standard for HEMS operations should be a multi engine, fully IFR certified helicopter crewed by two qualified pilots. That there are operations around the world that meet this standard argues against those who claim it is not feasible.

a. Two Pilot Crews: The safety value of two qualified pilots is undeniable. New HEMS pilots would have the opportunity to develop experience under the tutelage of a veteran pilot, and experienced pilots would have a trained and certified assistant to help manage the ever increasing tasks required to operate safely in the HEMS environment. While not a substitute for a second pilot, a functioning auto-pilot is essential to help reduce pilot workloads to manageable levels during task intensive phases of flight and to reduce fatigue on long distance transports.

Recommendation - Require an auto-pilot on all expansion or replacement aircraft, with current fleet modifications required within 48 months.

b. Full IFR Certification: Required to provide the pilot with the option to abandon the VFR environment before being faced with an inadvertent IMC emergency. Given a night flight with deteriorating weather, currently the pilot has to make the difficult choice between attempting a risky off field landing or declaring an emergency subsequent to entering IMC conditions. We believe that an IFR pilot should have the option of simply requesting a (non-emergent) IFR clearance and recovering to a well illuminated airfield. In addition, WAAS enabled GPS will soon provide the capability for ILS equivalent approaches to hospital helipads. The HEMS community will need IFR certified aircraft to take advantage of this and other rapidly developing technology that will continue to enhance the safety of its operations.

Recommendation - Require Full IFR certification on all expansion or replacement aircraft. Current fleet upgrades should be required within 60 months.

TRAINING:

1. Initial HEMS Qualification: Priority - Concern.

PHPA is concerned that the availability of highly experienced pilots suited to the HEMS workforce is declining and that pilots lacking requisite experience are being placed into an environment for which they are not fully prepared. Former military pilots in particular are of concern as they no longer fly solo, not even during their initial pilot qualification. All of their experience has been as part of a crew. Yet current regulations do not account for this lack of solo experience when qualifying new HEMS pilots into a single pilot helicopter. Contributing to this problem is the fact that a significant number of the helicopters in the HEMS fleet are single engine and do not have the capability for a flight instructor to accompany a new HEMS pilot on a flight with medical crew and patient on board. For some, their first exposure to the HEMS environment in their local area is solo.

Recommendation - PHPA urges the review and standardization of pilot qualification requirements for HEMS operations.

2. Recurrent Simulator Training: Priority - Important.

Airline pilots fly the same type of airport to airport IFR flight day in and day out, average 1,000 hours in the air per year, yet to a man (or woman) they routinely train on the most sophisticated flight simulators available. A HEMS pilot might log 20% or 30% as much time in the air, operates in an environment that changes daily, and usually receives little more than an annual aircraft proficiency check.

Recommendation - Require recurrent Scenario based Simulator Training for all HEMS pilots on at least an annual basis. This training should use aircraft specific simulators and data bases that place pilots in their own area of operation for maximum effect. (Scenarios should incorporate lessons learned from past mishaps or close calls, and could even be tailored to site specific lessons developed through a FOQA program.)

ENVIRONMENT:

1. Crew Rest: Priority - Important.

PHPA supports a maximum work shift of 12 hours and the requirement for a dedicated rest area where a pilot can sleep if tired. The lack of guidance from regulators in this area has increased the risk of tired pilots accepting flights when opportunities for rest were denied due to operator policies.

Recommendation - Incorporate NEMSPA's recent white paper on the subject as the basis for an industry wide standard which includes training on dealing with fatigue in the HEMS community.

2. Medical Personnel Flight Veto Power: Priority - Concern.

A much touted policy by many in the industry is "Three to go, one to say no". Having a second opinion on a proposed course of action is a valuable tool for a pilot. However, even in a crew of two qualified pilots, the second in command (SIC) seldom has veto power over the Captain. At best, these well intentioned policies can be frustrating to an experienced pilot when paired with a nervous rider. Moreover, decisions made by untrained individuals are often little more than an indication of trust. If the pilot is well liked and trusted by the crew, they will remain silent as he drives them into the ground, whereas an unknown pilot can be pounded with concerns to the point of distraction on a relatively routine flight.

Recommendation - PHPA supports the encouragement of input during flight from all crew members, as well as providing them access to a post-flight reporting system to alert flight standardization personnel to operations with which they have a concern. However, we believe it is important to remind all concerned that FAR 91.3 (a) properly assigns final authority for the operation of the aircraft to the pilot in command (PIC), and that authority cannot be shared or delegated.

3. "Hard" Liftoff Times: Priority - Important.

Some pilots are reporting operator imposed requirements to be airborne within a set amount of time subsequent to receiving a flight request. This arbitrary setting of the amount of time available to properly plan a flight as well as complete the many checklist items required to safely start the aircraft and initiate flight, is unwise on a number of levels. Every flight is different, as is the time required to properly plan and initiate it.

Recommendation - Hard liftoff times are an unsafe practice that should be banned by the FAA.

4. ASAP & FOQA Programs: Priority - Important.

PHPA supports the implementation of non-punitive ASAP & FOQA programs that encourage pilot participation and reporting of safety related issues. A well designed and managed program can provide pilots with invaluable feedback to improve overall safety performance.

Recommendation - Encourage the implementation of these valuable programs.

The Professional Helicopter Pilots Association appreciates the continuing efforts of the NTSB to improve the safety of HEMS operations. These flights, conducted by professional men and women, have had and will continue to have a substantial impact on the lives of those they transport. The efforts of the Board in addressing the safety of this industry will have no less substantial an impact on those passenger's, as well as the crews who serve them.



Butch Grafton
President PHPA Int.

[alouette3]

Interesting that the equipment upgrade gets a "critical" rating and all human factors (training, environment etc) merit only a "concern" or an "important".No amount of bells and whistles can change the EMS safety record. It has to be a multi pronged effort.
Of course, since that means doing several things together and since the FAA or the operators are incapable of walking and chewing gum at the same time it will be just another bandaid for a bullet wound.
Pilot training, pilot attitudes, scheduling, duty time and operational control all need to be addressed urgently and concurrently with all the other gizmos. Just my 2c.
Alt3.

[SASless]

I agree with Alouette on this one.

The Bells and Whistles play an important role but the training, procedures, and general mindset amongst the players is where the most effective and most immediate change needs to take place.

Until the industry accepts they are in medical transportation and not "Life Saving" and thus kick the "Hero" mindset to the curb the safety environment will not change.

The rub comes when revenue, flight count, and profitability is considered and cautious, careful, deliberate operations cannot be sustained and kept profitable.

Perhaps, the industry is over sold and some of the dodgy outfits need to fold their tents.

[Gomer Pylot]

Mindset is what it is, and will always exist. Some people have a desire to be a hero and nothing will change that. They need to be weeded out of the industry somehow, before they kill somebody, but I'm not sure how that could be done. For those of us who have long since realized we'll never be heroes, but just want to stay alive and collect our paychecks, better equipment will certainly help us to do that. Give me the equipment the PHPA proposes, and I can survive most situations, whether inadvertent IMC or an engine failure. There will always be accidents, no matter what equipment is being used, because there will always be unexpected and unusual events, as the airlines continue to show us, but if we have the most probable events covered, we've done a lot. I do agree that training needs a higher priority, and I think Butch covered it to some extent. We need frequent IFR training, either in sims, the aircraft, or both, because without currency and proficiency, that fancy equipment will kill you in a heartbeat. But without the necessary equipment, you're probably going to die anyway.

[WhirlwindIII]

Last three posts sum it all up.

[Gregg]

Medical-Helicopter Study on Safety Splits Industry - WSJ.com (http://online.wsj.com/article/SB124018627927633409.html)

[SASless]

Ah Gee.....you mean folks that have been the worst serial killers in the country are miffed someone is taking them to task on how they operate?:ugh:

I would suggest a quick review of their accident stats and we can probably guess who they are.:=

Just why does it take a builder of helicopters to do this study.....and not the very industry that was the subject?:rolleyes:

Reckon some folks have yet to realize there is a problem?:mad:

[What Limits]

More grist to the mill.

This (http://www.flightsafety.org/pdf/HEMS_Industry_Risk_profile.pdf) from the Flight Safety Foundation today.

I totally agree with all the previous posters on the person factors associated with this. No amount of bells and whistles will reduce accidents without the appropriate correction in attitudes.

[Phrogman]

Alt 3, Sasless, WIII: spot on with the human factors comments. The most wanted list declared by the "Union" has its priorities out of whack in my opinion. All those toys listed as "critical" are wonderful for what I would call "Positional Awareness" (NVG's, Color GPS moving maps, Terrain Alerts), but those things don't do much for a pilot who has lost "Situational Awarenesss" (in the conventional sense of the term). These "critical" gadgets should be secondary to proper risk management training and a mission analysis process that takes into account the true probability of success based on the training and experience of the aviator, vice the probability of a good payday. Poor decision making and "missionitis" are always going to be the achilles heel of this industry no matter how many things you put in the aircraft to overcome the weakest link. I am comforted to see that the press for multi-piloted operations seems to be high on the most wanted list, it will definitely help matters.

[WhirlwindIII]

The more bells and whistles present, the more probability at some point a pilot will lose situational awareness, especially if he/she does not know how to declutter all the info to JUST that required. Trying to deal with too much info in a short period of time is like trying to speed read on a professional level while still in grade school.

[Brian Abraham]

From Aviation Week today

HEMS Hearings Explore Safety Issues

The House aviation subcommittee hearing that we told you had been scheduled last Wednesday explored multiple issues relating to Helicopter Emergency Medical Services (HEMS) air ambulance safety. It was broadcast by streaming video from the Transportation Committee web site.

Subcommittee Chairman Jerry Costello (D-Ill.) noted that helicopter air ambulances operate in challenging conditions, including bad weather, unfamiliar and often confined landing sites, and at night, simply because their services are so vital.

At the meeting, FAA Flight Standards Director John Allen testified that the agency has taken a multipronged approach to address HEMS safety, including the release of an operation specification (OpSpec) that increases weather and visibility minimums, FAA-recommended best practices and multiple notices, bulletins and advisory circulars covering HEMS operations and equipment.

"We recognize that relying on voluntary compliance alone is not enough to ensure safety operations," Allen said in testimony. "In that regard, the FAA has initiated a formal rulemaking project that will address many of the HEMS initiatives . . . over the last several years." Allen added that the agency hopes to have a notice of proposed rulemaking published in late 2009 or early 2010.

House Transportation and Infrastructure Committee Chairman James Oberstar (D-Minn.) agreed that, "while voluntary guidance and increased weather and visibility operating requirements are steps in the right direction, this is not enough." He said the FAA must also address safety technology enhancements such as TAWS, GPWS and night vision goggles - along with human factors that affect mission-oriented HEMS pilots performing mercy flights, he said. "FAA must commit to long-term action to ensure that patients and flight medical crew aboard HEMS flights reach their destinations safely."

"The regulatory issues involved here are not easily parsed, so we need to be sure that in our efforts to accomplish this goal we do not create unintended consequences that create additional problems," Costello said.

Some HEMS operators are reportedly already balking at the prospect of new equipment requirements and to stricter dispatch rules.

Bolding mine. With all the evidence before them (lost lives, bent metal) it looks as though the operators can't see the woods for the trees. Any lumberjacks out there able to clear a forest?

[Shawn Coyle]

There'll be an interesting article in a future issue of Vertical about what the industry groups have done. (and not written by me - I've seen the draft and it's not going to make these groups look good)

[SASless]

Whirlwind,

Complexity a threat to Situational Awareness?

Yes it can be.

The opposite can be just as deadly....that being no complexity.

For example.....

Single pilot marginal weather....unstabilized aircraft...basic instrumentation....paper map in hand....NIGHT!

How many of us really use a paper map at night and do a proper job of it?

A moving map GPS....with a screen big enough to be seen easily beats hell out of the other situation does it not?

Let's add NVG's into the mix.....now we can actually "see" in the dark....instead of trundling along waiting to see some lights somewhere on the ground.

Add a hands off autopilot so all we have to do is attend to the conduct of the flight and not be splitting our attention to hand flying the aircraft and all that other stuff we do to "manage" the flight.

If one is too dull to keep up with the "hired help" then perhaps one should step out of management....and seek a day time VFR only job.

[alouette3]

I watched portions of the testimony on the web. The panelists were evenly divided on whether this was a medical enterprise which just happens to use helicopters or an aviation enterprise which just happens to have sick people as passengers.Equally split were opinions whether the states should have the ability to regulate HEMS thereby being able to control how many helicopters operate in their state and what kind of equipment should be mandated.One of the guys went as far to say that the Airline Deregulation Act of 1978 should not apply to HEMS as it was passed with only the scheduled airline operations in mind and not HEMS, which was still in it's infancy.
To me, the key lies in resolving the first issue (i.e. aviation or medical). But,the pessimist (or realist) that I am, I think this will go down as another eternal debate, on par with Global Warming, Abortion, Gun Control etc.
Alt3

[WhirlwindIII]

SASless (where did you get that moniker dear friend?)

Complexity is that which is required to be processed by the pilot per given unit of time. Simplicity is a moving map, until it fails.

Complexity is a completely overcoddled medical crew with their mouths constantly in motion distracting the pilot.

Complexity is the corporate arm of an Air Carrier thinking they can control to their benefit from their comfie chairs afar through directing and disciplining their line swine thus creating safety through ten thousand pilot' and maintenance technician' computer key strokes per minute, all aghast at filling out endless thoroughly ignorant forms that lead to statistical discovery completely after the fact of their distraction via flight operations taken place through the ground zero delegated Operational Control placed with the pilot (golly gosh, ya thinks - is this something new?) - you know, the Ivory Tower Syndrome.

Dumber is just getting more fascinated with dumber!

Complexity is an industry thinking they can out - technologize the attention required to the human element of this HEMS operating equation by night vision goggles and all sorts of other technical goodies.

This industry needs to get fascinated with its line workers and the basics required to support them and make their jobs easier, thus more effective, and more safe. This is NOT what is currently happening, and we all see it.

Just think, Canada have been doing this for 30 years, with no upsets - what are we missing?! I know.

WIII

[squib66]

Nearly three years on: what has changed for better (or worse)?

[SASless]

There are fewer accidents I believe.....or at least they are not making the news as frequently.

[WhirlwindIII]

The industry is paying more attention to detail, flying less, and enjoying fewer collisions with weather related difficulties due to increased VFR minimums. As to all the other fixes time will tell.

[SASless]

Get a bucket of Salt and have it handy when you read this FAA Fact Sheet. They make some statements applauding themselves, particularly about encouraging the adoption of NVG technology, that stretch the truth just a wee bit.

What I did find interesting is the Date Bench Marks they use....and how slowly things happen within that bureaucracy. The untold side of the story is how "helicopter only" Inspectors used to suffer under the promotional system and in some ways that became a deadend street for those seeking advancement.

Yes... there have been improvements...but a review of the history of FAA progress despite the strong recommendations of the NTSB...leaves one a bit cold and not at all warm and fuzzy about the FAA's rate of change.

The sad commentary is the American EMS Industry had to be dragged kicking and screaming into making so many of these changes despite the horrible toll in lives and machines they were experiencing in the daily operations.

Fact Sheet – Helicopter Emergency Medical Service Safety (http://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=6763)

[WhirlwindIII]

However the improvements to safety and predictability are cloaked the bottom line is HEMS pilots need more accurate and real-time support from all corners.