New Us Ops Specs A021 - Hems

[Civis]

Anyone read through or been involved in the draft for this?

Supposed to take effect in February but no guidance or definition on what constitutes a " Route " with reference to lateral clearance from enroute obstacles. Also no information on conformance documentation.

Can't seem to link the finished document but available at:

www.faa.gov (http://www.faa.gov) and search A021


Other links: FR Doc E8-27137 (http://edocket.access.gpo.gov/2008/E8-27137.htm)

Request for comments
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Operation Specification A021 (http://www.nemspa.org/OpSpecA021_A050.htm)

[SASless]

"Ding...Ding...Ding...."

You have just been toned out on a night flight, weather is marginal at best, you are going to a scene call, the location is in Pender County.....you have four minutes to call airborne from the Hospital Pad.

As you lift...you get a vector....135 at 42miles....

You are single pilot.

Your aircraft has no SAS or Auto pilot.

Drag out your map....in the dark...fly the aircraft....look for traffic...handle the radio....talk to ATC....set up the FM radio to talk to the ground crews at the scene....set up the nav's....oh....and check the "route" for obstacle clearance while you are at it!

Anyone see a small problem in the logic?

[alouette3]

This will certainly impact lift off times. We can have'canned' MEA's for routes that are flown regularly (i.e. between hospitals) but a scene flight is an entirely different thing. Secondly, after maintaining 500' above the obstruction (at night) and then considering the cloud clearances in Class E airspace, sends the minimums throught the roof (pardon the pun). This will kill at least 50% of our flight volumes.The beauty of it all is that ultimately, we as PIC's, are still responsible for terrain and obstacle avoidance.
Can't recall getting the memo that had absolved me of this responsiblility.:confused:

Alt3.

[WhirlwindIII]

All this stuff cracks me up!

We have FAA and gosh knows what other organization constantly reiterating the importance of flight planning and risk assessment and PIC responsibilities, etc. etc. but who's looking at the infamous liftoff times as the primary motivator of mistakes?

Helicopters aren't four wheeled ground-bound ambulances and the aviation side of the house (read FAA and NTSB and everyone involved) needs to take a look at outside sources (hospitals, operators, standards organizations etc.) requiring pilots to take off within a certain time frame, irrespective of whether proper preflight planning has been accomplished. The FARs say we must accomplish proper preflight planning and pretakeoff checks etc. etc., - they don't say one must liftoff within 4 minutes! What is it we aren't getting? FARs and safety of operations take precedence.

Sure, it is important not to waste time getting off the ground and to some
place to pick up a patient, but it is far more important not to make mistakes and create more patients/victims!

Cart before the horse sort of thing - or is it just plain dumber than dumb?

[SASless]

The way I read this....not only do you have to do a map recon before flight but you have to record for posterity what obstructions you use to determine your minimum safe altitude. Now that will throw a HUGE Speed Bump into the process!

Preplanned data can be determined for inter-hospital flights and other known routes but scene calls will now require the pilot be provided the location prior to takeoff so the Safe Height calculations can be and recorded.

The way I read this one has to calculate the safe height above ground for the route then add the cloud separation criteria and bounce that against the current and forecast weather for the duration of the flight before running out to the aircraft.

The follow-up question is how does one keep track of temporary masts, cranes, tethered balloons and the like and incorporate that data into preplanned routes? Notams are supposed to have that information but how do you update the preplanned route data to ensure it is timely?

"Business as usual" mindsets are going to have to change now if this is enacted and enforced by the FAA.

However the FAA as usual left it up to the individual operators to determine the method and documentation method to determine the minimum safe height for the "route" being flown without setting forth the definitions of what they considered a "route" to be.



all visual flight rules (VFR)
segments of the flight must be conducted within the weather minimums
and minimum safe cruise altitude determined in pre-flight planning.
Specifically, A021 requires pilots to identify a minimum safe cruise
altitude during pre-flight planning by identifying and documenting
obstructions and terrain along the planned flight path. HEMS pilots
must also determine the minimum required ceiling and visibility to
conduct the flight using the revised weather minimums contained in
A021.

[Devil 49]

Once again the Gummint has firmly closed the gate after the cows are long, long gone, and generate paperwork at the same time.

My opinion: Night accidents are a human factors issue. Until we scheduling and stop pretending that humans aren't affected by 180 in the wake sleep cycle, we'll kill aircrew. Insufficient, poor sleep and circadian disruption are known to degrade the reasoning process. Stupid pilots make bad decisions, launch without sufficient visual ability to 'see and avoid' weather, terrain, etc., and function poorly when the challenge occurs. NVGs help, but no not address the basic problem.
Nor does this bit of paperwork mumbo-jumbo.

[alouette3]

Well said Devil 49. Scheduling and shift hours have been a favorite issue for me.
I believe we need to rewrite our FARs for Part 135 HEMS (the only ones that fly nights in helicopters for profit on a regular basis) scheduling to include extended rest periods after a late flight. A 24 hour off cycle after a flight that begins or terminates after midnight is reasonable. Obviously this will throw a huge wrench into the system. More pilots will be required to be hired, schedules managed more proactively etc. All distasteful to the operators.
The only reason paperwork mumbo jumbo has been added is to let the ope rator's off the hook. In case of another CFIT accident, the company can wash their hands off and say that the pilot was negligent and in violation of the Ops Specs.Ultimately, it is all about liability.
Alt3

[WhirlwindIII]

Alt 3 et al

"Ultimately, it is all about liability." Yes!

In other words the operator and FAA could care less as long as following an accident the agrieved can go after the pilot's estate long after he/she is deader than dead just because they, the operators and FAA (and NTSB), don't have the stones to tell the industry to slow down and get it all right in the first place via using the rules, regulations and good operating practice that is already in place as part of pilot certification.

This revision to AO21 is really sad stuff - just as despicable as the large banks doling out 18.4 billion US $ in bonuses for their worst performance since the great depression - some things just do not make sense.

I'd say we in HEMS have run smack dab straight in to our Achilles heel - failure to take the responsibility for slowing down and doing things right from the get-go.

WIII

[Cyclic Hotline]

alloutte3 noted:
More pilots will be required to be hired, schedules managed more proactively etc. All distasteful to the operators.


Alternately, with the current economic situation, the lost employment tied to medical insurance and the likelihood the private insurance organizations will have to compete with the government in the US - the whole EMS industry might implode.

I don't think you need to worry about the effect on operators, you need to be concerned about the effect on your customers, because they are the ones ultimately paying for the service.

I think a more likely scenario in the current situation may be the exact opposite from your suggestion. Hardly the stuff to improve safety - but if you think times were tight before, just wait another 6 months.

[alouette3]

Have to agree with WWIII.
Cyclic Hotline: there will be a shift in business practices no doubt. With the Government leaning towards socialized medicine, there will be an impact on insurance companies etc. I see the Hospital based system going away in a few years and the Community based sytem standing after a few radical changes. But it will certainly be a lot longer than in the next six months.

Seems to me that all we are doing is rearranging the deck chairs on the Titanic to avoid hitting the iceberg.
Alt3.

[WhirlwindIII]

Hospital Based vs Community Based -- think hybrid, operator provides the machine and pilots and maint, hospital provides the medical people and bits, both share the base fixed costs, plus or minus.

[hostile]

yyaaahh!:{, more pilots... disasteful for the operators...

You know, who would like to operate ems - they found money for that. If they don't - they shouldn't operate. Always need to think safety first even its feels difficult in the beginning. New rules always feels so, but they have a reason to be in.

:ok:

[Darren999]

With all the said changes with AO21. Just give me an auto pilot and NVG's, I'll be fine with that...
We have canned numbers for sectors for scene calls. if you head West its..... If you head East its............
It can all get far to complicated. Furthermore, with reference to lift times, I lift when I'm ready and everythings safe to do so. I am fortunate and do not get any heat on lift times.

[WhirlwindIII]

Seems simplicity and effectiveness have taken a back seat to complication and fascination with structure, process, and unintegrated technology.

When??