HEMS - Regulations and saving life
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Sorry to spoil a rumour but there are NO new Rules from CAA relating to helipads at hospitals etc. JAR Ops has introduced some changes for public interest sites but that is all.
Any hospital site used has always required compliance with Rule 5(1)(b), (i.e. no 3rd party risk) and that goes back to the year dot, nothing new there, and really why should innocent people be put at risk in a congested area? Is risking multiple lives acceptable to save 1, even a child?
Regarding SAR, I would respectfully point out that civil SAR helos are allowed to pick up in the same way as the military, including accepting 3rd party risk where necessary and this is I suggest a red herring for this particular topic of Birmingham hospital.
There was a meeting many moons ago between the Police ACPO (including a well know Lawyer (not FL on this occasion and no offence to him intended) where the issue of saving life was discussed in full and the situation regarding police pilots using the 'saving life' bit discussed. It is no different to an ambulance or fire engine driver going through red lights and then hitting and killing someone. They could be done for it but it would depend on the degree of judgement and common sense applied in the particular situation that would help decide whether a prosecution would take place. The police lawyer agreed that this was correct.
In other words the aircraft commander does what he is paid to do, looks at the situation, makes a decision and chooses whether or not it would be reasonable on that occasion to break the law and gets on with it.
I know that the CAA have not issued any sort of decree regarding this site or changed any rule. Maybe the operators have re-assessed it and decided it was not acceptable, maybe the hospital decided this themselves, maybe someone who knows the FACTS of what has happened might post something.
Sorry to spoil a good rumour
Any hospital site used has always required compliance with Rule 5(1)(b), (i.e. no 3rd party risk) and that goes back to the year dot, nothing new there, and really why should innocent people be put at risk in a congested area? Is risking multiple lives acceptable to save 1, even a child?
Regarding SAR, I would respectfully point out that civil SAR helos are allowed to pick up in the same way as the military, including accepting 3rd party risk where necessary and this is I suggest a red herring for this particular topic of Birmingham hospital.
There was a meeting many moons ago between the Police ACPO (including a well know Lawyer (not FL on this occasion and no offence to him intended) where the issue of saving life was discussed in full and the situation regarding police pilots using the 'saving life' bit discussed. It is no different to an ambulance or fire engine driver going through red lights and then hitting and killing someone. They could be done for it but it would depend on the degree of judgement and common sense applied in the particular situation that would help decide whether a prosecution would take place. The police lawyer agreed that this was correct.
In other words the aircraft commander does what he is paid to do, looks at the situation, makes a decision and chooses whether or not it would be reasonable on that occasion to break the law and gets on with it.
I know that the CAA have not issued any sort of decree regarding this site or changed any rule. Maybe the operators have re-assessed it and decided it was not acceptable, maybe the hospital decided this themselves, maybe someone who knows the FACTS of what has happened might post something.
Sorry to spoil a good rumour
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Just to add to my last, the 'saving life' Rule was designed to address the need to low fly if the a/c had a problem that needed that 'out', NOT to address the SAR/HEMS/Police use of an aircraft. This has been misunderstood for years. Before I get howled down about being wrong, the Rules of the Air changes sent out by the GA department of the CAA many months ago, addressed this and make it clear. If you look at the proposed change it removes that alleviation completely and relies instead on Article 84 of the ANO, as explained in the covering text.
Please excuse me while I duck from an incoming Hellfire from an Apache!!!
Please excuse me while I duck from an incoming Hellfire from an Apache!!!
Two issues here:
(a) Landings at hospitals, and,
(b) Saving life in helos.
(a) The CAA are beginning to show an interest in this because of the ever increasing demands from Europe under JAR. Annex 14 to one of their regs shows that the operator must be able to fly a safe profile to the hospital helipad, should an engine fail (similarly on take off too).
Alternatively, the hospital should take on the burden and build a suitable site to cater for most if not all helos. Guess where the burden will end up - helo operators, because hospitals are not going to spend millions transforming/building landing sites.
Only the older a/c will suffer (105's, 355's etc.) New gen a/c can cope with the regs.
The deadline for this is forever slipping because most of the German helos are 105's! Current deadline: 2009 and counting.
This ruling is quite complicated and I have tried to simplify it somewhat.
Hospital landing sites has nothing whatsoever to do with the HSE!
(b) Saving life in a public transport helo.
A very VERY emotive subject.
It is very easy to take the moral high ground here and become the local hero while saving that little girl who is struggling in the icy cold river beneath the hovering chopper. Of course, anyone who has any conscience would think first and foremost about dangling the skid in the water and saving her.
BUT,
one has to consider the implications:
if the chopper went in, the girl would die and so to, the crew of the chopper. What is the advantage to that?????
One hopes that the helo/pilot will do its job and save the day, but if either fails, then you are looking at a manslaughter charge.
The CAA will always officially declare that they will prosecute if you operate beyond your clearance. They have to say that. What they do at the end of the day, is another matter.
We have discussed this until the cows have come home:
We would do everything to assist third parties to save the victim[Comms/illuminate scene/throw liferaft etc]. But if we ALL ONBOARD honestly thought the victim was about to die, we would do what we had to do
What that entails is between me, my maker and a very good lawyer
(a) Landings at hospitals, and,
(b) Saving life in helos.
(a) The CAA are beginning to show an interest in this because of the ever increasing demands from Europe under JAR. Annex 14 to one of their regs shows that the operator must be able to fly a safe profile to the hospital helipad, should an engine fail (similarly on take off too).
Alternatively, the hospital should take on the burden and build a suitable site to cater for most if not all helos. Guess where the burden will end up - helo operators, because hospitals are not going to spend millions transforming/building landing sites.
Only the older a/c will suffer (105's, 355's etc.) New gen a/c can cope with the regs.
The deadline for this is forever slipping because most of the German helos are 105's! Current deadline: 2009 and counting.
This ruling is quite complicated and I have tried to simplify it somewhat.
Hospital landing sites has nothing whatsoever to do with the HSE!
(b) Saving life in a public transport helo.
A very VERY emotive subject.
It is very easy to take the moral high ground here and become the local hero while saving that little girl who is struggling in the icy cold river beneath the hovering chopper. Of course, anyone who has any conscience would think first and foremost about dangling the skid in the water and saving her.
BUT,
one has to consider the implications:
if the chopper went in, the girl would die and so to, the crew of the chopper. What is the advantage to that?????
One hopes that the helo/pilot will do its job and save the day, but if either fails, then you are looking at a manslaughter charge.
The CAA will always officially declare that they will prosecute if you operate beyond your clearance. They have to say that. What they do at the end of the day, is another matter.
We have discussed this until the cows have come home:
We would do everything to assist third parties to save the victim[Comms/illuminate scene/throw liferaft etc]. But if we ALL ONBOARD honestly thought the victim was about to die, we would do what we had to do
What that entails is between me, my maker and a very good lawyer
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Old heliman; You have confused the hell out of me! Are you saying that given the circumstances we have the right to break the law?
Thomas Coupling; Is it not a sad situation that in this day and age; to save someones life, part of the decision making process is - between me, my maker and a very good lawyer?
Like most of us in this corner of the industry, I have already discussed this with those that I fly with, and we have all agreed what we would do as a crew. But one day one of us is going to be put in an awful position and fear of prosecution, with all that implies should not be part of the equation.
Thomas Coupling; Is it not a sad situation that in this day and age; to save someones life, part of the decision making process is - between me, my maker and a very good lawyer?
Like most of us in this corner of the industry, I have already discussed this with those that I fly with, and we have all agreed what we would do as a crew. But one day one of us is going to be put in an awful position and fear of prosecution, with all that implies should not be part of the equation.
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Thomas coupling
has a point and i would agree that this is a very emotic subject. But i would have thought that one must way up the gain with the potential for loss. it is like saying that you could not send a B.A Team into a burning building on a persons reported shout (B.A = breathing Apratus Persons reported = People trapped ) becouse there is a possablilty of the pump failing and the crew lossing water. It is a pluasable argument but the risk must be looked at to the gain. as previously stated safety first but by the nature of the work there is risk.
the discision regarding putting the A/C in a compromised position i would have thought that most Pilots would have had these sort of dicusions in the crew room on many occasions before the situation that is currently being dicussed happens and I would have thought that he would know what limits he will go to and to what limits his crew would and way up the options from there.
Sincerely
Bravo 99 (AJB)
Just to add though I think we all know what discision all pilots would take but as we all are saying. having the potential for prosecution hanging over the final decision seems heavy unfair and almost unjust. unfortunatly this probably will not change things and the threat will always be there. I just hope that on the day it happens all the cards are stacked in the pilot and crews favour.
B99
has a point and i would agree that this is a very emotic subject. But i would have thought that one must way up the gain with the potential for loss. it is like saying that you could not send a B.A Team into a burning building on a persons reported shout (B.A = breathing Apratus Persons reported = People trapped ) becouse there is a possablilty of the pump failing and the crew lossing water. It is a pluasable argument but the risk must be looked at to the gain. as previously stated safety first but by the nature of the work there is risk.
the discision regarding putting the A/C in a compromised position i would have thought that most Pilots would have had these sort of dicusions in the crew room on many occasions before the situation that is currently being dicussed happens and I would have thought that he would know what limits he will go to and to what limits his crew would and way up the options from there.
Sincerely
Bravo 99 (AJB)
Just to add though I think we all know what discision all pilots would take but as we all are saying. having the potential for prosecution hanging over the final decision seems heavy unfair and almost unjust. unfortunatly this probably will not change things and the threat will always be there. I just hope that on the day it happens all the cards are stacked in the pilot and crews favour.
B99
Last edited by Bravo 99 (AJB); 11th Jun 2004 at 20:08.
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Yes, an emotive subject.
I found myself in the position of having to dunk an Explorer's skids in the sea so the paramedic could lift out a drowning three year old girl.
Long before this we had discussed this possible scenario as a crew, following a similar incident in South Wales. The consensus was that we would help other agencies as much as possible but that risking the helicopter was a no-no.
When it came to the crunch, with a lifeboat or winch-equipped helicopter more than 15 minutes away, the decision was easy to make and I believe most pilots would have made the same decision. Do you watch a child drown or do you lift her out? The possibility of litigation never entered my head but the risk to the helicopter was certainly uppermost in my mind. As Bravo 99 (AJB) says, the cards were certainly stacked in our favour with an offshore breeze and gentle swell.
Of course the CAA took a great interest following the event but they were as pleased at the successful outcome as anyone. That's not to say that they wouldn't have jumped all over me if I had C***ed up, I was in no doubt that they would have!
I hope none of you have to make a similar decision, I certainly don't want to do it again. Our unit now carries a self-inflating device to chuck to survivors but that wouldn't have been of much use on the day.
Sorry this thread has gone off the Hospital Landing Site topic a bit, but I felt I should add my thoughts after reading it.
I found myself in the position of having to dunk an Explorer's skids in the sea so the paramedic could lift out a drowning three year old girl.
Long before this we had discussed this possible scenario as a crew, following a similar incident in South Wales. The consensus was that we would help other agencies as much as possible but that risking the helicopter was a no-no.
When it came to the crunch, with a lifeboat or winch-equipped helicopter more than 15 minutes away, the decision was easy to make and I believe most pilots would have made the same decision. Do you watch a child drown or do you lift her out? The possibility of litigation never entered my head but the risk to the helicopter was certainly uppermost in my mind. As Bravo 99 (AJB) says, the cards were certainly stacked in our favour with an offshore breeze and gentle swell.
Of course the CAA took a great interest following the event but they were as pleased at the successful outcome as anyone. That's not to say that they wouldn't have jumped all over me if I had C***ed up, I was in no doubt that they would have!
I hope none of you have to make a similar decision, I certainly don't want to do it again. Our unit now carries a self-inflating device to chuck to survivors but that wouldn't have been of much use on the day.
Sorry this thread has gone off the Hospital Landing Site topic a bit, but I felt I should add my thoughts after reading it.
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just discover this thread...
it's not only a UK or CAA problem... as mentioned above, it reverts to regulations set down by JAR-OPS 3 and the requiremtents a pilot has to fullfill to be able to fly to or from a landing spot.... the requirements are quite restrictive and if put into full force would not allow any landings at most hospital sites anywhere because they do not fullfill the necessary standards. For example, it is not allowed for a single engined heli to fly over difficult environment or to an elevated landing site. So all heli operations must have twin-engine heli's for most HEMS flying. The police and SAR are exempt from JAR-OPS but do, at least here in Germany, try to comply.
In the end it looks like helipads must meet the ICAO requirements. This means an elevated landing site having at least 1,5 times the length of the largest heli flying there (though how are we to know how big future heli's may be?) . ...plus many more difficulties. Actually, because of obstacles found on most hospitals, only elevated sites may in the future be possible.
The various German operators have been discussing this problem for 3 years now but still no proper solution.
In a desperate emergency, it is in the end the pilots decission whether he lands or not. And, if something goes wrong, it'll be the insurance companies that hang him or the company he flies for.
Yes, it's sensible to have the landing sites regulated to a certain degree, but what the new EU regulations are asking for will make flying direct to hospitals nearly impossible.
These regs, as mentioned before, have been floating around for about 3 years now... the outcries are coming a bit late. The German CAA is trying to have the ICAO regulations applying only to sites with more then 400 takeoffs and landings a year... but my opinion is, either the site is safe or not.... you can't go according to a number!!
It's nice to know, that not only over here we are getting upset about all this.... I just wonder, who in the EU came up with these regs in the first place
Westy
PS. sorry for the length.....
it's not only a UK or CAA problem... as mentioned above, it reverts to regulations set down by JAR-OPS 3 and the requiremtents a pilot has to fullfill to be able to fly to or from a landing spot.... the requirements are quite restrictive and if put into full force would not allow any landings at most hospital sites anywhere because they do not fullfill the necessary standards. For example, it is not allowed for a single engined heli to fly over difficult environment or to an elevated landing site. So all heli operations must have twin-engine heli's for most HEMS flying. The police and SAR are exempt from JAR-OPS but do, at least here in Germany, try to comply.
In the end it looks like helipads must meet the ICAO requirements. This means an elevated landing site having at least 1,5 times the length of the largest heli flying there (though how are we to know how big future heli's may be?) . ...plus many more difficulties. Actually, because of obstacles found on most hospitals, only elevated sites may in the future be possible.
The various German operators have been discussing this problem for 3 years now but still no proper solution.
In a desperate emergency, it is in the end the pilots decission whether he lands or not. And, if something goes wrong, it'll be the insurance companies that hang him or the company he flies for.
Yes, it's sensible to have the landing sites regulated to a certain degree, but what the new EU regulations are asking for will make flying direct to hospitals nearly impossible.
These regs, as mentioned before, have been floating around for about 3 years now... the outcries are coming a bit late. The German CAA is trying to have the ICAO regulations applying only to sites with more then 400 takeoffs and landings a year... but my opinion is, either the site is safe or not.... you can't go according to a number!!
It's nice to know, that not only over here we are getting upset about all this.... I just wonder, who in the EU came up with these regs in the first place
Westy
PS. sorry for the length.....
I'm not particularly concerned about the litigation aspect per se. However, I have to remind myself occassionally that:
(a) I (as a police helicopter pilot), am flying 'punters' around. Fee paying passengers. Would I divert offshore to save someone if I had a cab full of punters from a race course on the way home? (excessive example accepted) but that's how the CAA/JAA perceive the carriage of police observers.
(b) I am no longer SAR current, and observers are most certainly not rescue trained.
Therefore my major concern would be:
whilst in the process of exercising my (self perceived, blown up) excellent piloting skills and expertise, I blow the rescue, I inadvertently kill 2 passengers and land on top of the drowning victim....Risk management or what?????
My family pay for it emotionally and financially for the rest of their lives.
I've just read a report about a neighbouring police force to ours who went thru just this experience for real recently. They witnessed the falling into a fast flowing freezing river of a scrote(!) followed by the dog who chased after him , followed by the dog handler who went in to save his dog!
The chopper stayed with them and did a very professional job acting (no doubt)as a comms link, threw stuff into the water to help, but in the report I read, didnt actually fly down and effect a physical rescue. That decision must have plumbed the emotional depths of that crew!
Alternative rescue vehicles eventually saved the day due to a co-ordinated effort..........
Gotta get your head round these decisions before the day of the race. Too much adrenaline at the time to think straight...methinks
Westwind 1950: thanks for the input from Germany. Is there ever light at the end of the tunnel, will there be a solution or can you persuade the authorities to delay the regulations for ever!!!!
(a) I (as a police helicopter pilot), am flying 'punters' around. Fee paying passengers. Would I divert offshore to save someone if I had a cab full of punters from a race course on the way home? (excessive example accepted) but that's how the CAA/JAA perceive the carriage of police observers.
(b) I am no longer SAR current, and observers are most certainly not rescue trained.
Therefore my major concern would be:
whilst in the process of exercising my (self perceived, blown up) excellent piloting skills and expertise, I blow the rescue, I inadvertently kill 2 passengers and land on top of the drowning victim....Risk management or what?????
My family pay for it emotionally and financially for the rest of their lives.
I've just read a report about a neighbouring police force to ours who went thru just this experience for real recently. They witnessed the falling into a fast flowing freezing river of a scrote(!) followed by the dog who chased after him , followed by the dog handler who went in to save his dog!
The chopper stayed with them and did a very professional job acting (no doubt)as a comms link, threw stuff into the water to help, but in the report I read, didnt actually fly down and effect a physical rescue. That decision must have plumbed the emotional depths of that crew!
Alternative rescue vehicles eventually saved the day due to a co-ordinated effort..........
Gotta get your head round these decisions before the day of the race. Too much adrenaline at the time to think straight...methinks
Westwind 1950: thanks for the input from Germany. Is there ever light at the end of the tunnel, will there be a solution or can you persuade the authorities to delay the regulations for ever!!!!
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Westy:
Your post is confused and confusing.
What you have not mentioned is that German Regulations do not contain the latest text of JAR-OPS 3 which deals with most of the issues you have raised. The JAA does not have competence on Heliports/Helidecks or Aerodromes - they are still the responsibility of the State.
The latest version of JAR-OPS 3 (Amendment 3 - 1st April 2004) - in the cases you have mentioned - is not
Whilst it is correct that a helicopter operating in Performance Class 3 is not permitted to fly over a hostile environment (except under a specific approval), that provides compliance with ICAO Annex 6 Part III. It is not true that such helicopters cannot operate to an elevated heliport under JAR-OPS 3.
As mentioned before, compliance with the heliport Standards contained in ICAO Annex 14 is an issue for the State and is not regulated under JAR-OPS 3. Whilst the 1.5D that you quote comes directly from Annex 14, most Flight Manuals require a larger FATO than that (2D being a average size).
It is not clear to me (and probably others) what particular EU regulations you are quoting here - it is certainly not JAR-OPS 3.
I would suggest that as soon as the German Regulations are brought into harmonisation with the latest version of JAR-OPS 3, the problems that you are describing (for HEMS in Germany) will disappear.
Once the latest proposal for amendment of JAR-OPS 3 are published, you will also see that the link between the Category A procedure (which drives the permitted size of the heliport) and Performance Class 1 has been broken; this will allow the size of the heliport to be directly related to the performance of the helicopter and legitimise operations to most of the elevated heliports at German hospitals (without alleviation).
Your post is confused and confusing.
What you have not mentioned is that German Regulations do not contain the latest text of JAR-OPS 3 which deals with most of the issues you have raised. The JAA does not have competence on Heliports/Helidecks or Aerodromes - they are still the responsibility of the State.
The latest version of JAR-OPS 3 (Amendment 3 - 1st April 2004) - in the cases you have mentioned - is not
quite restrictive and if put into full force would not allow any landings at most hospital sites anywhere because they do not fullfill the necessary standards.
As mentioned before, compliance with the heliport Standards contained in ICAO Annex 14 is an issue for the State and is not regulated under JAR-OPS 3. Whilst the 1.5D that you quote comes directly from Annex 14, most Flight Manuals require a larger FATO than that (2D being a average size).
Yes, it's sensible to have the landing sites regulated to a certain degree, but what the new EU regulations are asking for will make flying direct to hospitals nearly impossible.
I would suggest that as soon as the German Regulations are brought into harmonisation with the latest version of JAR-OPS 3, the problems that you are describing (for HEMS in Germany) will disappear.
Once the latest proposal for amendment of JAR-OPS 3 are published, you will also see that the link between the Category A procedure (which drives the permitted size of the heliport) and Performance Class 1 has been broken; this will allow the size of the heliport to be directly related to the performance of the helicopter and legitimise operations to most of the elevated heliports at German hospitals (without alleviation).
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hi Mars,
When I say EU I'm referring to JAR-OPS. Unfortunately we have a BIG problem in Germany... we must first TRANSLATE the ammendments into German before they can be put into effect...and put into law.... and that takes forever (besides being sometimes quite wrong!). At the moment we are working only with change 1 !!! I don't even possess a draft of 2 or 3! and I hear there is a change 4 out there somewhere. You in the UK don't have this problem
So, our problem is trying to advise the heliport owners as to how to build or rebuild their sites... only to have lots of money invested which later turns out to have been possibly unnecessary.
It would be very sensible if the EASA can finally take over this... but in a sensible way. Then we no longer would have to wait for the "official" translations..... on the other hand, most of the Germans at the various authority offices don't speak or understand English... another VERY BIG problem!!
Westy
When I say EU I'm referring to JAR-OPS. Unfortunately we have a BIG problem in Germany... we must first TRANSLATE the ammendments into German before they can be put into effect...and put into law.... and that takes forever (besides being sometimes quite wrong!). At the moment we are working only with change 1 !!! I don't even possess a draft of 2 or 3! and I hear there is a change 4 out there somewhere. You in the UK don't have this problem
So, our problem is trying to advise the heliport owners as to how to build or rebuild their sites... only to have lots of money invested which later turns out to have been possibly unnecessary.It would be very sensible if the EASA can finally take over this... but in a sensible way. Then we no longer would have to wait for the "official" translations..... on the other hand, most of the Germans at the various authority offices don't speak or understand English... another VERY BIG problem!!
Westy
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THomas coupling
I have to say that you have a very valid point.
out of curiosity, and not knowing what is written in the POM is it possable that there is something written regarding this type of situation, which could assit in the correct line of thinking ( ie something to sway the dicision) rather than a dicision as you say based on the day/adrenilin etc.
It would be interesting to see if there is.
Sincerely
Andy
Bravo 99 (AJB)
I have to say that you have a very valid point.
out of curiosity, and not knowing what is written in the POM is it possable that there is something written regarding this type of situation, which could assit in the correct line of thinking ( ie something to sway the dicision) rather than a dicision as you say based on the day/adrenilin etc.
It would be interesting to see if there is.
Sincerely
Andy
Bravo 99 (AJB)
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Thomas
I have to agree that risk management is important and that the role of a police unit is not to have the "derring do" mentality. However, the POM cannot legislate for every situation. Are you saying that a police crew should never exercise their judgement? In particular, do you think it was wrong to rescue the drowning girl? What would you have done?
I have to agree that risk management is important and that the role of a police unit is not to have the "derring do" mentality. However, the POM cannot legislate for every situation. Are you saying that a police crew should never exercise their judgement? In particular, do you think it was wrong to rescue the drowning girl? What would you have done?
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Westy:
It appears to me that the solution is quite clear - keep the versions in synchrony - the German hospital problem has been dealt with by the Authors of JAR-OPS 3; if you as a Nation wish to ignore the solution - so be it.
If the translation of (the amendments to) JAR-OPS 3 into German costs more than the building of a single Annex 14 heliport, I would be astonished.
How you can advise the heliport owners on the building, or re-building, of their sites when you do not even know what the current regulation contains beats me. You (Germany) might wish to conduct a discussion with the Authors of JAR-OPS 3 - it would appear that they have a comprehensive understanding of the hospital problem and have already provided appropriate solutions.
Maybe a temporary solution is for the MOT/LBA/Lande to permit (pro tem.) operators to use the latest version of JAR-OPS 3 whilst the regulations are being updated. Any other State would have already permitted this by using JAR-OPS 3.010 - Exemptions as the basis for amendment of the Operations Specification for each HEMS Operator.
This discussion was first conducted at AIRMED 2000 in Stavanger and led to substantial guidance being put into JAR-OPS 3 at the next amendment cycle. You might wish to obtain the latest copy of JAR-OPS 3 and read Section 1 and, in particular, Section 2 of Subpart B - you will find them revealing.
EASA is not the answer to this, you will merely pay for the translation in another way.
It appears to me that the solution is quite clear - keep the versions in synchrony - the German hospital problem has been dealt with by the Authors of JAR-OPS 3; if you as a Nation wish to ignore the solution - so be it.
If the translation of (the amendments to) JAR-OPS 3 into German costs more than the building of a single Annex 14 heliport, I would be astonished.
How you can advise the heliport owners on the building, or re-building, of their sites when you do not even know what the current regulation contains beats me. You (Germany) might wish to conduct a discussion with the Authors of JAR-OPS 3 - it would appear that they have a comprehensive understanding of the hospital problem and have already provided appropriate solutions.
Maybe a temporary solution is for the MOT/LBA/Lande to permit (pro tem.) operators to use the latest version of JAR-OPS 3 whilst the regulations are being updated. Any other State would have already permitted this by using JAR-OPS 3.010 - Exemptions as the basis for amendment of the Operations Specification for each HEMS Operator.
This discussion was first conducted at AIRMED 2000 in Stavanger and led to substantial guidance being put into JAR-OPS 3 at the next amendment cycle. You might wish to obtain the latest copy of JAR-OPS 3 and read Section 1 and, in particular, Section 2 of Subpart B - you will find them revealing.
EASA is not the answer to this, you will merely pay for the translation in another way.
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This thread has prompted my first post.
Regarding SAR I have never once had the CAA question the judgement of the crew in carrying out any tasking.
These are non-normal usually one off events that must call on the judgement of the rescue services at that time.
What the regulators are concerned about is the regular and planned use of landing sites, which do not offer a certain level of safety to third parties, casualties and crew (in that order).
I fully support this concern.
Hospital landing site usage has or will increase for the following reasons:
1) The are more helicopters
2) Medical staff are covering themselves
3) Shortage of Ambulances so Helos used instead
4) NHS stretched so patients being moved long distances to where there is a free cot/bed etc
Very recently our SAR unit has had various secondary tasks which involved patient transfer many hundreds of miles.
None of our team mind going out on a limb to recover a person or many persons in distress.
To then have to regularly “wing it” in and out of very small-unlit hospital landing site I consider questionable.
I fully agree with the regulators trying to improve margins of safety for hospital landing sites even if its only for the sake of the children sleeping in the house I’m having to narrowly avoid.
Can I respectfully point out to a previous poster that Civilian /Coastguard SAR is not constrained by any limits on operations other than the self imposed trade off between seriousness of situation/risk to third parties/aircrew/aircraft.
This applies to weather, performance or otherwise.
Regarding SAR I have never once had the CAA question the judgement of the crew in carrying out any tasking.
These are non-normal usually one off events that must call on the judgement of the rescue services at that time.
What the regulators are concerned about is the regular and planned use of landing sites, which do not offer a certain level of safety to third parties, casualties and crew (in that order).
I fully support this concern.
Hospital landing site usage has or will increase for the following reasons:
1) The are more helicopters
2) Medical staff are covering themselves
3) Shortage of Ambulances so Helos used instead
4) NHS stretched so patients being moved long distances to where there is a free cot/bed etc
Very recently our SAR unit has had various secondary tasks which involved patient transfer many hundreds of miles.
None of our team mind going out on a limb to recover a person or many persons in distress.
To then have to regularly “wing it” in and out of very small-unlit hospital landing site I consider questionable.
I fully agree with the regulators trying to improve margins of safety for hospital landing sites even if its only for the sake of the children sleeping in the house I’m having to narrowly avoid.
Can I respectfully point out to a previous poster that Civilian /Coastguard SAR is not constrained by any limits on operations other than the self imposed trade off between seriousness of situation/risk to third parties/aircrew/aircraft.
This applies to weather, performance or otherwise.
Praises to IMABELL.....the jar of Prunes idea is perfect....a sure way to get them moving...but I bet the recipients would really S--T!
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Presstransdown
You say
Are you saying that:
In practice the CAA don't question what civilian SAR pilots do when carrying out SAR ops,
or
Civvy SAR pilots are legally exempt from Rule 5 and legally exempt from being prosecuted for endangering an aircraft, people or property when carrying out SAR ops?
If you mean the second, it sounds reasonable but where is that written?
You say
Civilian /Coastguard SAR is not constrained by any limits on operations other than the self imposed trade off between seriousness of situation/risk to third parties/aircrew/aircraft.
This applies to weather, performance or otherwise.
This applies to weather, performance or otherwise.
In practice the CAA don't question what civilian SAR pilots do when carrying out SAR ops,
or
Civvy SAR pilots are legally exempt from Rule 5 and legally exempt from being prosecuted for endangering an aircraft, people or property when carrying out SAR ops?
If you mean the second, it sounds reasonable but where is that written?
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@Mars
thanks for your reply.... I wish it was that simple. We had fairly "usable" regulations for heliports dating 1969... they required an area of 15 m X 15 m plus a 10 m safety margin on each side. Unfortunately, not even this "basic" regulation was used for hospital sites.... the arguement being that pilots trying to save a life can ignore all rules .....sure, and there have luckily been hardly any accidents... but the ones that did happen received from the heliport owner (hospital CEO) only the reply, that since the port wasn't certified, it was souly the pilots problem 
When the JAR-OPS first came out, people suddenly started waking up to the problem... special groups were formed to talk things through... make suggestions. Unfortunately, the results are not very satisfying.... and there is no way that the further amendments can be applied until they are OFFICIALLY translated and OFFICIALLY put into German law! Sad but true.....
I could go on and on, but it wouldn't help much. For me it is very interesting to read how things are done elsewhere. Thanks again.
Westy
thanks for your reply.... I wish it was that simple. We had fairly "usable" regulations for heliports dating 1969... they required an area of 15 m X 15 m plus a 10 m safety margin on each side. Unfortunately, not even this "basic" regulation was used for hospital sites.... the arguement being that pilots trying to save a life can ignore all rules
.....sure, and there have luckily been hardly any accidents... but the ones that did happen received from the heliport owner (hospital CEO) only the reply, that since the port wasn't certified, it was souly the pilots problem When the JAR-OPS first came out, people suddenly started waking up to the problem... special groups were formed to talk things through... make suggestions. Unfortunately, the results are not very satisfying.... and there is no way that the further amendments can be applied until they are OFFICIALLY translated and OFFICIALLY put into German law! Sad but true.....
I could go on and on, but it wouldn't help much. For me it is very interesting to read how things are done elsewhere. Thanks again.
Westy
Just to clarify two points made earlier in this thread;
1. SiloeSid mentioned the hospital HLS directory (I am assuming he means the RAF one)
Inclusion of a site in this directory does not clear it for legal use by a commercial air ambulance operator.
2. Jellycopter talked about Rule 5 and "saving life"
Nowhere in the current ANO exemptions available to UK HEMS units is there any direct reference to saving life.
1. SiloeSid mentioned the hospital HLS directory (I am assuming he means the RAF one)
Inclusion of a site in this directory does not clear it for legal use by a commercial air ambulance operator.
2. Jellycopter talked about Rule 5 and "saving life"
Nowhere in the current ANO exemptions available to UK HEMS units is there any direct reference to saving life.
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Bertie
"Saving life" comes from Rule 5 itself.
Rule 5 (3) of the Rules of the Air says that (3) nothing in Rule 5 prohibits an aircraft from flying in such a manner as is necessary for the purpose of saving life.
Old Heliman says the CAA interprets that law to mean saving life only if there's an emergency involving the aircraft, but that's not what the Rule says.
"Saving life" comes from Rule 5 itself.
Rule 5 (3) of the Rules of the Air says that (3) nothing in Rule 5 prohibits an aircraft from flying in such a manner as is necessary for the purpose of saving life.
Old Heliman says the CAA interprets that law to mean saving life only if there's an emergency involving the aircraft, but that's not what the Rule says.
Purveyor of Egg Liqueur to Lucifer
Yes it was the 'RAF one' I was flicking through and I am aware that "Inclusion of a site in this directory does not clear it for legal use by a commercial air ambulance operator." 
As the thread was starting at the time, I was looking at the 3 clear route options of the various sites, purely out of interest as I'm sure that some must be used by 'commercial air ambulance operators'!
There doesn't appear to be many sites with that many options!!
Commercial air ambulance operators? in England? Bertie must be Scottish!
As the thread was starting at the time, I was looking at the 3 clear route options of the various sites, purely out of interest as I'm sure that some must be used by 'commercial air ambulance operators'!
There doesn't appear to be many sites with that many options!!
Commercial air ambulance operators? in England? Bertie must be Scottish!