Brainstorming HEMS

[Bob95fxdl]

Gents (and ladies, where applicable):

Let me first say that with my really vast () HEMS experience (all of a year and a half), I am not an expert in the field. I have, however, been flying helicopters since 1979, served since 1985 as an IP, SIP, and IFE, as well as being a Safety Officer, so I will claim some expertise on that end. I'd like to make a few comments from my perspective in the US on the issue.

First, as to the articles from Dr. Bledsoe: take them with an extremely large bucket of salt. If you read his latest article, "Saving the Air Medical Industry," carefully, you'll notice he has little to say about HEMS that is good. Though he doesn't claim to be an expert, he leads you to think he is. Makes you wonder if there are some sour grapes in there somewhere. Perhaps he was fired because of attitude or something similar; I can't say. I would like to hit on some of the things he and others have addressed, then go to other aspects:
1- HEMS must be dispatched through the local/regional EMS system: I'm not sure what he is referring to. In the Community-Based Systems (CBS), this is already done. The problem actually lies with the EMS Dispatch. They are the ones who do the "copter shopping," not the company dispatch.
2- Require two pilots on every aircraft: this would immediately minimize the effectiveness of almost every CBS and most HBS and probably close them down. Why? Probably the most common and cost-effective aircraft in the HEMS industry is the AS350 and its variants. With an crew of three and two hours of fuel, in most cases, the aircraft is limited to about 200-300 pounds of patient at liftoff. Add in another 150-200 pounds of second pilot and, well, you see the issue. You'd have to get a bigger aircraft, which costs an extreme amount of money when one looks at the number involved, or cut the range drastically by reducing fuel loads to carry the extra pilot weight.
3- Don't attempt scene flights after dark: Is he kidding? That's when we're needed the most. Most EMS services are thoroughly trained by the HEMS providers how to select an LZ, mark it well and park vehicle under or by hazards, in order to ensure the aircrew is aware and avoids the obstacles.
4- Both the transferring and receiving hospitals need to have IFR approaches to their helipads: this one is plain stupid. If he or anyone he knows has ever TERP'd (planned/designed an IFR approach)(I'm also an Instrument Examiner) an approach, in over 98% of the hospitals, it would be impossible to meet FAA-mandated requirements for proximity and safety.
5- Require Night Vision Googles: While I agree about the need, one must also realize that the priority remains with the military. There are other companies working to make more of them, but they must all meet the same standard, lest we create a whole different set of standardization problems.
6- FAA Statutes Need EMS-specific rules and regulations: I do agree with this. The biggest issue I see within the HEMS arena is competition and the lack of standards within the community. My company, the biggest one in the US, has very clearly defined rules and regulations and will not tolerate anyone violating them. They would rather lose a flight than compromise safety. That's why I signed on with them instead of their competition, though I would have been paid more.
7- Weather mnimums must be stricter: Minimums are just that, minimums. Training and common sense must prevail. Within our firm, there is a simple policy of "Three to Go, and One to say No." If anyone feels uncomfortable, he/she has the freedom to turn down the flight, with no repercussions, even if the pilot disagrees and feels comfortable.
8- Limited work periods for mdical crew members: I have mixed feelings on this, but there's already a solution, at least within our company: If a crew is tired after numerous flights, they can stand down and there is no repercussion. By FAA regulation (and company policy), pilots are expected to come to work well-rested and prepared to be on duty and flyable for twelve hours. Currently, there's nothing regulatory that says the same about med crew personnel. I personally know of numerous med personnel who come off their hospital or EMS shift to HEMS and expect to be able to catch naps or sleep during their 24-hour shift. I do consider this a potential for incurring loss of situational awareness, but it is beyond my level to dictate. I don't, however, hesitate to take the station out of service and require the med personnel to get some sleep if I see their alertness (or the lack thereof) becoming a potential safety issue. To date, I've never been challenged on those decisions.

Having said all this, I see three issues being the solution to these problems:
1- Training, and more training. I don't know of any HEMS company that hires anyone without at least a CP rating, which requires them to be instrument rated. A high percentage are ATP-certified.
2- Clearly defined (and standardized) minimums and policies. As much as I hate to say it, if we cannot fix this problem ourselves, the FAA will have to do it for us, and we probably won't like the result.
3- Establish a separate Certificate within the FAA for EMS Flight, covering both RW and FW operations. This will eliminate the competition and resulting shortcuts and pressure (see #2 above).

It's time for me to get off my soapbox. I'm sure there are others who have their own opinions too, so I'll back out for now. Regardless, we do need to work to fix the problems, but we need to keep the rhetoric and inflammatory comments out of the discussion. JMTCW.

Bob in GA

[Gomer Pylot]

I agree that Dr. Bledsoe is pretty clueless. He clearly has an agenda, and (cherry)picks facts and statistics (not the same things) that further his agenda. He seemingly has only limited experience with HEMS operations, mostly hospital-based programs in urban areas. I have read some of his writings, and they just make me shake my head in wonder.

I have to say once again that IFR is not the answer. Having an instrument rating, and the basic instrumentation to recover from inadvertent IMC is essential, but filing and flying IFR is out of the question for scene flights, unless the regulations and technology change drastically. Transfers aren't much different in most cases. Avoiding IMC in the first place is the important thing.

[DTibbals53]

Us Hems

Great comments by all! Very constructive, with a minimal amount of emotionalism involved.

I agree with the regulation as a necessary evil. A timeline for compliance is the norm in the US and there is no reason that an implementation period of 10 years or so would not be effective and prudent.

Dual pilot, twin engine IFR capable aircraft is not only desirable, it is, in my opinion, desprately needed. Airframes are, or should be, updated and upgraded on a recurring basis. 30,000 hours is a bit too much to expect from a rotorcraft performing all of its flights within 3% of max gross weight. Replace them, over time, with more capable airframes. With the huge profits being realized by the operators, this should not be a deal breaker. Even if paring back some of the more densly served areas by closing a base, it can be done, especially if all of the operators must comply.

JimL, you posted: "As a matter of interest I see that the FAA is just about to publish, for comment, new OpSpecs "A021 Helicopter Emergency Medical Services (HEMS) Operations" and "A050 Helicopter Night Visions Goggle Operations (HNVGO)" which contain detailed site, qualification, dispatch and weather criteria."

The A021 proposed is a sweeping reform forcing operators to do away with the Class G operations and MVFR activities. It is proposed that the operators, except when on takeoff or landing, fly at altitudes of 1,000 feet above the highest obsticle, and avoid towers, etc., by 5 miles laterally when below that threshold. With towers at 2,100 feet AGL, that means cruise flight at 3,100 feet. Weather minimums would be 3,600 ceilings. Quite a change from the current 800 day cross country requirements. I think it will benefit the industry greatly.

Fly Safely out there. One more crash is too many.

[Quichotte]

JimL,

in deep respect for you and your knowledge, Tec pointed right.

I'm a HEMS pilot in a JAA Land under the latest OPS 3 Amendment flying single pilot at night with HCM. It's a public operation. We have mountains up to 4000ft in the "specified area".

Sitting on my desk and looking around i see:

my licence: JAA without IR
my logbook: 5000h incl. 1000h VFR night single pilot
trought the window i see: an older twin equipped according to JAA night HEMS, means HSI and AH but without IR certification, without AP and without weather radar or other gimmicks. Radar altimeter not needed on-shore.

Facing me is my HCM, a very warm and nice friend and collegue. Like all of our HCM he is only on freelance here. In their main business our HCMs are paramedics or fire fighters in other ground based public services and do not see helicopters. They have round about 1-4 shifts each month, divided between day and night. If the weather is sometimes to bad to fly in their shifts or we have no requests they fly only one or two night missions in 3 months. They got a initially 3-4 days HCM course approved by the CAA and a refresh one day per year. They know not much about flying (especially at night) and their only way to assist the pilot is to hold a spot light, a map, to turn on a new frequency or the GPS. Under daylight conditions they are able to navigate by map, but mostly not in the dark. They have no flight ops radio certificate. During the patient legs they are sitting mostly in the back.

Safety at first. Therefore we do each year of course the whole CRM and safety courses. Safety courses are much cheaper than better instruments or a second pilot.

I try to understand you and the JAA but there are to much backdoors in OPS3.

[JimL]

Hi Quichotte,

I have sent you a PM but probably need to put something on the record here. Your post has been read with interest but it is not clear what changes you would like to be made.

As was stated earlier in support of Gomer's post, it is not clear to me what useful capability IFR would add to HEMS - particularly as you indicate that you are in a relatively mountainous area. The requirement for an IR and certification for flight into IMC for the aircraft was examined some time ago but were not seen to be cost-effective. In particular, the requirement for instrument recency every six months was inserted because it added instrument competence without the need for the formal procedures - which takes up the majority of time in an IR (and is largely self-serving). The additional time to achieve a pass in the six monthly instrument procedures check and the yearly IR test were seen as problematical (not cost effective) in an operation that is essentially VFR and where recency could not be maintained.

An aircraft that has been certificated for flight in IMC will add the required stablility (the autopilot essentially adds flight director functions) but is unlikely to provide any more instruments - as those specified in Parts 27/29 are essentially the same as those required in JAR-OPS. No small aircraft that I am aware of is equipped with weather radar; RADALTs are essential over water but only useful over land.

If your HCM complies with all of the training and checking requirements of JAR-OPS (Subpart O and elements in the HEMS Appendix - which are almost entirely aviation related) but you consider that he/she is still underqualified (no you did not say that), you need to take that up with your company via the safety reporting system (which needs to address the safety case that should have accompanied the request for the two-pilot derogation). As was stated by Shawn, if the HCM is in the second pilot's seat on the way to the scene, there is value added in the additional pair of eyes; outside to see danger and inside to support and monitor your actions.

If you have a specific request to make then best raise it now and it can be resolved during the three months consultation period for EASA Ops. If I can I would like to assist in any request but first need to understand what it might be.

Jim

[helmet fire]

I am fascinated by the IFR reluctance as I believe that it is a lynch pin in making HEMS safer. I know that individual operating environments will make IFR impracticable and even down right dangerous: the Swiss Alps and Air Zermatt's operating environment springs to mind, as well a the environments you guys are describing above. In fact, the company I work for has it's main area restriced to about 22 minutes flight time radius.

But still I advocate IFR and an instrument rating checked regularly.
IFR gives you an irreplaceable skill set to cope with adverse situations, wether they be deteriorating weather, turning inside bowl feateures in the mountains, ending up in a low speed loss of visual reference event (brown out, white out), a loss of NVG image at low level, Inadvertent IMC, etc. It gives you an appreciation of lower safe altitudes and their employment, it gives you an aircraft with higher instrumentation requirements and eith two pilots or preferably a SPIFR autopilot. All these things will dramatically aid HEMS pilots, no matter what environment they operate in. Once capital expenditure for equipment (aircraft and sim if needed) is taken into account, the skill upkeep costs are not really that expensive. Get in the sim every month, ensure an IIMC event is practiced (with screens and foggles) every checkride you do, etc, etc.

A friend has supplied the following information that I think helps explain the cultural differences about the current US system and what I am advocating in my list:

"What really astonishes me is the almost universal belief among us US EMS pilots that IFR could not possibly add anything useful to our operating environment. And yet, when you talk in depth to them, you realize that their concept of IFR is of a flight ending in an ILS to minima at an airport 10 out of 10 times -- unless they are lucky enough to have a GPS approach to a hospital with minima below the legal VFR ceiling"

I guess that one of the issues, I am advocating IFR for a safety and skill set use primarily, and an operational advantage secondarily. In Oz, we would use the IFR to the nearest approach and transit to the hospital HLS from the break visual point IF THE WX PERMITS. Otherwise we land and road it from the airport or hospital we got into. He continues:

FAR Part 135 contributes to the problem. Under Part 91 you can file to or from a place that doesn't have approved Wx provided you carry an alternate. Part 135 requires an approved weather source at both places without exception -- which excludes most of the hospital helipads. Because IFR is so hard to access and is so rigid -- VFR is seen as the only viable alternative. Couple that with the fact that VFR is VFR whether it is flown in dark air or light air -- and the system just encourages people to rely on the Mark 1 eyeball to spot the radio masts. (Before GPS we had to glance at our maps occasionally and might have noticed the towers -- but now that we don't have to use the maps to navigate many pilots don't bother to consult them for information about obstacles either.)

I think this is the part of our list surrounding IFR Infrastructure. If the above is accurate, it seems that the regulations could possibly be more supportive in this requirement in terms of outcome. In Oz we would get the area forecast if departing from an HLS without a specific forecast or report, then use the forecast for the arrival approach or an aerodrome very close by. That seems to me to meet the intent of the US system without prescribing the exact point of departure/approach and thereby significantly altering the outcome of it's use. I can see the dillema you guys are facing. I believe this is part of the 10 year step toward the creation of a helicopter specific IFR structure.

Am I getting on the right track to understanding the IFR system (or problems) in the US?

Lastly, I think he makes a very intresting point about human factors and the proliferation of GPS systems into our world.

[Shell Management]

hf
You've got it. While as you and I may see INSTRUMENT as the key word in IFR, in the US the key word is RULE. US is still fixated by rules and traditionally the FAA is reluctant to change to make them practical.

NTSB are to have a hearing in February: SB-08-51

Of course there are regualtors in Europe who get fixated by their rules (though without the reluctance to tinker!) and ignore the implementaion irregularities Quichotte highlights.

It suits most US companies to 'blame' the FAA for tying their hands or their crews for rule-breaking. The FAA's punitive approach encourages this victimisation of crews and a reluctance to report near-misses.

Bob95fxdl

Most EMS services are thoroughly trained by the HEMS providers how to select an LZ, mark it well and park vehicle under or by hazards, in order to ensure the aircrew is aware and avoids the obstacles.

Interesting. To what standard is this done?

[tecpilot]

Of course there are regualtors in Europe who get fixated by their rules (though without the reluctance to tinker!) and ignore the implementaion irregularities Quichotte highlights.

Since OPS 3 with HEMS we had a lot of long faces in Europe. The HEMS market changed completely. Since Appendix 1 to JAR-OPS 3.005(d) HEMS costs strong increased. It's easy to understand that civil and public operators paid some paperfoxes and attorneys to find out the holes in Appendix 1.

One of the holes is the night operation with HCM and no strict requirement where his place have to be.

My most beloved words in OPS 3 are:

"The Authority may exceptionally and
temporarily grant an exemption from the
provisions of JAR-OPS Part 3 when satisfied that
there is a need and subject to compliance with any
supplementary condition the Authority considers
necessary in order to ensure an acceptable level of
safety in the particular case."

We have a lot of exemptions in the member countries of JAA.
A few days ago: Switzerland is now also on OPS 3.
First thing they have done, is to cancel the need of twins in HEMS under special circumstances. Now let's wait how the things are going on.

A few months ago i have learned that a UK based HEMS operator thinks about to fly without MD (MedPax), only the HCM and the pilot. I don't know if this is still in progress, but such plans seems to be legal on the first view but it's not a step forward in safety. If the HCM is busy with the patient the pilot is alone.

But no blame to the JAA and our respected JimL! JAR-OPS 3 was a big step in the right direction.

[alouette3]

Shell Management:

The dimensions required for an unprepared LZ are typically written down in the company General Opearations Manual and Ops Specs. Both these documents are approved by the FAA and hence carry the full weight of regualtory authority behind them.Now, do the ground units konw of these dimensions or even care? Probably not. But efforts are made to educate them by individual programs on a regulsr basis. After all this , if we show up at an LZ that does not look suitable in size ,shape,slope or obstructions, it is still the PIC 's decision whether to accept or reject the LZ chosen. I have rejected a few in my time and a new LZ that met the criteria was qucikly set up.
So, it is not a complete wild west show out here. There are regualtions and standards which are fairly strictly imposed by the company and the FAA.
Alt.3

[victor papa]

The point was made earlier and I for one would also like to clarify that I am pro IF rated pilots onboard with the necessary instrumentation for inverted IFR ops(not necessarily an iFR certified aircraft). HEMS should in my opinion, based on my region, always remain a VFR ops and should seldom end up in iFR(the unplanned oh Sht scenario only). Except for 2 airports in a massive country(not US/Aus) there are no standby radar at any other airports so only 1 aircraft allowed at a time during iFR conditions in the circuit. We have massive traffic flow with 4 airlines covering the country. Despite our distances to be flown, this alone will lead to a emergency out of fuel landing and once the iFR req is satisfied the expectation will be there.

I ask again someone to give me a helicopter in this class that can satisfy the minimum requirement of 2.5hrs range, 6000ft, 35 degrees, 1 plt + 2 crew (100kg/person) and full IFR. Again, I agree with the IF pilot rating +training + experience and as I have said before a HSI, radio alt, EGPWS and tCAS as a must on top of the normal minimum equipment instruments, but in the circumstances above is there an IFR light twin who will enhance the safety in those conditions at the cost and expectation=pressure associated with it?

Maybe I lost the plot somewhere?

[Gomer Pylot]

Helmet fire, my reluctance to require IFR comes from the following. First, the fuel requirements are onerous. We carry just enough fuel to get the fllights done VFR, and if we put more on we can't carry a patient. Second, going IFR to scene flights, which are most of what we do, would often require an IFR flight to an airport 30 miles or more away, then transitioning VFR to a scene 10 or 20 miles in the other direction. When we have fully instrumented aircraft capable of flying ad hoc IFR approaches to an unprepared scene, regulations permitting that, and the fuel/payload capacity to do that, then IFR becomes attractive. That is decades away, at the earliest, IMO. Hospital transfers in my area are pretty much the same - no IFR airports anywhere near them, so IFR just isn't possible. The major receiving hospitals do have IFR airports nearby, but without weather reporting and TERPS application at the local hospitals, it's just not legal to depart from them IFR, nevermind fly there IFR.

[helmet fire]

I see your dilemma Gomer.
I would like to lift the focus off the current "why nots" and into the dreams of how we can makew it better. There is no doubt we need a close examination of the "why nots" so that we can accurately identify the current elements of our system that are inhibiting desired outcome.

I am not professing that you should go IFR everywhere. Such a requirement is purely regional and based on wx, etc, as is pointed out by VP. As to your fuel reserve requirements, that is part of the steps we are dreaming of: upgrade to a more appropriate aircraft! Dream a bit! In our region we regularly go IFR in HEMS. But the actual use of IFR is a secondary advantage to the safety layers it introduces in terms of loss of visual reference events, night operations, and situational awareness of obstcale clearance. Let alone cultural benefits that flow from introducing a professional skill development and retention program for the crews.

VP, you have stated your operational requirements many times and no-one has supplied an answer to satisy your needs. Such an answer is impossible without your detailed knowledge of the environment, wx, terrain, infrastructure, and of course budget. I understand that you are strongly in favour of a high powered single over a medium twin due to cost. To be honest, it sounds like you need to build an airfield and use a fixed wing.

However, a GPS approach costs approx $10,000 USD to set up, and these fundamentally free you from airports. This is part of the IFR Infrastructure that we need to start to dream about. There is no reason that you could not establish GPS approaches to stategic fuel reserves in your environment. It is currently feasable technology (and proven) to do a GPS approach to 85 ft AGL. That is lower than any ILS. And it is certainly lower than any VFR operators should safely be trying to get under. The technology is available now, we just need those willing to implement it. That will power will take on many adversities, not the least of which is cost.

The question then is: are HEMS ops cost effective? I would like someone else to start a thread on that topic so this one is not hijacked by the question, but I believe they are very cost benefitial.

Lastly re the HCM and the rumoured operation in the UK: Such an example (true or not) highlights why we have to make the rules so complicated. There is always someone avoiding intent and literally interpreting rules to their own advantage. Such a disregard of the intent of the HCM requirement will simply result in the best case an ammendment to Ops3 intracately prescribing the requirements and we will all whine about rule complexity. Worse case, it will remove the exemption for a HCM and replace with a second pilot. That is the also the danger of not properly training your HCM in aviation support skills: it will give the critics a reason to force the second pilot requirement on us all.

[WhirlwindIII]

IMHO

HEMS IFR, and the extent to which it is used is one thing. HEMS pilots training to IFR standards (including those on VFR operations to the extent possible) as one precautionary tool to allow them to effectively deal with some principle causes of accidents such as IIMC, altered planes of reference, is another. The latter can be implemented to some degree or other and should be.

Having to divert to an alternate destination, which may or may not have the medical expertise to meet specific needs, is a driving factor in defining the extent to which real IFR ops are utilized. It brings up the term soft IFR as bantered around in HEMS IFR for good reason - i.e. use IFR when one can't safely do the flight VFR, but keep it reasonably conservative on the real weather conditions to assure the patient gets in to the primary destination.

I don't see really low IFR ops in HEMS being medically practical but things do have a way of evolving.

WIII

[victor papa]

Helmet fire- I do not prefer the single for cost, but for range, power margin and simplicity of operation for the pilot. The only 2 singles I would push based on the above is the b3+ and the B4. We operate currently on GPS with terrain warning in all our Squirrels. The b4's have the KN150 and the one the EX500 all inclusive package incl Jepp etc. We do not do night ops currently but was looking at 2 pilot nvg ops in the B4. Budget is an isuue but not the major concern.

As was said before, a dangerto iFR remains mountains and despite us being at 6000ft we have lots of those with clinics in the valleys or mountain tops. Thunder storms and high wind conditions swirling from all directions is a given. We work our fuel range on a 15kt head wind both directions because you are not guaranteed of a head then tailwind scenario.

If I can dream I will take a N3 Dauphin and nurse her when heavy but have the range and IFR. 139 will also do great watching the range. Landing zones and clinic size will keep me stationary though. Most of the clinics are smaller than those 2. We use a Squirrel for a mobile clinic and the people think it is magic?

If I can really dream I will take a 225 in Jigsaw confic.

[helmet fire]

When we can generate threads upon threads and thousands of posts personally attacking each other and opposition companies, yet run out of input into brainstorming a solution to the perception of risk in one of our industry's most important and high profile sectors - do we need to look any further to find the root cause of the problem?

[havoc]

HEMS Hearings and proposed OP SPECS

Write Congress...we (the choir) do not have the authority to change things, only the decision necessary to safely complete the flight at hand.


FAA Invites Comment On Changes In HEMS Rules

[victor papa]

Helmet fire I can not agree with you more.

It is very obvious looking at the amount of people posting on the forums where the accidents are discussed vs those posting when a preventative discussion is going on like this one. We do not necessarily agree but on this topic I am with you 100%.

Maybe it is a case of we are quick to react(safer to hide and blame than to stick your neck out and make statements?) but not to prevent or brainstorm?

[JimL]

Helmet Fire,

It is clear what you are attempting to do but changing the culture by (pseudo) enforcement of an existing system is probably not the best approach. What might be required is to break out the various elements of the existing IFR system into its constituent parts to see what might be usefully employed. If you examine the ICAO Rules of the Air you will see that they are almost exclusively procedural - i.e. fly at a minimum level that achieves obstacle clearance; comply with the ATS system; when not within the ATS system (class G) fly at the correct quadrantal, submit a flight plan, maintain communication and give position reports. Only the first rule - that the aircraft should be adequately equipped with instruments and navaids - is outside the procedural approach. For those reasons, I agreed with Gomer that a wholesale application of the IFR system was not appropriate.

As is clear to most observers, there is a need for a culture change; however, this is made extremely difficult by the business (and political) model that is employed in some States. For the US, the FAA, although wishing to solve the problem, appear not to be able to modifiy FARs and therefore have to resort to exhortation and the provision of guidance. However, there has been a change of tack recently and the FAA have used the OpSpec method of enforcing more appropriate weather limits and departure criteria. Industry have contributed to the discussion of amendment to the OpSpec and their representatives have endorsed the changes. (We will have to see how this revision of the OpSpec plays out.)

One of the main problems that we face is that helicopters are intrinsically unstable. Without improvement in the basic handling qualities (usually provided by control augmentation), helicopters become progressively uncontrollable as the visual cue environment degrades. This is not so for fixed wing, and is the reason why they can be certificated for flight on instruments without the additional (handling quality) requirements that are contained in Appendix B of Parts 27/29. This is particularly an issue when flying at night; although the above codes do specify that flight at night/in IMC does require additional attention, it does not appear that additional rules are specified for flight at night. In fact, it is slightly worse than that because flight in daylight with a degraded visual-cue environment (DVE) is also problematical (but not when the weather limits are observed). For a reason which I have not yet fathomed, accidents that result from these circumstances are still categorised as CFIT when, clearly, control has been lost (perhaps the first thing that needs to be addressed).

What will not improve this situation (unless accompanied by an enhancement of handling qualities) is the addition of sophisticated synthetic vision systems (SVS) or enhanced vision systems (EVS) into the cockpit. Whilst SVS might have prevented the recent accident - where there was a flight into mast wires - it will do nothing for loss of control due to DVE. (Look to the discussion of the addition of GPS to the cockpit and the probable effects on safety.) If obstacles cannot be seen and avoided, then the flight is probably not being conducted under Visual Flight Rules.

Crewing is another issue; although HEMS can be undertaken single pilot, we, in Europe, have implemented a system where the second pilot seat has to be occupied (it is the primary role of the Hems Crew Member (HCM) to assist the pilot; it is this requirement that forces the necessity for adequate aircraft and not just performance - hence the replacement of the 'squirrel' in most European States). There is also a basic rule that, at night, there should be two pilots (although that can be alleviated for local operations - generally accepted to be 20-25nm where there is good cultural lighting). However, the latest HEMS twins are equipped for SPIFR and do not (necessarily) have a full two-pilot panel. There is also a (licensing) rule that requires one of the pilots to have an ATPL when two pilots are required by 'certification' or an 'operational' rule (this is way above the ICAO Standards). In the recent past, the ATPL has been a licence with an IR requirement - thus making the two-pilot rule very expensive.

So far this has been negative and, apart from the mention of improvement in the OpSpecs, doesn't provide many positive messages. However, the first part of the provision of any solution is to really understand the problem (and is the reason why the research being undertaken by the JHSAT was mentioned earlier).

There is no magic bullet but, If I were asked to provide a list of elements that might improve the HEMS accident record, these might be some:

1. Pilots should be educated on the dangers of not observing the weather limits for VFR.
2. Where the operation is such that reduced visibility/cloud-ceiling may be encountered (and in any case at night), the helicopter should meet the stability requirements of Appendix B to Parts 27/29.
3. The European rule for two-up-front should be adopted (and enforced) - any downgrading to one should result in the filing of a discretionary report.
4. The HCM should be regarded as a crew members and receive appropriate training and checking.
5. Every HEMS helicopter should be equipped with a full panel for at least the P1.
6. Every HEMS helicopter should be equipped for SBAS or GBAS.
7. Every HEMS pilot should be trained and checked for flight in IMC (without the procedural elements) - this should include three monthly refresher training.
8. All HEMS flights that include a landing at a HEMS Operating Site (scene) at night should be NVIS equipped (scene flights without NVIS should be prohibited)
9. All HEMS post holders should attend a HEMS management course (run by industry) and be accredited - this should a requirement under provisions of the AOC.
10. All HEMS operators should provide evidence that they meet the minimum requirements for performance and operations establish by the State.
11. HEMS operations should have appropriately constructed flight and duty times schemes (standby duties should receive appropriate treatment - i.e. not necessarily counted as full time).
12. HEMS operations should require a specific approval.

EASA have recently proposed an Operational Suitability Certificate to include a number of the elements mentioned above; although not yet published, it is expected next week. HEMS is a prime candidate for the application of such a certificate.

Jim

[Shawn Coyle]

JimL
Nice summary.
Sorry, but my LOTLA (Lexicon of Three Letter Acronyms) is missing the definitions of SBAS and GBAS. Can you please elucidate?

[JimL]

GPS - Satellite Based Augmentation System and Ground Based Augmentation System.

Jim