Brainstorming HEMS

[helmet fire]

Hi all,
prompted by many threads on US HEMS accidents I thought it might be educational (or at least of intrest) if we brainstormed some of the concepts that have been discussed as possible ways to mitigate the risks of HEMS, particularly night HEMS. There is no reason why a world wide look at the problem might possibly throw up elements for all of us to learn from for introduction into our own HEMS system.

Australia has not escaped the night HEMS accident scenario. The following is not a comparison of our HEMS system with anyone else's.

I was fortunate enough to be involved in a study tour of HEMS operations in Europe and although I did not do the US leg of the trip, others in my organisation did. I did however spend a year in the US earlier in my flying career. I dont offer this as evidence that what I am saying below is valid, simply that it is an opnion. Inevtiably it will also be a generalisation and suffer there as well. IT IS TO STIMULATE BRAINSTORMING THE ISSUE.

I have drawn heavily on previous threads and posts, particularly those of Nick Lappos and Shawn Coyle: this is a compilation of ideas, not just "my" ideas. Here are some ideas that may, in combination, mitigate the risk of HEMS operations:

1. Night flying requires reference to instruments. If you want to fly at night get an IFR rating. Even just the simplified en route IFR rating. 3 hours instruments required each 3 months to stay current. Renewals required each year.
2. Institute a night lower safe altitude even when VFR. Make it 1000 ft for VFR, and allow a lower one of 500 ft if using NVG or if IFR rated and in an IFR capable aircraft. 500 ft for day.
3. Institute go/no go weather minima. In black and white. Lower weather minima for IFR capable operations. I believe all operational restrictions should significantly advantage IFR programs, thus encouraging the upskilling to IFR and the adoption of autopilot equipped aircraft by outcome - this is the only effective way to get bean counters on board.
4. EASA crew standards implemented: two pilots up the front for all HEMS missions, day, night and IFR. Note: the second pilot may be a HEMS Crew member specifically trained in aviation skills on an approved front seat competency course.
5. Night operations outside of lit, prepared and established HLS or below 1000 ft require NVG.
6. Moving map systems mandatory as is required in several European HEMS programs.
7. The establishment of a low level IFR infrastructure and helicopter specific instrument procedures exploiting the low speed capability of the helicopter.
8. The establishment of ADS-B and GPS - W based infrastructure ASAP.
9. The fitment of an IR vision system and/or EGPWS conferring operational advantages.
10. The fitment of TCAS/TCAD to exploit higher traffic density.
11. Address areas of multiple competing programs to find a solution. I believe the community we are trying to help should not be a commercial battlefield at their expense.
12. Create an agreed HEMS "gold standard", published and in turn advertised by programs. Ie you could be a 5 star operation if you tick all the agreed boxes such as multicrewed, IFR capable, SPIFR autopilot equipped, NVG, TCAS, EGPWS/IR, regular CRM, etc, etc.
13. The removal of different regs standards for different "mother" organisations i.e. public use aircraft have to abide by HEMS regulations if doing HEMS regardless of who owns the aircraft. This includes abolishing different standards for SAR and for return legs in terms of weather and minima. SAR and HEMS should operate to the same standards.
14. The establishment of a risk management system that does not involve the ability to fudge the numbers in order to launch.

Make it a five to ten year project to more slowly absorb costs and operational changes, and away you go!

Yes: some programs will have to merge or be extinguished. You get that.
Discuss.
More beer waiter!

[topendtorque]

HelmetFire,
yes, your post is stimulating.

Can I go slightly outside the square and refer to burocratic ( I hate that word) procedure.

Pretty much all departments of all jurisdictions (weeds, law, capital works, even aviation) work on a very simple principle.

1) Employ sharp people to come up with good ideas.
2) Invite them to put out to public debate those ideas.
3) Formulate a STRATEGIC plan to deal with the pertinent issues.(lay on the delightful luncheon process during that process)
4) Devise a serious implentation plan to teach every m****** f****** just how they are gunna do things right.


DRUM ROLLl

5) it's now time to call another election and do the same thing again.

What you need to do is fast track to step five. The U.S.A. is not yet in step one mode.

cheers tet

[WhirlwindIII]

tet

Very well said, indeed! Couldn't agree more.

WIII

[TheVelvetGlove]

My God- are there really pilots out there in the world flying HEMS at night without an instrument rating? Where?

[Gomer Pylot]

There may be a few in the US, because it isn't a regulatory requirement. Most operators won't hire a pilot without an instrument rating, though. Public use (police, etc) operations aren't regulated by the FAA at all, and some of them may be using pilots without an instrument rating.

Many of the models used in HEMS in the US aren't capable of having two crewmembers up front. There is just no second front seat, and no room for one. That's where the patient's feet are. That requirement is a non-starter here. The government can't realistically require that. As good an idea as it might be, it's out of the question. Remember, there is a different philosophy here than in much of the rest of the world. For much of the world, anything not specifically permitted is forbidden. Here, anything not specifically prohibited is permitted. That philosophy is not subject to change, it's built into the Constitution and the entire culture. Capitalism is also enshrined in the culture, and overrides almost everything else. Putting companies out of business is considered socialism or worse, and it won't happen. It's a fact of life, and we have to live with it, regardless of the opinion of the rest of the world.

[Shawn Coyle]

The HEMS operation I flew with had an IFR approved helicopter, but we were not considered an IFR operation, so we legally couldn't file or fly IFR. Would have made my life easier on at least one occasion in my short EMS career. Would also have made it a lot safer.
All for want of some paperwork that management wouldn't go with.

[helmet fire]

Hi Gomer,
Your points are valid and you can see them contributing to the culture that currently pervades US HEMS. When you say that "anything not specifically prohibited is permitted" is the crux. The list I put up did not exclude taking regulatory steps that would prohibit non-compliance, but that regulatory requirement should only be initiated when there is a demonstrable safety case to support it. in other words, change the system to mitigate the risk.

This DOES happen in the USA. 1 in 80,000 of Americans will be killed on the road as a pedestrian this year - almost all of them will be "jaywalking". That is why some places have a "jaywalking" regulation. It is not unconstitutional, against the core values of the USA, nor changing or challenging a culture - it is to reduce risk to the general population. The same can be said for the introduction of seat belt rules, helmets on motorbikes and riding around in the back of utes ("trucks" as you might call them).

There is an identified risk in HEMS, even where that risk is perceptually increased beyond the facts due to media and emotional reactions to lost loved ones. Mitigating that risk is not a business restriction if it can be based on a safety case, such as the two crew in the front. Aircraft not capable of such SHOULD be phased out over the next 10 years, and if the business case (ie benefits) are not large enough for the extra cost, then I would suggest the risk V benefits of the existing model is not supportable.

I suggest that the US Medical fraternity is looking for ways to restrict or stop HEMS (yes, there are gathering loud calls for the cessation of night HEMS and the severe restriction of day HEMS). Lets identify the risks ourselves, produce mitigators and then institute them before we find regulatory knee jerks that do kill the business.

[alouette3]

Saving the Air Medical Industry

The article above has been written by a well known critic of the US HEMS operations. Quite a few interesting points. However, if everything the author suggests is implemented----it will kill the US HEMS industry.
Moreover, folks in Europe must understand the size of this country. There are people living in rural America with access to an understaffed clinic that need helicopters. Even if it is for a "simple" heart attack. A lot of rural ambulance services are staffed by volunteers who have very basic skills and may not be able to baby sit a patient for a three hour drive to a metro hospital.All this has to be taken into consideration. Deregulation is almost killing the airline industry here but it has had great benefits too. So, IMHO,the answer (as always) lies somewhere in between rampant capitalism with deregulation and total govt. subsidized over regulated socialism.
If we want twin engine,two pilot fully IFR capable helicopters to fly only by day or do only IFR approaches to hospitals , then let us call it quits and have only FW operations instead of helicopters for EMS.They can fly patients from airport to airport,IFR only, two pilots all the time and ambulance crews from hospitals or scenes can bus them to and from the local airport.Problem solved.
I am curious how our friends in OZ run the Flying Doctor Service?.Any Aussies here who might like to weigh in ,especially with respect to rural Australia also (or maybe --only?) known as the Outback?
Alt3.
P.S. Disclaimer: None of the above should be construed as me being supportive of the status quo.Our safety record here is dismal and a great deal needs to be done but let us also not go overboard and acknowledge the cultural, geographic ,economic and ,yes , political, differences between the US and the rest of the world.

[Gomer Pylot]

I agree that something different is needed, but I'm not certain exactly what. Alouette3 makes some good points. Many of the hospitals in small towns in rural America have very little capability. They can take care of sprains, small cuts, colds, and other minor ailments, but they're over their heads with heart attacks, strokes, fractures, and lots of other injuries. Ambulance services can't afford to be out of service for many hours driving patients to trauma centers, because often there is only one ambulance, staffed by volunteer crews. There are a few ground ambulance transport services, but not nearly enough, and time can make a huge difference to a stroke or cardiac patient. Even if they're kept alive on the ambulance, the chances of a full recovery diminish steadily as the time to a stroke or cardiac center increases. Often there is no airport available within a reasonable distance, at least one capable of taking the most often used FW EMS aircraft, especially one with IFR approaches. Prohibiting night HEMS will mean that many, many patients will die or never fully recover. We need to balance taking care of patients with safety, and where to come down on that fence is a philosophical question. Here, the philosophy has been to take care of the thousands, and the relatively few accidents are worth the risk. Requiring large helicopters with two pilots and full IFR capability, which can't be used 95% of the time, will mean that most rural areas will be without service, and that covers most of the continent. I understand that other countries have a different philosophy, and that's their business. The current US situation isn't ideal, but it's what we have, and changing it will be a major undertaking. It's not just a matter of the FAA making regulation changes overnight. Under current US law, that isn't possible. It requires notices of proposed rule making, taking comments from the public (including companies impacted) and then implementing the rules over time. I don't see emergency regulations being enacted.

The only way I can imagine providing large helicopters to the entire country is for the federal government to pay for them. The right would immediately cry "Socialism!" and oppose it. It might happen, and I for one would welcome it, but it would be a nasty fight. Capitalism certainly won't provide it. I'm pessimistic about this, but far more optimistic this week than last week.

[victor papa]

I am not in Aus, but fully agree with you Alo. I have posted before our requirement which is 6000ft, 30 degr(in summer more likely 35-38 inland) and 2.5 hrs fuel carrying plt and 2 med crew and tgis with a full ALS system fitted to the aircraft. We are again now in the twin vs single argument and 2 pilot vs 1 due to lack of capability to carry 2 pilots and IFR capability. We do not operate at night at the moment and if required would go with NVG which we have no regs for yet. Our IFR rated airports for a helicopter is about 4 hours apart at best so true IFR unless we operate a 225 with ferry tanks is a myth. Our hospitals in the major cities are like the airports 4 hours of heli flying apart. In between are intermediate facilities who can if you are lucky stabilise you until you can get to a primary facility were you can survive within the heli's range until the transfer. We got the EC130 to work beautifully capable of carrying 2 pilots and the stretcher and have the legs for the long flights. On the twin side we have to look at the 145 and/or 135 which are maintenance friendly(which are extremely important if you are not allowed to be offline for more than 24hrs in succession without replacing the aircraft) but will have to be nursed 10 times more than the 130 at the alt and temps as well as requiring a total different amount of training and skill due to complexity vs the 350B3 and the 130. On the otherside we have the 109 which with it's fuel burn we will have to put fuel out just about every hour to be safe and not as maintenance friendly but do have the power but will still have to be nursed from 34 degrees with the added complexity factors as stated. In a country with high poverty, fuel drums are not necessarily where you left them! Our average guys are 5ft8 weighing 95 to 110kg if they are in good shape. Patients go easily to 135kgs at 6ft4 or something ridiculous.

IFR and twin engines to me are not necessarily the answer and neither are enforcing 2 pilot ops(different operation). Remember in something like the B4 IMHO the visibilty is probably better from the rearseats than most other helo's sitting in the front at a nose up attitude in the hover. I do believe in a good, reliable, stable platform with added EGPWS, TCAD, radio alt(not preset at 150ft) properly integrated into the intercom and always have a power margin(nothing beats the simplicity of the FLI in a B3/B4) for the unexpected downdraught/wind change/etc.

[David Earley]

Helmet Fire's contribution is well presented as usual. At the recent ISAS conference in Adelaide (Australia) a speaker summarised the distinctives of about 5 US EMS operations he had visited on a "study tour" recently. On the summary of one, appeared the motto
"WE NEVER SAY NO".
That kind of sentiment/motto would be rightly howled down in any safety minded environment . It sums up a culture/attitude of management that seems to be a product of the competitive nature of much of the US health system. Simplistic perhaps, but until there is a fundamental change in that attitude, I can't see Points 1,2,3,5,7,11,13 and 14 of Helmet Fire's recommendations being possible.
It is unrealistic to expect the needed change in that attitude leading to changed behaviour without it being initiated arbitrarily by the regulator. I cannot see industry operators doing it unilaterally unless they are backed by a management structure that can and will support them through a long winter of being uncompetitive with those around them.

[helmet fire]

Agree David.
The points I listed were actually a compilation of ideas across many of the threads at Prune coupled with some of the results of our study tour. I had started another thread with them intending them to apply to HEMS generally, not US HEMS in particular, but in error has left "US" in the title and Senior Pilot moved my post into this thread. My fault entirely, but I am afraid that these ideas will only be discussed by those interested in US HEMS.
I believe that having the discussion about HEMS from an international perspective would allow US operators to see what ideas are going on outside the US, not get threatened by external opinion.

Alo3 points to exactly my concern about the sort of momentum that is gaining credibility within the US, and until the HEMS industry can change either reality of risk or at the very least the perception of that risk, then we are not going to combat that momentum.

I am in Aus. I have been flying EMS for the past 12 years and much of it to remote small town rural communities without adequate medical facilities. Legs of 2 hours each way are not uncommon in our model. We fly twin engine IFR machines and the model works - so I am not convinced the same model is unsupportable in the US, however, there are fundamental differences in the financing structure of our model which make comparisons difficult and unreliable. This is brought out by David's post.

The intent of my post was not to compare Aus V US or Euro V US or anyone V anyone. It was to stimulate discussion about what measures any HEMS program might take. Never the less, I will answer some of the concerns raised: IFR, imposition of regulation, and 2 pilots.

IFR: the fact that there is limited current infrastructure available to US HEMS in terms of where you need it and when, was faced here in Oz. We went out and created a network of IFR infrastructure that still has a long way to go. We have established IFR approaches to hospitals (and therefore fuel) where weather or operational reasons required. Indeed, I now operate at Westmead Hospital in Sydney with a company that developed the first non-airfield, helicopter specific GPS approach, certified in 1997/8. See my earlier point 7 & 8 which were created entirely in response to the concerns you raise about the lack of current infrastructure.

Imposing Regulation: David and Gomer are absolutely right. None of these issues are insurmountable, but you are both right: overcoming them is unlikely. This is true across countries, and the US is not really a special case here - look at the evolution of NVG regulation across countries, the USA got going some 15 years ago, and some countries still don't have permission.
There are probably many ways to overcome this limitation, but the first of which is to create an industry standard. Given the gathering intervention by the medical world onto our industry, perhaps the way forward is to create a standard and present it to the medical world. The long dark winter that David refers to may be a lot shorter if the medical world drive requirements to conform with the industry published standards. This form of economic incentive is far more effective than regulation.
An example is in Australia. For the last 20 years we were stuck in the old argument that poor rural communities could not afford flash aircraft and equipment and that their only hope of life was a Longranger battling fearsome conditions to help them. Two NVFR crashes in QLD changed that paradigm. The standard imposed BY THE MEDICAL SIDE is now twin engine and IFR capable. Not imposed by the regulator, nor the industry. That meant that operators either operated (and charged for) twin engine IFR or they were out of a service! We can exploit that power by establishing standards for the medical side to grasp, adopt and then require. I don't see any other way to convince the regulators or our bean counters en masse.
See point 12 for this appearing in the list.

Two Pilots: I think we need to realise the effect of the EASA regulation: it does not have to be two pilots. Read point 4. The typical Euro crew was only three persons, the same as many of the organisations in the US saying two pilots are unsupportable. The three crew are: pilot, HEMS Crewmember, and Doctor. The HEMS crewmember is a paramedic with pilot theory passes, specific front seat training in VFR, IFR, NVG. Not necessarily flying as well. The point is that there are two aviators in the front. I know that there will be negative argument about what happens when the patient is on board, but it works very successfully in many parts of Europe. Can we learn from them?

Lastly, the implementation timeline of 10 years or so is the sort of long term thinking we need to apply. Both David and Gomer illuminate timeline issues, but perhaps the goals should be set with these firmly in mind: maybe 20 years. In those terms, some of the list points suddenly become a more realistic proposition.

[Gomer Pylot]

Helmet fire, I agree with your desires, and I hope something like that comes to pass here. But it will take a major change in philosophy. Hospitals have little to do with it, because the major operators are standalone commercial operations, not run by nor even affiliated with hospitals. Certainly there are hospital-run operations, but they're increasingly in the minority. The federal government will have to get into the action and provide funding if more capable aircraft are going to be mandated. I'm hopeful that with the new administration the new Congress will enact universal health care, and with it the possibility of federal funding for HEMS operations. Only the federal government has the capability of funding new helicopters continent-wide. It need not be direct funding, just mandating larger helicopters and paying enough for patient flights will do the job. I'm far from certain that we will go that far down the road to gasp, Socialism, though.

[helmet fire]

Agree Gomer,
The accident rate in the US has a surprising ripple effect through HEMS world wide, particularly amongst the general public, and even more specifically amongst the medical fraternity. I understand the prevalence of commercial operations, but I am putting across the idea that their customer - the medical professionals that get on board the helicopters - are the ones that will impact: not the federal government, and not us as a group of peers. We are too busy competing!
That is the experience in one of the states of Australia - Queensland: the paramedic union drove the up spec to twin engine IFR. The industry are still arguing that the job can be done in a Longranger and the regulators are not even seeing a risk. Such experiences are what has prompted me to suggest to you guys an avenue for influencing equipment and spec levels that does not rely on the federal government regulations, nor competitive pressures to keep it cheap. You should be concerned in the States with the momentum from that very same customer to stymie the use of HEMS. Get in first and suggest the standards to them: better to give them risk mitigation strategies like IFR, Twins, etc, etc than the current risk mitigation they are considering (stop night HEMS, restrict day HEMS).
Food for your thought.

PS: thanks Senior Pilot for the restoration

[alouette3]

Helmet Fire:
Good points. I think you make a very valid point about momentum. When somebody makes a suggestion about how to 'fix' US HEMS and has a 'Dr.' before his name, trust me, he has more credibility than Average Joe The Pilot.
My only concern is (and I believe it is echoed, to an extent,by Gomer) is that we do not end up losing the only benefit the helicopter offers over a Fixed Wing by adding all kinds of equipment and restrictions.As Gomer said earlier, it is not the best system here in the US but it is what we have got and has worked well for a long time. We definitely need to tweak it and improve safety with the assistance of training and technology. But if we mandate all the stuff that Bryan Bledsoe advocates we will end up killing HEMS, as we know it, in the US.
As to comparisons I don't believe you were making any.But there are plenty of folks out there, right here in the US, who do. They talk about how the Brits do it and how the Austrians don't fly EMS by night etc. etc.Comparisons fall apart very quickly when you compare the political and geographical differences between Europe and the US.The only countries that compare favorably in terms of size are Australia and Canada. It would be worthwhile starting comparisons there.
Gomer,
Even if socialized medicine does make it to the US in the near future I believe HEMS subsidies will be at the bottom of the priority list. As an example, we only have to look at Medicaid reimbursements to see that as true. So I would'nt hold my breath.
Final thoughts (and I know I am going to take heat for this) while even one accident is one too many and 2008 has been horrible,one must also objectively compare number of helicopters/hours flown/successful flights vs. accidents before we condemn the US HEMS ops. We do have cultural baggage and we must do better. But 750 helicopters complete millions of flight hours and thousands of patient transfers every year successfully. I think that is awesome.How can we improve without going overboard is the dilema.I don't think any one agency, person or operator has all the answers.
Alt3.

[Gomer Pylot]

Alt3, I'm not holding my breath either. What I really think will happen is little if anything. I agree that the accident rate isn't as bad as people assume, given the number of helicopters flying EMS in total. The largest companies have ~100 each, and there are literally dozens of smaller companies with a few each, some private operations, some operating for hospitals, a few like Maryland done with public use aircraft. The rate needs to go down, but I don't have any answers. The spate of recent crashes has a plethora of causes, and I see no common denominator. Every so often defecation occurs, no matter what is done to prevent it.

[tecpilot]

helmet fire, i don't know which european HEMS you have seen, but what is Europe? Did you mean JAA land?

1. "Institute a night lower safe altitude even when VFR. Make it 1000 ft for VFR" - JAA lowered the allowed weather at night for VFR - HEMS from 1500ft to 1200ft, on route shorttimed 1000ft, visibility 3000m - not good
2. There are many HEMS bases without IR pilots (in Germany and Switzerland at least 60%) and sometimes without IFR helicopters in Europe - not good. No sweat, JAA don't want it.
3. There are also single pilot VFR night HEMS flights (also without AP!). The HCM is in the back assisting the MD. JAA have not specified up to today the place of the HCM on a front (copilot) seat. He have "to assist the pilot", what ever that means. - not good
4. There are no HCM "with pilot theory passes", no existing JAA rules about the special and determined HCM training. Mostly they get 20-40h theory and 10 supervision missions (different between the operators) including refueling, pushing a helicopter into hangar, sweeping it and other simple stuff. Especially they will never have IFR theory or NVG hours. - not good
5. Therefore at night the HCM is only a cheap place holder. Pilots are too expensive - not good
6. "The point is that there are two aviators in the front." You are joking?
7. Also Europe has seen devastating VFR night HEMS accidents. Why not so much as in US? I bet, it's only a question of the numbers of flights and some other small points. Only statistics! As example, in the more than 80 million inhabitants Germany you will find only round about 10-12 night HEMS bases. They do not fly really much at night and mostly short hops 50-150km. Jobhopping is not so common in Europe than is the US. Therefore the most pilots in the business in Europe have very much experience in their small mission areas (diameter 100-200km at night), in their helicoptertypes and in their local weather situation. Much alternate landing sites also around! Good ATC and full radar coverage additionally!


I'm not sure if the european system is really better than the american.

And just one last point, in all the last german HEMS VFR night accidents were involved only IR pilots and IFR ships. There are no night accidents with VFR pilots and simple ships. Why? Simple, the IR pilots in trust in their clocks and APs went straight ahead in CFIT, the VFR pilots turned back or canceled the flight before take off after weather check because they fear the clouds

[Devil 49]

7 people killed in a day mid-air crash, in, or very near an airport traffic area;
3 crew die in what appears to have been a structural failure, also in day light- these are very unusual occurrences. They're no less of concern because of their exceptional nature.
Next, 4 fatalities colliding with a tower that, from what I hear, was a known en route hazard. To me, also unusual- except that most wire strikes occur with known obstacles.

Then, Texas/ PHI, Wisconsin/ Air Methods, and the Maryland State Police accidents- 11 lives lost. These fit the stereotype EMS night and weather crashes, except that I think we're missing the forest for the trees in our analysis. These aren't as easily classified as 'night VFR into IMC':
The PHI pilot was an IFR captain in the Gulf for years. He never struck me as a 'cowboy' and his professional skills should have been adequate to the task;
MSP's Trooper 2 seemed to be doing the right things when the flight came to grief;
I know very little about the Wisconsin crash, except that it was an Air Methods EC 135. That airframe is often employed in my company as SPIFR platforms. I don't know if it was an IFR program.
So- Night and day; single and twin; VMC and IMC; VFR and IFR platforms; the one thing missing is two pilot crews. I think it's reasonable that the common element is the human factor. That's the issue that needs to be addressed.

Pretending that EMS is just an on-demand charter is short-sighted. In EMS we have an aviation decision to make, but a responsibility to the patient that over rides all when evaluating a flight- you have to know with reasonable certainty that at the very least, you will get the patient the receiving facility without undue hazard- or you're not doing the job hired for, period. The most conservative response is the best choice for all. When I have doubts, I have no doubts, and no option but to decline.
I shouldn't need a risk assessment matrix or operational control center to know that the proposed flight is not certain- the facts speak for themselves. Muddling the decision allows more flights and more revenue, but dilutes responsibility. EMS is not combat, there are options besides accepting dispatch or proceeding into unfavorable circumstances. Risking 4 to possibly help 1 is very bad math. There's no such thing as “taking a look” or “giving it a shot”, those are excuses for poor decision making.

We in US EMS do the hardest part of our job when we're at our worst, a sweeping generalization- most programs swap mid-hitch, day to night duty, with a 24 hour break between day and night shifts. Circadian rhythm, sleep patterns and rest, all are supposedly covered by the umbrella regulatory requirement for “10 hours of uninterrupted rest”.
Pilots are not blameless in this, I've heard professional pilots say bald-faced that they had plans for the day between two night hitches that meant they wouldn't be sleeping. I've heard of relief pilots reporting for night duty with the plan to sleep because they hadn't done so that day.

NVGs are slowly coming to the fleet. With aided vision, a pilot can see and avoid, almost as well as on a day flight. Right now, at typical unaided night visual acuity ranging from 20/200 to 20/400, we see by using counter-intuitive techniques and crappy lighting. Often, we don't see issues at all until we're in the cloud, hit the hill or the tower. Most pilots I know don't cruise that low at night. I wonder if the CFIT incidents aren't descents to regain contact, a very bad choice.

I'm not an equipment guy, this is all about decisions, how and why they were made, and the planning that results in the flight completed. Throw equipment, procedures and regulations at the problem and it'll have some impact- reducing flights, but not accident rates. More complications means more opportunity for mistakes as the root cause isn't addressed- the human factor.
I'm especially not a fan of IFR as a safety solution. Yes, I've been IIMC, but never had to continue IMC- a return to better weather or a precautionary landing works. Besides, the weather's VFR or better 95% of the time. Do I wish for full IFR capability? Sure. I also wish Carmen Electra would drop by, but I'm not building a business plan around that possibility.
Add that in our area, the average leg length is twenty-two minutes. By the time I check, plan, and fly, the patient could be transported by ground. Which is the case now, because I don't go.

[JimL]

tecpilot,

It may be that you are describing a past issue of JAR-OPS. The latest copy has (and has had for a number of years) Subpart O dedicated to the Crew Member other than Flight Crew.

The requirement for specific HEMS training and checking is contained in Appendix 1 to JAR-OPS 3.005(d) paragraph (e)(2) - you might look at it again because it is quite comprehensive.

Because there may be circumstances where the HEMS crew member may be required down the back, there cannot be an absolute requirement for him/her to be seated in the co-pilots seat; however, it is specified in ACJ to Appendix 1 to JAR-OPS 3.005(d) sub-paragraph (c)(3)(iv), as are the specific duties.

The requirement for two pilots at night is contained in the HEMS appendix - which contains a derogation for a pilot and a HCR under specific circumstances and for which Approval from the operational authority is required (similar to the type of conditions contained in the OpsSpec mentioned below - i.e. for local operations).

No, it is not perfect but does provide a skeleton on which a good HEMS operation can be hung.

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.

What hasn't been established yet is the actual accident rate (only the headline figures); it is also clear that there are few recognisable patterns in the accidents; even the human factors issues are complex. It will take a great deal of analysis before any specific measures can be decided. What does appear to be evident (from the reports as well as from commentaries in this and other threads) is that there needs to be a culture change.

Jim

[Shawn Coyle]

For nearly all HEMS operations, two of the three legs flown do not have a patient in the back. The outbound leg to the scene is the one with the most unknowns (if going to a scene).
It makes sense to train the med person who might be sitting in the left seat to know what's going on. Even if they're sitting in the back, they should be able to be of assistance.