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Helicopter EMS Issues in the USA

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Old 1st Sep 2009, 00:38
  #21 (permalink)  
JHR
 
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JHR

SASLESS

The legal interpertation from the Fed's.

They think 135.207 does not limit a helicopter from flying over the top with out surface reference. Day or night they don't care. It's my opinion that the US FAR's only define IFR as operating with less than the required basic cloud clearance. Dark night, no horizon is still VFR. We as pilots are supposed to not get into flight conditions we can not deal with.

I certanly do agree to many people are losing thier lives with the operating rules that are in place today. I also wonder how many operators either EMS or utility actualy train or give check rides at night.

The company I work for has OPS's spec's for day and night VFR and IFR operations, the ops's spec's just authorize the operations, they don't tell us the conditions that have to be met to make the flight.

JHR


March 3, 1992
William K. Comee

Dear Mr. Comee:

This is in response to your letter dated September 13, 1991, withdrawing your request for exemption. In your withdrawal request you asked for a confirmation in writing that the Federal Aviation Regulations (FAR) permit a properly equipped multiengined helicopter with an appropriately rated crew to fly VFR over-the-top.

Your request apparently was initiated because of some confusion over FAR Sec. 135.207. That section states:

No person may operate a helicopter under VFR unless that person has visual surface reference or, at night, visual surface light reference, sufficient to safely control the helicopter.

You correctly cite FARs Sec. 135.211, 135.181, 135.161 and 135.243 that allow for aircraft to fly VFR over-the-top. The term "aircraft" as used within the FARs includes helicopters. "VFR over-the-top" with respect to the operation of aircraft, means the operation of an aircraft over-the-top under VFR when it is not being operated on an IFR flight plan. (14 CFR 1.1) "VFR" means visual flight rules. (14 CFR 1.2)

If the agency's intent was to preclude VFR over-the-top operations in FAR Sec. 135.207 it would have stated so. It must be presumed that the drafters of the regulation were aware of the different terms as evidenced by their use in other FARs that pertain to VFR over-the-top operations. Section 135.207 does not mention VFR over-the-top operations. We therefore conclude that FAR Sec. 135.207 does not preclude properly equipped helicopters and instrument rated aircrew from flying VFR over-the-top.

We trust this satisfactorily responds to your request.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division
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Old 1st Sep 2009, 12:11
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You are absolutely correct when you note VFR/IFR is based purely upon weather conditions alone. The visibility minimum only applies to the distance one can see "If" there was something to see.....such as lights. horizon, terrain. Anyone that has flown offshore at night knows what the difference is.

I have always maintained that in reality, if one must rely solely upon the instruments to control the aircraft you are no longer "VFR" despite the regulation saying you are.

The issue in my view is the regulation does not adequately meet the Kool-Aid Acid test of reality....and thus sets up a very dangerous situation where un-qualified, non-capable ( I hate to use the word "incompetent"...) pilots can suddenly find themselves in grave trouble.
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Old 1st Sep 2009, 12:42
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Just to muddy the waters some further, realizing of course that these regulations do not apply to civil operations.
I believe, SASless, but do not know, that the intent of the definitions below is in keeping with what your opinion is.

OPNAVINST 3710.7 (series), NATOPS GENERAL FLIGHT AND OPERATING INSTRUCTIONS, which is the governing publication for all U.S. Navy and Marine Corps flight operations defines some terms a bit differently than the FARs and other civil regulations with which I am familiar.
While there is a provision for VFR-on-top or over the top or whatever you want to call it, in practice it is almost never used because it's rare to be on top and have a horizon.
The obvious question might be... "If you have visibility but no horizon, what do you put in your logbook?" The answer is... "Actual Instrument Flight"

Actual Instrument Conditions. Conditions external to the aircraft in flight that do not permit visual reference to the horizon.
Instrument Meteorological Conditions.
Meteorological conditions expressed in terms of visibility, distance from clouds, and ceiling less than the minimums specified for visual meteorological conditions. IMC conditions exist anytime a visible horizon is not distinguishable.
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Old 3rd Sep 2009, 02:03
  #24 (permalink)  
 
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NTSB issues safety recommendations for Medical Helicopters

NTSB issues safety recommendations for Medical Helicopters | Pilotbug

The NTSB has issued 15 safety recommendations to various government regulators and helicopter emergency medical services (HEMS) operators following a dramatic increase in accidents. Among them are the creation of scenario-based pilot training curriculum, installation of flight data recorders for aircraft, the use of an autopilot in single-pilot operations and use of night-vision equipment for pilots.
According to the NTSB, of the 55 mediflight accidents which occurred in the last 3 years, of which 41 were helicopters, 29 could have been prevented with the adoption of these recommendations and the others contained in the press release.
As a result of the increase in accidents, a 4-day hearing was conducted in February by the NTSB with testimony from the FAA, the Helicopter Association International (HAI), the Association of Air Medical Services, the Professional Helicopter Pilots Association, the National EMS Pilots Association, Air Methods, and CareFlite. The following was determined to be the focus of the hearings:
  • Pilot Training
  • Collection of Flight Operations Data
  • Use of Flight Recording Devices and Data
  • Safety Management Systems
  • Weather Information
  • Use of Autopilots or Dual Pilots
  • Night Vision Imaging Systems
  • Reimbursement Rate Structures
  • Federal Policy and Guidelines
The full press release can be seen here
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Old 1st Aug 2010, 11:37
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Ems & Sar Crashes

Wassup with the glut of EMS and SAR crashes going on in 2010?

It sucks!
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Old 2nd Sep 2010, 10:14
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Thumbs down single eng single pilot at night!

Why are there still some countries (the USA) still using single engine & single pilot at night for EMS in all kinds of weather.
I would also rather continue with a ground ambulance dispite the longer transport time.
How many accidents and how many must die until they change their attitude about this?
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Old 2nd Sep 2010, 10:29
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Good vibs,

Standby for the 'defenders of single-engine ops' who fail to see that it is not the number of engines but the fact that singles are invariably VFR. That means that they will be scrabbling around under the cloud at night and crash into hills or wires, or get disoriented.

EMS is a job for twin/IFR machines but it just doesn't seem to be catching on in the US where these accidents will continue to happen.
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Old 2nd Sep 2010, 19:15
  #28 (permalink)  
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I am beginning to wonder what is going on in tbe US Helicopter industry of late.

Was it Phoenix where the A-Star EMS aircraft crashed in clear skies and during cruise....followed by the Kaman KMax logging crash....then the Hiller in Idaho...and now this JetRanger.

Are we past Pilot induced crashes and now seeing mechanical failures or engineering failures as being the cause of fatal crashes?
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Old 2nd Sep 2010, 20:56
  #29 (permalink)  
 
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21 lives this year

Spike in medical helicopter crashes elevates safety concerns

by Samantha Ptashkin

Fox 11

Posted on September 2, 2010 at 11:58 AM

TUCSON, Ariz.-- One medical helicopter down, three crew members dead. It's a horrific scene many people witnessed in Tucson in July and now a recent crash in Arkansas has elevated the concern for helicopter safety.

Tucson Medical Center flight nurse Suzanne Knepper heads up in a helicopter two to three times a week to help pre-mature babies get the medical attention they need. "When infants are in distress, it's usually a very acute thing," Knepper said. "We have to get there right away and the time in travel in southern Arizona is quite long."

Knepper says the medical chopper is vital in saving lives, but so far this year, helicopter crashes have also taken the lives of 21 people nation-wide. It's a sharp spike from last year.

The latest crash happened in central Arkansas Tuesday morning. Three crew members died. That crash marks the fourth fatal accident this summer, among those, the LifeNet chopper which crashed down in midtown Tucson, also killing three crew members. "Any death is very significant and obviously a tremendous loss and we're very concerned as an industry as a whole about the number of accidents that result in fatalities," said Craig Yale, a spokesperson for Air Methods.

Yale says the industry has taken more precautions over the past year, including the use of night vision goggles for crew members and warning systems which alert pilots of any obstructions. "We go through safety checks with our own equipment and then when we get up on the helicopter we make rounds with pilot and we all agree that what we've seen so far is safe and that we're all ready to fly," Knepper said.

Despite all the safety checks, Knepper and her team know something can always go wrong. "Accidents happen in a helicopter, in an ambulance," said Flight Nurse Pat Brown.

But they say they can't live in fear of losing their own lives. The minute they board, their focus is on saving the lives of others.
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Old 2nd Sep 2010, 21:59
  #30 (permalink)  
 
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Single or Twin

I have less than 100 hrs as co-pilot in HEMS H24 / SAR operations in Italy and so far, what I more like about the captains I fly with (former mil and civi), is their attitude in sticking to the rules, saying "No" when ops manual meteo minima are "no go".
So much noise about twin or single in so many threads. All of us (in this forum) know about differences of single and twin equipments and of course the flight crew experience, ratings and training, therefore their different capabilities.
What is missing there is discipline and information.
Set a correct "No go" minima for single engined machines and stick to it.
Somebody will reply that even with twins there will always be the one who overevaluate the capabilities of his machine.
VFR pilots also and not only IRated ones should be more informed about all dangers of IMC and night operations and try at least one time, not for training, only for demonstration, an unexpected IMC, disorientation etc. etc. and undestand that as SASless says, fog kills (and not only fog).
Correct estimation of the risk (I'm sure nobody wants to die) would keep more pilots VFR/SE and IFR/ME far from all these dangerous situations.
Moreover, when I read in the NTSB reports, I'm surprised about the numbers of accidents caused by lack of recurrent training or experience for night and/or IFR operations.
This makes me think that CFITs happens for the same reason.
Write the rules and stick to it.

Last edited by vaibronco; 2nd Sep 2010 at 22:00. Reason: english grammar
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Old 2nd Sep 2010, 22:31
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The single vs. twin argument should take a back seat to auto-pilot vs. no auto-pilot. The FAA took the low road when arguing for NVGs. Most US EMS machines are at best, marginally capable of flight in IMC. Having flown the full gambit of machines from VFR the B-206L and VFR AS 350B-2/3 to full single pilot IFR (SPIFR) B-230, A-109E and EC-135 it is my opinion that an auto-pilot does more for reducing pilot workload and enhancing safety than either 2 engines or NVGs. An autopilot takes the pilot out of the flight control loop and allows for the safe management of the machine while control is maintained. As stated in the OpsSpecs “ auto-pilot in lieu of a copilot for IFR flight”. A pilot in Inadvertent Instrument Meteorological Conditions (IIMC) has neither a co-pilot nor an auto-pilot. The outcome rest purely in the pilot’s ability to maintain control of the machine, while attempting to navigate and communicate.

Single engine vs. multi-engine could be argued for the Tucson mishap where a for a low altitude (<500 AGL) engine failure over an urban environment resulted in disastrous results.
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Old 2nd Sep 2010, 23:04
  #32 (permalink)  
 
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As long as ANY so called "Aeromedical Provider" is allowed to dictate rules to the FAA we shall continue to see an uncontrollable amount of crashes and accidents.
The FAA allowed HEMS operators to go the way of the cheapest possible expedient to make the public at large believe safety is being considered primary: NVGs.
The US HEMS industry is again being allowed to regulate itself and we know that when profits are at stake self governing is tantamount to anarchy.
Considering how long this crisis has been dragging itself, the FAA is just as culpable as those operators that crash on a regular basis.

The causes are always the same.

My prayers go the the surviving family members who in lack of a valid lawsuit shall only be left with the "usual" one year of pay to remember their dear folks.

Last edited by tottigol; 2nd Sep 2010 at 23:14. Reason: Cursed grammar
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Old 2nd Sep 2010, 23:04
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I'm somewhat bemused by the issue of single vs twin here. When was the last time an aircraft was lost due to an engine failure? Compare that to the number lost due to pilot error, weather, wires, and failure of items other than engine such as rotor blades, gear boxes and tail booms?

Is 'single' being confused with 'not IFR' here?
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Old 2nd Sep 2010, 23:48
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Is 'single' being confused with 'not IFR' here?
In UK the rules no longer allow single engined helicopters to fly under IFR so the terms are effectively the same thing.
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Old 3rd Sep 2010, 00:07
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Yeah - and it's the same all over JAR land I guess?

But it is not the case under the FAA or the ROW is it?

Whether a heavy AS355F1 is safer than an AS350, A119 or B407 is another question altogether!
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Old 3rd Sep 2010, 00:15
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Vaibronco,
Your post seems to imply that all the wise things you suggest do not happen here.Setting minima,understanding and teaching pilots the dangers of IIMC,recurrent training. All EMS companies that are worth their salt do all of the above and sometimes more.So to suggest otherwise is offensive to some of us.Fact remains, that for every one (and that is one too many,admittedly) that makes the news, there are thousands of HEMS flights that operate routinely and safely on a single day. In fact ,I would wager, my company flies more every year than all the outfits in the the continent of Europe,put together.Besides, have you looked at a map recently and seen the size of this country? I can tell you, my friend, mine is definitely bigger than yours. So the attitude of your captains whom you so admire are not only restricted to your side of the pond.
To the rest, the last three crashes (Oklahoma, Arizona and now Arkansas),seem to be aircraft related as opposed to pilot issues. So notwithstanding the "witnesses" who saw the aircraft "fly through a fog"--I shall reserve judgement.After all, 500+ "witnesses" "saw" the missile that brought down TWA 800.
And, I have said this before, as long as Europe and Canada and Oz have government funded HEMS outfits, comparing that to the ones in the US is futile.
Alt3.
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Old 3rd Sep 2010, 00:27
  #37 (permalink)  

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But it's not a performance issue, it's more to do with system duplication/redundancy and the sophistication of the stabilisation/autopilot.

I have flown single engined floppy stick helicopters i.e. no stick trim, let alone an autopilot, in IMC, quite legally, under military rules. I also used to fly a public transport AS355N (twin) with a "floppy stick", at night (normally in UK, by definition, under IFR as there is no VFR at night here).

There was a likelihood that sometimes we might go inadvertently IMC at night due to the nature of the job, and we were required to train for that eventuality. However, it's all been outlawed now after some high profile accidents at night.

Not before time. The FAA seem to be lagging behind, now to an alarming degree, it seems.
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Old 3rd Sep 2010, 10:50
  #38 (permalink)  
 
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I am sure I am not alone in this frustrating scenario.

More unnecessary deaths for what?

Absolutely for what???

Can someone please confirm that: “night-vision gear” actually means “Night Vision Goggles” (NVG's) flown in Night Visual Conditions by qualified (NVG) Flightcrew?

Do we expect the FAA must surely act soon?

Nope.
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Old 3rd Sep 2010, 10:50
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I am sure I am not alone in this frustrating scenario.

More unnecessary deaths for what?

Absolutely for what???

Can someone please confirm that: “night-vision gear” actually means “Night Vision Goggles” (NVG's) flown in Night Visual Conditions by qualified (NVG) Flightcrew?

Do we expect the FAA must surely act soon?

Nope.
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Old 3rd Sep 2010, 10:50
  #40 (permalink)  
 
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I am sure I am not alone in this frustrating scenario.

More unnecessary deaths for what?

Absolutely for what???

Can someone please confirm that: “night-vision gear” actually means “Night Vision Goggles” (NVG's) flown in Night Visual Conditions by qualified (NVG) Flightcrew?

Do we expect the FAA must surely act soon?

Nope.
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