Helicopter EMS Issues in the USA
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Helicopter EMS Issues in the USA
A very good article discussing the US Helicopter EMS Industry and its woes, trials, and tribulations. It also notes being a Pilot in that role is just about the most dangerous occupation in the country with a very high on the job mortality rate.
http://www.sltrib.com/portlet/articl...007&siteId=297
A great interactive study of helicopter EMS accidents and historical events such as FAA actions and Medicare Funding changes that have affected the EMS industry.
Fatal Flights: Fatal Medical Helicopter Crashes Since 1980 (washingtonpost.com)
http://www.sltrib.com/portlet/articl...007&siteId=297
A great interactive study of helicopter EMS accidents and historical events such as FAA actions and Medicare Funding changes that have affected the EMS industry.
Fatal Flights: Fatal Medical Helicopter Crashes Since 1980 (washingtonpost.com)
Last edited by SASless; 24th Aug 2009 at 14:27.
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And when compared to the EMS operations north of the 49th parallel, it's even more eye opening. Much could be learned from the success of les Canadiens, who haven't had an accident in years...
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I would be the first to admit that the US HEMS industry needs a makeover.But , this comparison with the Candian system drives me nuts.800+ helicopters versus 20+. Government run vs for profit.All this makes the comparison moot. It's like comparing peaches to a watermelon.
Alt3.
Alt3.
Thread Starter
Comparing zero accidents to our dismal record does need looking at to see what factors influence their success at avoiding all these fatalities. May be there are no lessons to be learned but perhaps it is worth looking at.
For sure we have no bragging rights on safety performance.....at least as I see it!
For sure we have no bragging rights on safety performance.....at least as I see it!
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Perhaps the reason the Canadian system is so much safer is *because* it is so different? I really don't understand why the FAA don't grow a pair and regulate the industry properly.
From the article: "Shortly after midnight...a medical helicopter pilot, started across Choctawatchee Bay to pick up a hospital patient and transport him to a facility 60 miles away. Palcic, 63, was just two minutes into the flight of AIRHeart-1 when his crew radioed a dispatcher that he was turning back because of the thunder and lightning.
Moments later, Palcic's helicopter banked in clouds and plunged 700 feet into shallow waters, killing him, a flight nurse and a paramedic.
VFR at night over water with known thunderstorms in the area? And, this was a hospital to hospital transfer. Pure craziness.
From the article: "Shortly after midnight...a medical helicopter pilot, started across Choctawatchee Bay to pick up a hospital patient and transport him to a facility 60 miles away. Palcic, 63, was just two minutes into the flight of AIRHeart-1 when his crew radioed a dispatcher that he was turning back because of the thunder and lightning.
Moments later, Palcic's helicopter banked in clouds and plunged 700 feet into shallow waters, killing him, a flight nurse and a paramedic.
VFR at night over water with known thunderstorms in the area? And, this was a hospital to hospital transfer. Pure craziness.
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Very interesting article.
There are some interesting differences between the way the whole setup is put together in the USA and other places. Not really to do with flight safety, but the article's description of a "golden trout" is exactly the opposite situation to the UK. For the receiving hospital in the USA, the patient is a revenue generator. In the UK it is exactly the opposite: a drain on effectively fixed resources. It is obvious that in the US hospital management is keen to receive HEMS. In the UK it is pretty much exactly the opposite.
There are some interesting differences between the way the whole setup is put together in the USA and other places. Not really to do with flight safety, but the article's description of a "golden trout" is exactly the opposite situation to the UK. For the receiving hospital in the USA, the patient is a revenue generator. In the UK it is exactly the opposite: a drain on effectively fixed resources. It is obvious that in the US hospital management is keen to receive HEMS. In the UK it is pretty much exactly the opposite.
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Vee r,
Once again, I would like to dissent. The problem is not a lack of regulation. Part 135 is pretty comprehensive. Besides, the society in the US is allergic to govt. intervention in business and the FAA has to walk that fine line between regulating and promoting air commerce.The companies are ruthless. They will cut corners in equipment,salaries and aircraft maintenance as far as possible to maintain the 1:475 ratio of earnings of worker to CEO that has become so much a part of the US captalistic culture.Also, a suddden spurt of onerous regulations mandating equipment that is expensive and,given the dubious helath care reimbursement rates here,will probably put a lot of companies out of business and put a lot of pilots out in the street. Once again, a prickly scenario which the FAA is loath to get into.
What is the solution? Self regulation. Foremost by us in the trenches,followed by the companies,individually and as a group and possibly, an agency (not the FAA) that can oversee HEMS ops. Kind of like the USFS does for the firefighting industry.Not great but better than what we have now.
SASLess,
With due respect, comparing the accident rate of a low volume, low risk tolerant nation like Canada with the high volume,high risk tolerant nation like ours is a non starter. The accident rate of Sun Country Airlines compares very favorably with that of American or United or Delta or Continental. Does it mean that Sun Country is safer or does it mean they don't fly a lot given their fleet size compared to the legacy carriers?
Alt3.
Once again, I would like to dissent. The problem is not a lack of regulation. Part 135 is pretty comprehensive. Besides, the society in the US is allergic to govt. intervention in business and the FAA has to walk that fine line between regulating and promoting air commerce.The companies are ruthless. They will cut corners in equipment,salaries and aircraft maintenance as far as possible to maintain the 1:475 ratio of earnings of worker to CEO that has become so much a part of the US captalistic culture.Also, a suddden spurt of onerous regulations mandating equipment that is expensive and,given the dubious helath care reimbursement rates here,will probably put a lot of companies out of business and put a lot of pilots out in the street. Once again, a prickly scenario which the FAA is loath to get into.
What is the solution? Self regulation. Foremost by us in the trenches,followed by the companies,individually and as a group and possibly, an agency (not the FAA) that can oversee HEMS ops. Kind of like the USFS does for the firefighting industry.Not great but better than what we have now.
SASLess,
With due respect, comparing the accident rate of a low volume, low risk tolerant nation like Canada with the high volume,high risk tolerant nation like ours is a non starter. The accident rate of Sun Country Airlines compares very favorably with that of American or United or Delta or Continental. Does it mean that Sun Country is safer or does it mean they don't fly a lot given their fleet size compared to the legacy carriers?
Alt3.
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Perhaps the question should be why is it more acceptable in the United States to accept higher risk, treat workers like "Cannon Fodder" then it is in the rest of the world?
I see the same trend in forest fire operations. In the United States more forest fire fighters are likely to die in a single fire season then in 20 seasons in Canada.
I see the same trend in forest fire operations. In the United States more forest fire fighters are likely to die in a single fire season then in 20 seasons in Canada.
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AL3,
I would suggest Part 135 is pretty restrictive.....but enforcement of 135 in the EMS world is pretty well non-existent. Neither the operators or the FAA really do a decent job of living to the rule.
The problem is the conflict between complying with the rule....and getting the job done.
Simple case in point.....Night VFR surface light reference requirements.
There's lots of very dark places in the country and how many of us ignore the requirement to have that bit of help from the lighted objects on the ground and just cruise on over those dark places knowing there will be lights at our destination? Everyone of us are illegal to do so but we do it (I have to use past tense for me as I am now happily and safely retired.).
How many times do you break the rules before the odds catch up with you and turn you into a statistic?
I would suggest Part 135 is pretty restrictive.....but enforcement of 135 in the EMS world is pretty well non-existent. Neither the operators or the FAA really do a decent job of living to the rule.
The problem is the conflict between complying with the rule....and getting the job done.
Simple case in point.....Night VFR surface light reference requirements.
There's lots of very dark places in the country and how many of us ignore the requirement to have that bit of help from the lighted objects on the ground and just cruise on over those dark places knowing there will be lights at our destination? Everyone of us are illegal to do so but we do it (I have to use past tense for me as I am now happily and safely retired.).
How many times do you break the rules before the odds catch up with you and turn you into a statistic?
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Night surface reference
SAS,
You might try a legal interpertation search for night helicopter surface reference. There is a legal interpertation dating back to about 1992 from the FAA in D.C that states if the aircraft is equiped with the flight instruments required by Part 135 for night or over the top operations it may be flown with out surface light reference. The aircraft does not have to be IFR certified.
A literal interpertation of the surface reference requirement would prevent night ops with S92's EC225's ect unless they were on an IFR flight plan.
In spite of all the above there has to be a better way of operating at night than is currently in use. The Bond EC225 and the most recent EC145 accident in Forida would indicate that technology by it's self is not the answer.
When is the last time you witnessed a VFR operator conduct any training or flight checks at night. At the very least an inprovement in training and testing is in order.
JHR
You might try a legal interpertation search for night helicopter surface reference. There is a legal interpertation dating back to about 1992 from the FAA in D.C that states if the aircraft is equiped with the flight instruments required by Part 135 for night or over the top operations it may be flown with out surface light reference. The aircraft does not have to be IFR certified.
A literal interpertation of the surface reference requirement would prevent night ops with S92's EC225's ect unless they were on an IFR flight plan.
In spite of all the above there has to be a better way of operating at night than is currently in use. The Bond EC225 and the most recent EC145 accident in Forida would indicate that technology by it's self is not the answer.
When is the last time you witnessed a VFR operator conduct any training or flight checks at night. At the very least an inprovement in training and testing is in order.
JHR
Thread Starter
What does your OpSpecs say.....that would be the first hurdle to get over then you might try to fall back on the information you suggest.
But.....this is what the Regulation states:
But.....this is what the Regulation states:
Code of Federal Regulations
Sec. 135.207
Sec. 135.207
Part 135 OPERATING REQUIREMENTS: COMMUTER AND ON-DEMAND OPERATIONS AND RULES GOVERNING PERSONS ON BOARD SUCH AIRCRAFT
Subpart D--VFR/IFR Operating Limitations and Weather Requirements
Sec. 135.207
VFR: Helicopter surface reference requirements.
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.
Sec. 135.207
Sec. 135.207
Part 135 OPERATING REQUIREMENTS: COMMUTER AND ON-DEMAND OPERATIONS AND RULES GOVERNING PERSONS ON BOARD SUCH AIRCRAFT
Subpart D--VFR/IFR Operating Limitations and Weather Requirements
Sec. 135.207
VFR: Helicopter surface reference requirements.
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.
Last edited by SASless; 28th Aug 2009 at 01:25.
The Canadians provided an NPA in 2001 that attempted to address this situation; the explanatory text is illustrating:
The subsequent change in regulations inserted the following text:
It is not clear that the problem is solved with the addition of this text because it still relies upon judgement that cannot be made before flight and therefore dispatch criteria is not established.
The amount of external visual cues is also related to the handling qualities of the aircraft. As has been stated in the 'EC225/New Procedures' threads, an aircraft that has sufficient flight control augmentation can be flown safely with very few external references.
To paraphrase Gomar Pylot 'there are sufficient visual references until there aren't'.
Jim
Issue:
Aircraft operating under the visual flight rules (VFR) are required by the Canadian Aviation Regulations (CARs) 602.114 - Minimum Visual Meteorological Conditions for VFR Flight in Controlled Airspace and CAR 602.115 - Minimum Visual Meteorological Conditions for VFR Flight in Uncontrolled Airspace, to operate with "visual reference to the surface".
The term "visual reference" is not defined and there have been many accidents where aircraft have crashed due to pilot disorientation caused by a lack of visual cues. These situations typically occur during night VFR flight or flight over featureless snow covered terrain or frozen lakes.
Justification for Change:
The single most important instrument for maintaining aircraft attitude is an attitude indicator. As can be seen from the regulations above, any aircraft may be operated during the day without an attitude indicator and a private aircraft operated at night without one. In reality, virtually all aeroplanes have attitude indicators, as do most helicopters. The problem more likely lies in pilot training and judgment than in equipment shortcomings.
There is a common misconception that if the minimum visibility criteria are met, then conditions are suitable for VFR flight, particularly during daylight. There is also general agreement among pilots that flight in conditions with any reduction in visibility on a dark night over uninhabited terrain is not VFR. The difficulty in rationalizing these different points of view is in determining what constitutes visual reference. Some jurisdictions have used the concept of a "visible horizon".
The United States’ Federal Aviation Regulations (FARs) Part 135 (equivalent to CARs subparts 703 and 704) mention "surface reference" only for helicopters as follows:
"135.207 VFR: Helicopter surface reference requirements - No person may operate a helicopter under VFR unless that person has visual surface reference or, at night, visual surface light reference, sufficient to control the helicopter."
Jane’s Aerospace Dictionary uses the following definition:
"visual reference - Earth’s surface, esp that clearly identified and thus giving geographical position as well as attitude and orientation guidance, used as a reference in controlling flight trajectory, if necessary down to touchdown."
These two references address the aircraft’s attitude and orientation with the Jane’s Aerospace Dictionary definition additionally requiring geographical information.
The CARs, Part VII, Regulations for night VFR indicate that electronic means of navigation are acceptable and the terrain and wide expanses of water in Canada may make determining geographical position by reference to the surface difficult.
Transport Canada has been addressing the issue of pilot judgement in various ways and these hopefully will have an effect on inappropriate use of the visual flight rules. It is felt that clarification of the term "visual reference" will have the effect of preventing flight when conditions do not fit the intent of these rules. There will no doubt always be an element of subjectivity when assessing if visual reference is adequate, however, incorporation of the following suggested change may assist in guiding pilots and supervisors in conducting operations in difficult conditions.
Aircraft operating under the visual flight rules (VFR) are required by the Canadian Aviation Regulations (CARs) 602.114 - Minimum Visual Meteorological Conditions for VFR Flight in Controlled Airspace and CAR 602.115 - Minimum Visual Meteorological Conditions for VFR Flight in Uncontrolled Airspace, to operate with "visual reference to the surface".
The term "visual reference" is not defined and there have been many accidents where aircraft have crashed due to pilot disorientation caused by a lack of visual cues. These situations typically occur during night VFR flight or flight over featureless snow covered terrain or frozen lakes.
Justification for Change:
The single most important instrument for maintaining aircraft attitude is an attitude indicator. As can be seen from the regulations above, any aircraft may be operated during the day without an attitude indicator and a private aircraft operated at night without one. In reality, virtually all aeroplanes have attitude indicators, as do most helicopters. The problem more likely lies in pilot training and judgment than in equipment shortcomings.
There is a common misconception that if the minimum visibility criteria are met, then conditions are suitable for VFR flight, particularly during daylight. There is also general agreement among pilots that flight in conditions with any reduction in visibility on a dark night over uninhabited terrain is not VFR. The difficulty in rationalizing these different points of view is in determining what constitutes visual reference. Some jurisdictions have used the concept of a "visible horizon".
The United States’ Federal Aviation Regulations (FARs) Part 135 (equivalent to CARs subparts 703 and 704) mention "surface reference" only for helicopters as follows:
"135.207 VFR: Helicopter surface reference requirements - No person may operate a helicopter under VFR unless that person has visual surface reference or, at night, visual surface light reference, sufficient to control the helicopter."
Jane’s Aerospace Dictionary uses the following definition:
"visual reference - Earth’s surface, esp that clearly identified and thus giving geographical position as well as attitude and orientation guidance, used as a reference in controlling flight trajectory, if necessary down to touchdown."
These two references address the aircraft’s attitude and orientation with the Jane’s Aerospace Dictionary definition additionally requiring geographical information.
The CARs, Part VII, Regulations for night VFR indicate that electronic means of navigation are acceptable and the terrain and wide expanses of water in Canada may make determining geographical position by reference to the surface difficult.
Transport Canada has been addressing the issue of pilot judgement in various ways and these hopefully will have an effect on inappropriate use of the visual flight rules. It is felt that clarification of the term "visual reference" will have the effect of preventing flight when conditions do not fit the intent of these rules. There will no doubt always be an element of subjectivity when assessing if visual reference is adequate, however, incorporation of the following suggested change may assist in guiding pilots and supervisors in conducting operations in difficult conditions.
No person shall operate an aircraft in VFR flight within uncontrolled airspace unless
(a) the aircraft is operated with sufficient visual referenceto enable a pilot to maintain the aircraft’s attitude and orientation with reference to the earth’s surface by the use of visual external cues;
...
(a) the aircraft is operated with sufficient visual referenceto enable a pilot to maintain the aircraft’s attitude and orientation with reference to the earth’s surface by the use of visual external cues;
...
The amount of external visual cues is also related to the handling qualities of the aircraft. As has been stated in the 'EC225/New Procedures' threads, an aircraft that has sufficient flight control augmentation can be flown safely with very few external references.
To paraphrase Gomar Pylot 'there are sufficient visual references until there aren't'.
Jim
Thread Starter
NTSB to issue a report soon.....
The FAA is publishing new policies/regulations regarding NVG's....wonder what provoked that I wonder?
•Safety Recommendation letters - Safety Board proposes 19 recommendations regarding Helicopter Emergency Medical Services (HEMS). These recommendations addresses various safety issues including pilot training; safety management systems to minimize risk; collection and analysis of flight, weather, and safety data; flight data monitoring; development of a low altitude airspace infrastructure; and the use of dual pilots, autopilots, and night vision imaging systems
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What provoked that is obvious to me. The FAA started allowing the use of NVGs, and thus had to issue regulations concerning them. When they didn't allow them, there was no need of further regulation. Time marches on, along with technology, and thus regulatory requirements change. Once there was no need for regulations concerning the use of VORs.
I see no good way out of allowing pilots to exercise some judgement. IMO, I get paid for my judgement, not for anything else. If I can't use that, then why not just use pilotless drones, controlled from a central location? Some people will always exercise bad judgement, and good judgement comes from making bad decisions and learning from them. If someone else always makes all the decisions for a pilot, that pilot will never become a safe and proficient pilot, because (s)he will never learn to make decisions, and inevitably a decision will be required, because not even the FAA can anticipate everything. All that can be done, IMO, is to set out the minima and expect pilots to comply, and punish those who don't. I don't believe there is a magic bullet, and the only way to completely eliminate all risk is to immediately destroy every aircraft that exists, and never even consider flying again. I'm not in favor of that. Everybody dies eventually, so we may as well accept that and stop the panic attacks.
I see no good way out of allowing pilots to exercise some judgement. IMO, I get paid for my judgement, not for anything else. If I can't use that, then why not just use pilotless drones, controlled from a central location? Some people will always exercise bad judgement, and good judgement comes from making bad decisions and learning from them. If someone else always makes all the decisions for a pilot, that pilot will never become a safe and proficient pilot, because (s)he will never learn to make decisions, and inevitably a decision will be required, because not even the FAA can anticipate everything. All that can be done, IMO, is to set out the minima and expect pilots to comply, and punish those who don't. I don't believe there is a magic bullet, and the only way to completely eliminate all risk is to immediately destroy every aircraft that exists, and never even consider flying again. I'm not in favor of that. Everybody dies eventually, so we may as well accept that and stop the panic attacks.
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I find it interesting that the EMS industry in the U.S. fully supports safety, the efforts of the IHST, etc. Unless it impacts the bottom line. The number of single pilot, unaugmented (SASless and/or lacking autopilot), VFR certified rotorcraft point to that.
Sure, pilots are paid to use their judgement. But what pilot wants to say "No" to a mission in which he could save a life ... even if the weather is marginal, at night, and near the end of his duty day? I'm curious as to how much "judgement" an EMS Op Specs allows a pilot to use, without fear of losing his job?
And how many accidents have occurred when the injuries were not life threatening, and a ground ambulance would have been more appropriate.
Clearly Part 135 doesn't work, as written.
Surely there's at least one lesson to be learned from the Canadians (who, by the way, modeled their system from a public use operation in the Lower 48).
Sure, pilots are paid to use their judgement. But what pilot wants to say "No" to a mission in which he could save a life ... even if the weather is marginal, at night, and near the end of his duty day? I'm curious as to how much "judgement" an EMS Op Specs allows a pilot to use, without fear of losing his job?
And how many accidents have occurred when the injuries were not life threatening, and a ground ambulance would have been more appropriate.
Clearly Part 135 doesn't work, as written.
Surely there's at least one lesson to be learned from the Canadians (who, by the way, modeled their system from a public use operation in the Lower 48).
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I can't speak for all operators, but we say no all the time, and I know of many others who do. If you're in this business to save lives, you're in the wrong business. It's just another for-profit business, and I don't think about lives other than mine and the med crews. Our weather minimums are the highest I've ever flown to, by far, and if the weather is below those minimums, we just don't go, and I've never been questioned about it. We won't get fired for declining flights, but we will get fired for flying in weather below the minimums. If we land enroute because of poor weather, that's better than flying on and dying, but we may be questioned about why we flew in the first place. I'm confident that at least the major operators have seen the light and are enforcing the weather minimums, and not firing any pilots for turning down flights for weather. Pilots being humans, though, may feel self-imposed pressures to fly, but those who do need to be weeded out, and will be eventually, one way or another.
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Sure, pilots are paid to use their judgment. But what pilot wants to say "No" to a mission in which he could save a life ... even if the weather is marginal, at night, and near the end of his duty day? I'm curious as to how much "judgment" an EMS Op Specs allows a pilot to use, without fear of losing his job?
I don't mind leaving for a call if my duty day is nearing it's end though. If there's time to get a patient to a hospital that's fine. We just inform dispatch that if we turn into pumpkins on the hospital roof, the machine isn't moving until our relief arrives. Wouldn't be the first time I've left a helicopter on a pad and gone back to the hangar in a taxi. It's a pain in the butt, but the mission was completed and no one violated duty limits.
It may sound callous, but I'm with Gomer too when it comes to allowing the patient to enter into the equation. I don't let their welfare go past idle curiosity in my mind, otherwise my brain is in the wrong part of the helicopter.
Thread Starter
GOM and Canuck,
How do you achieve "peace" with your med crews when you think as you do? I took the same view as you do and seemed to be confronted with the "we are here to save lives attitude" and "what do you mean we are just in a medical patient transportation business?" attitude by the Med Crews. The industry is full of those types who see themselves engaged in noble, angelic, heroic battle with death types.
How do you achieve "peace" with your med crews when you think as you do? I took the same view as you do and seemed to be confronted with the "we are here to save lives attitude" and "what do you mean we are just in a medical patient transportation business?" attitude by the Med Crews. The industry is full of those types who see themselves engaged in noble, angelic, heroic battle with death types.
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IME, most of the med crews don't want to go as often as I do. They're all former ground medics and ER nurses, and they fully realize that people die, and they don't want to die in a helicopter. I've never had any issues at all from the med crews about turning down flights, but I have aborted a couple of flights that I considered rather routine when the med crew decided the weather was too bad. Our med crews simply don't get rabid about saving lives. Ambulances take a lot longer, but the patient's car wreck isn't our fault, and we aren't going to die to get them to a trauma center a little quicker. The only medical personnel I've met who are really gung-ho about saving lives are newbies, and we don't hire any of those.