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-   -   NTSB says EMS accident rate is too high (https://www.pprune.org/rotorheads/346122-ntsb-says-ems-accident-rate-too-high.html)

Gomer Pylot 3rd Jan 2012 20:01

IME we rarely save lives, but we do reduce morbidity, especially with cardiac and stroke victims. Where I work, it takes far more than an hour to get a patient to a stroke or cardiac center by ground ambulance, and that's if the traffic is light approaching and in the big cities. It's not unusual to have traffic jams on the freeways that take hours to clear. All the while, the stroke or cardiac patient's chances of a full recovery are diminishing. A helicopter can get them there in a half hour or less. It's the same for trauma patients, but for most of those the outcome will be similar in an ambulance or a helicopter, and the main difference is in how long they will be in pain, and how many hospitals they will have to pay. Local hospitals can't deal with major trauma or broken bones, they just do first aid and ship the patients out to a larger hospital. It's not ideal, I admit, but that's what we have here. Skipping the local hospital, which the ground ambulance can't legally do, actually saves money, even if it doesn't save lives. And make no mistake, the health care industry here is about money, nothing else. The public isn't paying for HEMS, at least not directly, the end user is. The government is being kept out of the health care industry because it would reduce the enormous profits the insurance companies and the big hospital corporations make. Haven't you heard the outcry against 'Obamacare', which actually does little to help patients, and much more to help corporations? Even a little public help is too much for the teahadists.

I would be happy enough if the FAA suddenly mandated twin-engine, IFR helicopters for all EMS operations, although I would probably join the unemployed. First, the required number of those helicopters just don't exist, and it would take years before the factories could produce them. Second, the FAA simply does not have the authority to make such a mandate. This isn't England, it's the US of A, where the government is subject to the will of the people, not vice versa. At least theoretically. In reality, the government is subject to the will of the corporations which bribe the politicians. Either way, such a mandate is simply not possible, regardless of whether it's a good idea or even morally right.

The situation is as it is, and will remain so for at least the foreseeable future, and no amount of petitioning will change it, unless accompanied by millions of dollars. I have the same right as Shell Oil or the Koch brothers to bribe members of Congress to do what I ask. I just don't have the millions of dollars. The system isn't good, or right, but I don't have any idea how to change it. Those who can, have a vested interest in keeping things the way they are. So complaining about how things are done in the US may make Europeans feel better, but it will do nothing else.

MamaPut 3rd Jan 2012 20:56

Gomer Pylot,

Your last post is probably the most lucid and honest I've seen in a long time with its views on politics, corporate might and balancing ethics and morality with profit and reality. Well said. You, sir, are a true American "common man". Keep up the good work :ok:

ShyTorque 3rd Jan 2012 22:31


So complaining about how things are done in the US may make Europeans feel better, but it will do nothing else.
A very raw nerve has obviously been touched here. I don't think that anyone on the European side of the Atlantic has complained about how things are done in USA; why would we bother? It has merely been pointed out (on what is, after all, a forum for professional pilots) that things are now done differently on the other side of the Atlantic, for reasons of better capability and hopefully, for better safety. Night charters shouldn't be killing people. EMS shouldn't be killing people. Regardless of statistics, one accident is one too many.

Night helicopter ops will always have risks due to the nature of the job but it's disappointing if certain known risks cannot be reduced.

I didn't like the rule changes we were forced to obey in UK regarding night operations. It affected all of us, and we complained too. It affected the price of later contracts and therefore salaries in some sectors. However, there were a number of high profile accidents, as already mentioned and that was seen as unacceptable.

I, for one, believe that the USA deserves better equipment for the job in hand. If the industry isn't interested in providing better equipment and training to use it (and from what has been said here, it obviously isn't, due to loss of commercial margins) and the FAA won't mandate a change, then things will never progress. Companies will continue to buy cheaper aircraft and expect pilots to just carry on regardless.

The USA, as a huge economy, quite rightly likes to reflect on the fantastic advances it has traditionally made in all other branches of the aviation industry. Not to forget it put men on the moon almost 43 years ago. So it seems very strange that it won't even consider phasing out non-autopilot and otherwise under-equipped, non IFR helicopters for night roles. :hmm:

I await the accident report of the all-too recent "organ retrieval" accident.

170' 3rd Jan 2012 23:02

...
 
Gomer Pylot...

Hammer,Nail,Head :ok:

Gomer Pylot 4th Jan 2012 01:51

ShyTorque, I thought I had made my point, but obviously I didn't. It's not possible to suddenly just abandon several hundred aircraft and replace them with non-existent aircraft. They do not exist. There is an effort to find an acceptable, certifiable autopilot for existing aircraft, and that will probably be done as soon as someone comes up with one. The other problem is purely economic. It's not economically feasible to quit using current aircraft in some areas. We either use what can make a profit, or we quit HEMS entirely in a huge portion of the USA. The government will not, cannot, take over EMS operations here. It has to be done by the private sector, and that can only be done if there is a profit. I do believe the government should be doing the job, but the majority of the citizens do not, thus it won't happen soon. In an ideal world, things would be different, but this world, and this country, are not ideal, and never will be. We have to do the best we can with what we have, and keep trying to slowly make things better.

SASless 4th Jan 2012 02:33

GP,

What about the EMS programs that lose money on their operation but the hospital makes a profit after making up the loss incurred by the EMS operation as a result of the knock on effect of increased business at the hospital and clinics from patients drawn into the system?

Yes...in general...the EMS business is just that....making money but not necessarily at the Helicopter Unit level.

I would argue against the concept the Guvmint shoud provide the service.

Fundamentally I am opposed to the government getting into any "business" that is not a basic function of government. Search and Rescue...for example is a necessary government function but medical transportation is not in my view.

Just as I woud not have the government doing pothole repair.....I would have them paying for the repair but contracting it out.....in some states the liquor stores are run by the State or County.....and again I would take them out of that business and let the private sector run the liquour business.....with the State just taking some Tax money off the proceeds (and leaving all the cousins and brother-in-laws to find a private sector job instead of being a ward of the State).

Why is it wrong for the insurance industry selling a product and making a profit....and health car being provided by private organizations rather than the government?

I do agree we need to get the money out of politics and government out of business....along with business out of government....but as you so clearly stated...that just ain't gonna happen shy of a bona fide Revolution that would make the French one look like a garden party.

The way I see it...as long as there is a need for a service....and someone can provide it at a reasonable price...there will be buyers of that service. As the law of economy of scale works...folks wil find a way to group together to obtain bulk rates.

The key is to eliminate the barriers to fair and free competition where the providers with the best/cheapest product will prosper and those that cannot compete will fail.

You might recall in the earl days of the EMS business an outfit called Rocky Mountain Helicopters that found itself unable to get insurance because of their safety record. They soon went out of business....and other outfits formed and have become quite successful.

[email protected] 4th Jan 2012 02:47

The commercial realities of this business are what they are in the markets they serve. I’ve witnessed them first hand on both sides of the pond where decisions were made based purely on economic realities. In the US margins, are wafer thin and generally not investor friendly relative to the risk involved and the rate of return generated.

At the end of the day we are in business wholly because someone wishes to generate a reasonable rate of return on an investment. In any business risks are only mitigated to the extent that a loss might be acceptable when measured relative to the investment required to mitigate the risk entirely, after which there is an overall and rapidly diminishing rate of return or interest.
With 5% net margins commonly experienced by helicopter operators, even a larger operator earning $1 billion in revenues a year cannot afford too many strategic mistakes, let alone continued fleet renewal or upgrades. $50 million a year will get you a few helicopters, maybe some regulatory compliance, a few essential maintenance upgrades and maybe fix some maintenance/pilot errors. It hardly extends to satisfying investors who might reasonably expect a much higher rate of return parking their cash else where, with significantly lower risk. As Gomer said private companies are neither able, nor sensibly willing to consider some of the suggestions made – they simply could not continue in business,; at least in the US.


Pilots/Engineers are there to fulfill a job, that someone else is willing to provide, and must decide for themselves if the risk is acceptable to them. In the meanwhile the private job providers here in the US will continue to decide whether it is worth while being in the business, irrespective of what regulatory, crews or others may wish. In both cases of course, the balance of value/risk is worth more to some than others and perhaps a matter of perspective.

ShyTorque 4th Jan 2012 07:54

Gomyer, please note that I wrote "phasing out", not "suddenly abandon". The CAA didn't mandate a sudden abandonment, it gave a date in the future for a requirement for stabilized helicopters. :=

SASless 4th Jan 2012 08:43

Are we finished demanding twins and accepting the fact the number of engines is not the issue? Have we finally accepted it is not engine failures that are killing off the EMS crews? Perhaps there is progress being made....that being understanding the causes of the problem and not the symptoms of the problem.

It is CFIT or LOC following IIMC that is killing them, and that it does four times as often at Night than in the daytime that is the biggest killer.

Let's focus on the root cause of the problem shall we?

ShyTorque 4th Jan 2012 12:41


Are we finished demanding twins and accepting the fact the number of engines is not the issue?
SASless, who actually said it was the issue?

rotorspeed 4th Jan 2012 14:16

SASless

Ok let's indeed focus on the issue. Would you like to propose a detailed spec of helicopter you would mandate if you were making the decisions at the FAA, in order to provide far safer HEMS at night, at a viable cost? And what timescale would you implement it over?

Art of flight 4th Jan 2012 14:22

Perhaps I could start the spec list with....the ability to fly IFR in IMC in accordance with national legislation when VFR flight is not possible due to weather.

[email protected] 4th Jan 2012 14:34

An interesting topic without doubt but whilst we are on the subject of who pays for what, can we just remember that the UK Government doesn't pay for HEMS and AA, they are funded by charities.

Perhaps this is a model that could be considered by the USA since the relatively few UK taxpayers (compared to the US) manage to fund twin-engine IFR helciopters quite satisfactorily. No bribing of politicians, no profiteering, just people raising money for a service and paying an equitable amount for a suitably safe service at that.

JimL 4th Jan 2012 14:51

Art of Flight,

That is really not the answer. Rather than construct a new text, below is contents of an email on the subject sent to the Rapporteur of the ICAO HEMS WG in 2009.

In my view the issue is not so much about the ability to fly in IFR (for which the certification criteria exists) but one of addressing the issue of flight in VFR when it is no longer possible (or really difficult) to "...be able to see outside the cockpit, to control the aircraft's attitude, navigate and avoid obstacles and other aircraft".


My main comment would be that problems are mostly associated with reduced visibility and, not necessarily, a descending cloud base. This leads to two additional problems:

1. How is visibility measured in flight (I don’t know the answer); and

2. What if the cloud is descending generally – executing the 180º will not result in a flight back into a clear area.

This is why I emphasized that the decision is never presented to the pilot in clear and unambiguous terms. On the other hand, if the aircraft is well equipped – either with two pilots or with an autopilot (but in any case with some form of augmentation); there is a buffer both in height and in control.

My view has always been that although Parts 27/29 have a clause that states in 2x.141(c):
The rotorcraft must: (c) Have any additional characteristics required for night or instrument operations, if certification for those kinds of operation is requested. Requirements for helicopter instrument flight are contained in appendix B.
It is well known that there are no enforced requirements for certification associated with night operations (or operations in a reduced visual cue environment by day). This is not such an issue in those States where aircraft used for night HEMS are twins certificated under Appendix B of Part 27/29, but in the USA where singles with no additional (stability) requirements are used, too much reliance is placed upon FAR 135.207:
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
which, in an unlit area, relies upon the use of NVG to meet the visual surface reference requirements.

Although the objective of the rule does state that visual cues must be “sufficient to safely control the helicopter”, we all know that this (subjective judgement) is totally reliant upon the other part of the equation - i.e. the stability of the helicopter. Whilst that stability is addressed by Appendix B to Parts 27/29 for any aircraft that is certificated for flight in IMC, it is not for most singles (and even some twins).

The handing qualities of the helicopter and the usable cue environment are inversely proportionate to each other. As the quality of handling increases, the requirement for visual cues reduces. At the extreme (with an auto-pilot), the only cues that are required, are those which provide for obstacle avoidance (not unimportant but of a secondary order).

This is not a message that is usually well received by regulators, or operators, as it really points to the necessity to address stability in a reduced visual cue environment – particularly at night. The traditional answer to this dilemma is to place a requirement, at night, for twins (knowing that most will come with certification for flight in IMC) - this is the European solution; in addition, in some States (the UK for one), airspace at night is designated IFR; which leads to the (JAR) requirement for an auto-pilot for single-pilot operations.

Night IFR in the UK does not mandate the full set of rules contained in ICAO Annex 2 but instead a quasi-night-VFR regime exists that permits operations below 3,000ft to be conducted much as they are for day VFR.

No simple answers but, if States wish to address the main issues, stability is key; it does not have to be twins, Appendix B to Parts 27/29 can be used for singles.

It is only when the issue of stability has been addressed that EVS or SVS come into play; they address (the secondary issue mentioned above of) obstacle avoidance but can never replace the necessity for good handling qualities.
Jim

ShyTorque 4th Jan 2012 15:01

Thankyou for posting that, Jim. I was beginning to think earlier that I was a lone voice!

The last but one paragragh is what I've been advocating here but it's difficult when the bullets keep flying about the USA not being able to afford "our" twins and the shooters refuse to read what's actually being written.

Art of flight 4th Jan 2012 15:39

Quite agree Jim, just starting the list for rotorspeeds request. Of course that list could be started at any point including, aircraft equipment, pilot training and qualification, CRM/HF, briefing facilities, regulation and legislation etc....

I for one am grateful to be flying UK police ops in aircraft that are legislated for by the years of hard won arguments for regulation by people such as JimL. Wasn't long ago we in the UK were flying single pilot without stability at night and without any instrument qualifications, of course we still haven't got the later for police ops!

SASless 4th Jan 2012 16:42

JimL's post pretty well sums it up.

The only way I would differ with his input is the priority I would place on the two issues....(as I read it....)his being "stability" over "cues" and I would make it the reverse...."Cues" over "Stability" but the end result is the same. The better one can see the ground and obstacles....the less sophistication one needs.

I use the example of comparing two extremes of weather....one with a stark clearly defined ceiling with excellent visibility beneath the over cast and the opposite where there is very limited visibility with no definition between the cloud base and the surface touching phenomenon (fog, haze, smoke, mist) that obscures visual cues.

I know which one I gladly fly in....and the one I adamantly refuse to fly in. If I can see clearly....if only a few feet above the terrain..I can avoid obstacles and do so comfortably. No autopilot or stability augmentation needed.

If I am struggling to see what is in front of me...even if at only a few feet above the terrain...I am decidedly unhappy. Even if at a "safe" height and I cannot see but a short murky distance....I am not happy. Having a three/four axis autopilot and a second pilot in the cockpit would not alleviate that discomfort.

Visibility is the key to the issue in my view....not cloud height.

Give me a three/four axis auto pilot and send me out in bad vis at night VFR....is not the right answer. Give me that same autopliot and send me out on an established IFR route....IFR and that is the better concept.

Mere Stability is not the answer alone....there has to be a way to be assured o your location, route, and clearance from both Terrain and Obstacles.

The current Achilles Heel to increasing the sophistication of the aircraft is the lack of Helicopter based IFR route structures and approach procedures. The current system is directly aimed at the Airplane market and not Helicopters.

When we get to where we can do point in space IFR approaches, IFR approaches to off airport locations, and have route structures that facilitate that....we are stuck trying to figure out how to operate safely VFR in IMC conditions...as that is where the hiccups occur.

The sticky bit is when in limited visibility...the transition from VMC to IMC can happen very quickly and usually at the exact worse time and place. Throw in darkness and there is even greater chance for such thing to happen.

If one were to be using an aircraft with a three/four axis autopilot...recovering from IIMC should be far more successful as it would only require a bit of button pushing and assuming George cooperates it is then a matter of confessing one's Sin, gaining an IFR clearance, and completing the flight following IFR procedures....ignoring some minor issues like fuel, fuel reserves, traffic de-confliction while climbing to a safe height IMC with no advance notice to ATC, weather reporting/planning and more than a few other issues.

rotorspeed 4th Jan 2012 18:05

Come on SASless, how about coming up with a succinct list of what you want then! We've been debating suitable regulations to improve HEMS safety - tell us what you would specify, as I asked before!

SASless 4th Jan 2012 19:48

Rotorspeed....if you read my last post it should hit you right square between the eyes what I think will improve safety for EMS operations.

There is not a cook book approach to this situation as it is a very complicated situation on any number of levels.

We have had two pilot crewed IFR Multi-engined helicopters crash as well as single engine VFR only aircraft crash. Thus...equipment alone is not the answer.

We have had Rule/Regulation changes....and we still have crashes so that alone is not the answer.

We have had infrastructure changes....and yes...again...we have crashes so that is not the answer all by itself.

I see the cure as being a multi-disciplined approach to the situation.

Add in all the variables of each Operation...location, tasking, climate, and all that and there is just no simple answer as you are asking for.

My personal preference.....and just my personal view for what I would prefer to fly....a twin engined fully IFR equipped two pilot helicopter equipped with all the bells and whistles it could carry to include NVG's, Moving Map, TAWS, CVR, RadAlts, Dual GPS's, ILS, Marker Beacon, Synthetic Night Vision installed on the aircraft, Air Conditioning, Radar, and Stormscope and be limited to VFR only.

Until the FAA can either provide or authorize the creation Helicopter Only off airways IFR route structure and Point in Space IFR approaches with automated weather reporting at each landing site all Ops would be VFR except for using current IFR routings and facilities under IFR.

Now...over to you.....how does one achieve that....fully IFR operations to the degree I propose?

Nick Lappos, while at Sikorsky the first time, did extensive flight testing of those kinds of IFR procedures using an S-76. Those trials proved it works.

How would you improve safety....I gave you my recipe...what's yours?

rotorspeed 5th Jan 2012 11:13

SASless

To be blunt nothing hits me square between the eyes from your last post. As usual with your posts I find you tend to avoid concise, pertinent responses but ramble on a bit, undoubtedly with a lot of experience and some valid views beneath it all.

The fact is regulations need to be as clear, prescriptive and concise as possible. Training needs to be as well. Time and money is precious, apart from which people get bored trying to understand what they should do from lengthy messages.

I asked you to propose a detailed spec of helicopter you would mandate on a timescale if you were making the decisions at the FAA, in order to provide far safer HEMS at night, at a viable cost. You still have not done this - expressing your personal preference to be for IFR twins with every bell and whistle available and fly VFR only. A pointless comment, frankly!

I started off saying night HEMS ops should be IFR twins. Your position was that VFR singles was OK. So taking on board some research plus US and European comments, my off the cuff spec now for night ops US HEMS would be:

Phase 1, within 1 year:

Single engine providing has a proven failure rate of less than X
3 axis autopilot or two pilots
Radalt
NVGs
IFR approved GPS with moving map
At least 1 pilot instrument rated
Detailed data logging of every flight with reporting for central analysis

Phase 2, within 3 years:

As above but with:
Single engine providing has a proven failure rate of less than Y, (more stringent)
3 axis autopilot with stablisation system
Dual hydraulics
Dual generators
2 x IFR approved GPS
TAWS
CVR

After 3 years of operations the accident and incident data would be reviewed to establish whether there is any justification for moving to twins.

Aircraft spec is JimL's area of expertise, so perhaps he could contribute here.

I suggest someone with more US HEMS experience proposes some criteria for weather, ops and IFR let down procedures etc.

Bear in mind I've only spent 10 minutes on this with no added research, so this very much a starting point - evolutions welcomed!

fly911 5th Jan 2012 11:35

Inadvertant IMC
 
Basic VFR autopilot.

IntheTin 5th Jan 2012 11:58

Nothing really new!

NTSB report on Mayo Clinic crash released | News - Home

Jack Carson 5th Jan 2012 12:11

Rotorspeed, you are right on with your plan. At this time at least one of the major operators in the US (AMC) is well on its way with such a program without being forced into it by the federal government. Their aircraft are presently equipped as follows:

• Very reliable and proven single engine machines AS-350s and B-407s
• Duel Garmin IFR GPS Units – Paying to keep GPS data bases current has been an issue.
• All aircraft are equipped with Radar Altimeters
• All aircraft are NVG equipped with trained crews
• All pilots are instrument rated
• All flights are centrally monitored and tracked by company flight operations with a very sophisticated company proprietary system and monitored by operations personnel (former line pilots) 24/7.
• Most aircraft incorporate HTAWS with plans for 100% incorporation in future
At this time I see two significant holes left to be filled, the incorporation of either two or three axis autopilots and dual hydraulics. Dual hydraulics is optional on the AS-350B2/3 but standard on the B4. I am sure that cost has been a driving factor. Companies have opted for NVG’s in lieu of the more expensive auto pilots. NVGs may help with not encountering IIMC but do little or nothing once IIMC in encountered.

170' 5th Jan 2012 12:12

...
 
SASless

To be blunt nothing hits me square between the eyes from your last post. As usual with your posts I find you tend to avoid concise, pertinent responses but ramble on a bit, undoubtedly with a lot of experience and some valid views beneath it all.


Sasless- Like a lot of people of our generation, often tends to write as he would speak in the crew room or bar. It lends an air of authenticity to his posts and I'm far from alone in thinking that pprune gains tremendous benefit from his 'rambling on a bit'

Perhaps it's that some of us believe nothing will improve dramatically until certain infrastructure changes evolve. off airway IFR routing and PIS arrivals to visual or contact approaches as a mentioned example.

It's well and good to propose new bigger more capable machines, but where does the dough come from? I suspect the IFR, two pilot twin with all available bells and whistles was only Sasless thinking out loud. We all think it would be great. There's an economic reality and a lack of aforementioned infrastructure that will not be overcome be more rules and regs. Until everything else is in place.

Out of time.....Happy New Year to all

170'

SASless 5th Jan 2012 12:32

If one thinks stating the solution to Helicopter EMS accident rates can be done in two or three short sentences then there is no hope of there being effective communication between individuals who view the situation from different perspectives as the issues are far to varied and complex to be so nicely summed up in a manner akin to that of a Readers Digest magazine.

Rotorspeed.....if you do not like the answer...don't ask the question!

You pointedly asked for my input....you got it....deal with it!

If you find fault with my views...argue your points....but don't attack me personally as that is considered very impolite in these circles.

You can disagree but you do not have to be disagreeable....and that is exactly how you come across.

Does your Helicopter EMS experience equate to the time you spent doing that research by any chance?

Some slight problems with your thinking on "Singles".....you have any concept of the impact of putting two pilots in a 206L, 407, 350 helicopter has on the ability to carry a patient?

If you do...you would not have suggested that at all.

When Operators specify a maximum body weight for pilots....as a famous country comedian says...."Here's your sign!"

Your equipment list sounds very much like that I proposed as my personal preference....are you poaching from my list?

Do you assume there is insufficient data on record to be able to make a decision re Engine Failure rates for the various single engine helicopters used for EMS operations currently? Why do we need you "phase" concept. We can make that determination right now....as the EMS Operators have done. They are using these aircraft and we do not hear of a problem with accidents due to engine failures.

[email protected] 5th Jan 2012 18:12

Now Now, men. Steady on. It's just a frank discussion and sometimes you can agree to disagree :)

ShyTorque 5th Jan 2012 18:59


Sasless- Like a lot of people of our generation, often tends to write as he would speak in the crew room or bar. It lends an air of authenticity to his posts and I'm far from alone in thinking that pprune gains tremendous benefit from his 'rambling on a bit'
True, but bear in mind that SASless is no longer in the crewroom. He routinely fires out personal criticisms from his retirement yacht but doesn't like ricochets or return fire. :=

BTW, I'm not sure that two pilots in the present aircraft will be possible. Having operated the 355N in a casevac role (police aircraft, prior to air ambulance in our part of the world), it wasn't practical because when the casualty is on board his legs and feet need to go under the instrument panel, meaning that the front left seat had to be left out. We were obliged to leave one of our observers and his seat behind, sometimes in the hills if we diverted in from our normal job to pick up an urgent casualty case.

Also, the main issue under discussion seems to be loss of visual cues, trying to fly VFR, below safety altitude in IMC. Stabilise the aircraft (autopilot), make it fully IFR capable but leave it single pilot. Not sure how the old mindset of "let's always struggle VFR" could be cured, though.

SASless 5th Jan 2012 20:04

Shy.....I lived long enough to retire....which in our profession does speak for itself and managed to do so without being involved in an accident or chargeable incident. I do have some basis for conjecture about safety issues and concepts based upon those several years experience.

We can disagree without being disagreeable can we not?

If you poke a grouchy ol' bear with a stick....they sometimes bark a bit you know.

Here of late I have been using my walking stick to trip up children as they run by.....darn pesky whippersnappers!

Oh....did sell the yacht....and moved ashore for a while but it will take a bit to wash the salt off my hide.

Devil 49 5th Jan 2012 20:07

No stats or sources cited but-
 
First, why do most of the industry's serious mishaps happen at night when we fly half as much in the dark? Why is pilot error so much more dangerous at night?
There's no scientific physiological consideration given to scheduling pilots for night duty in the industry. There's no consideration for circadian rhythm or effective sleep's importance to efficient rest. The result is that sleep deficit, poor sleep quality and circadian disruption, which all have adverse effects on mental efficiency are all ignored as potential contributory issues to poor pilot decision making. Part 135 minimum mandate "10 hours of uninterrupted rest" as a standard is clearly inadequate in light of these known issues.
It seems that the most common rotation schedules are 7 days, 7 off, 7 nights, 7 off and a variation of 7&7 where the scheduled duty pilot works "X" 12 hour day schedules, takes a 24 hour interval, and works "Y" nights.
The first schedule, straight 7 successive night duty periods is unsatisfactory for a substantial part of the population that lack facilities dark and quiet enough to get a "good nights sleep" without interruption. These pilots accumulate the bad effects as the duty period progresses, becoming less and less efficient.
The second schedule, with a 24 hour interval to adjust to night duty, starts the pilot fatigued and in the middle of the duty schedule, and allows inadequate time to flip the circadian clock completely. Most pilots on this schedule start night duty tired and then disrupt their circadian cycle, resulting in poor sleep (and poor tinking when awake) accumulating a sleep deficit and sleep poorly until their body clocks adjust- and then cycle off to normal diurnal existence. The only arguable operational benefit of this schedule is that the night duty period is brief, 3 or 4 nights. And it fits a calendar handily, in my opinion an esoteric variation of "get home-itis": I really really want it to be this way because it's easier...
There's no point in mentioning the pilots I know who are invulnerable and believe that they can go all day and all night. Or those who show up making statements like I really need to sleep tonight...
I've never had an operator acknowledge that these problems exist, up to and including Uncle Sam. Machismo and invulnerability is apparently acceptable in this one regard, "Real men (pilots) just do it" even though physiological science seems otherwise.

Night operations should not be viewed as the same as day operations with less light, because they are not. First,what you see and how you see is different at night. You have to learn to see differently and in a world without color, or learn to use aided vision, which entails unique issues. The weather is also subtly different at night in most areas, with much less convective effect bad weather becomes worse weather due to stratification.

Having more capable equipment- autopilots and real IFR capability, for instance- often only complicates the decision process, especially problematic with night scheduling issues. Add that people tend to complacency in familiar scenarios, and one might be inappropriately counting on "George" or a pop-up IFR saving your bacon when a better call would be to decline a request based on intelligent assessment of existing conditions, or abort enroute.

The current vogue for corporate operational control regimes and risk assessment tools don't begin to address the scheduling issue. The answer is having brief night duty schedules, started with a well rested pilot, and either effective self assessment or encourage pilots to make the "knock it off call" when there is any doubt.

topendtorque 5th Jan 2012 20:52


Not sure how the old mindset of "let's always struggle VFR" could be cured, though.
That statement cuts to the quick a definition of the real problem.

Maybe some rule changing that people are not going to like will be needed wrt to VMC.

Now you have a visual range up to the pilots interpretation, perhaps that range should be extended but instead prescribe conditions that will allow that visual range I.E. I know in a quarter moon I can easy see that far. Right, new VMC rules. Flights during less than 1/4 moon must be filed IFR.

same same for fog, cloud etc, why not have a required differential on your forecast dewpoint temperature to be filed on a flight plan prior to flight along with ambient temperature. Then if in breach of the differential, the insurance or risk of being exposed to no insurance esp. third party, becomes the controller.

At the end of the day night is as clear as being hurt right where it counts, in the pocket. Any system that is self driven is much cheaper and usually far more effective.

ShyTorque 5th Jan 2012 21:04

SASless,


We can disagree without being disagreeable can we not?
If you poke a grouchy ol' bear with a stick....they sometimes bark a bit you know.
Yes, of course we can. But, as I said before, the problem comes when the bear wakes up unprovoked and tries to bite all passers by.

In some cases you might just end up with a grouchy ol' bear on each end of the stick.... :E

I know we're singing off the same hymn sheet but not necessarily always quite in tune... ;)

ShyTorque 5th Jan 2012 21:59

TeT,

Good start, but you'll be aware that the moon phase alone doesn't determine the actual usable light levels. Cloud, atmospheric pollution, cultural lighting etc all play a part too. Sometimes a flight can be made with no moon but purely on cultural lighting (UK Police have this option written into their "Visual Contact Flight" night rules, it's the pilot's own go/no-go decision).

As a point of interest, in UK, "filing IFR" wouldn't make a difference. Because there is no night VFR. The rules here state in essence that outside of CAS, at 3,000ft or below, IFR are deemed to be met if sufficient visual cues are available to carry on safely. Essentially the same as if the flight was flown under "Special VFR" rules in a control Zone, although the term is avoided in this context.

Obviously, the problem is how to know if sufficient visual cues will be maintained along the whole route.

Having the ability to abort "Night VFR" and pull up to MSA in a properly equipped IFR aircraft is surely safer than not. The worst case is having to "suck it and see" in marginal conditions, in a non-IFR compliant aircraft then fly into reduced visual cues, with no easy get out. If NVGs are in use, and they lose effectiveness due to reduced available light levels or IMC, this is when even highly skilled/experienced pilots can lose it and buy the farm. Night disorientation is very easily found in an unstabilised aircraft. This is why we (RAF SH) fought hard to get the night cloud and vis limits correct. The limits for NVG ops had to also allow "unaided flight".

Thankfully, in UK at least, there is nothing to prevent a properly equipped and trained helicopter pilot alternating between the "Visual Cue by night IFR" (my term) and the "Full IFR" as he sees fit. As long as he can obtain visual cues before he descends below 1,000 feet above the highest obstacle within 5nm of the aircraft, it remains legal and safe. Obviously, provided accurate situational awareness is maintained.

These days, in my small part of aviation, this essentially is how I operate much of the time by night. Sometimes a SVFR departure can be made, followed by an IMC transit, then an ILS to an airfield requiring a bit of a drive for the passengers. Obviously, the icing level may prevent an IMC climb to MSA and that is when finer judgement is needed. Sometimes a "no-go" decision will be made on the ground. Sometimes, that decision will prove in retrospect to have been over-cautious and leave me open to criticism (and it has), but as we all know, it's so much safer than the ultimate penalty paid for being under cautious...

Here it isn't a requirement to file a written flight plan for IFR provided I remain clear of Class A airspace. Special VFR entry to any control zone can be requested on the radio. No guarantees, but procedures are in place to allow it, day or night.

Aerobot 6th Jan 2012 01:34

I like to provide an alternate point of view. This is not just to be disagreeable, but if someone else is saying what I would, why bother to post?

That said as preface, I tend to get a bit edgy when the proposed solutions seem to built of silicon chips and rules. Furthermore, I'm a civilian and though it doesn't get as much airplay in these days of Call of Duty III, I think there is a great heritage of civilian aviation that doesn't have to give up the podium to anybody. I became acquainted with that heritage through my father, who was there when Mr. Hughes looked over a table of schematics, finally pointed his finger at a place on the airplane that nobody else was looking at and said, "Fire that man."

Enough digression. As I say, I resist solutions made of computers and regulations. I believe that the answer to the problem lies with the pilot, and the pilot alone.

I ask you: when you read these reports and try to figure out what happened do you, as I do, try to imagine how much time elapsed betwen the time the metal bent and the time the pilot suspected that he was where he shouldn't be, doing what he shouldn't? How far did the pilot go beyond the chicken-out point? Maybe the chicken-out point was on the ground...

Give him a Bell 47 with wooden blades, or give him an autopilot that could solo the Starship Enterprise, you haven't made him safer unless he knows that it's his helicopter and that he is under absolutely no pressure to fly it longer than he feels is safe. Train him in the EP's, sure, but make sure you train him in how to quit a flight at the first moment that his personal risk needle swings into the red.

Retrain or remove any person or thing in his entire life that puts any pressure on him to "just try it a little farther." Until you have done that you haven't done enough, and you certainly haven't done the single best, cheapest, thing you could have to make sure they all go home.

ShyTorque 6th Jan 2012 07:54

Aerobot, Do you really think your proposition is realistic? :D

Get rid of rules and technology and concentrate on the pilots? When all existing pilots are sacked, because they don't comply, who will train this new "breed" of aviators who chicken out at the first sign of any risk? How will the "personal risk" meters be calibrated?

Go back to the Bell 47? How many patients and medical staff will fit in one of those, in addition to the pilot? How much fuel can it carry?

You will, of course, be financing this venture yourself.. Because no-one else will.

SASless 6th Jan 2012 12:56

Dang Shy....you are sneaking onto my turf again!

ABot just said in a slightly different way what I said in reponse to JimL when he talked of "improving aircraft stability" and I suggested even if I had another pilot, a three/four axis autopilot and all the neat kit....I would still be very uncomfortable doing the VFR IFR Night thing you guys do....in marginal weather.

Abot did not suggest one should use a Bell 47 for EMS work....but said given the Bell 47 or....operative word he used was "or" ... a sophisticated IFR Twin...the Pilot(s) were a key common element.

I agree with what he had to say....as we have seen repeatedly, in crash after crash, pilot decision making/judgement is probably the leading factor in those events.

That ties in with my view that until we can improve the Helicopter IFR enroute structure to facilitate actual IFR flying and thus eliminate the VFR IFR Night (or Scud Running in daylight) with its inherent risks of IIMC, CFIT, LOC in IMC following IIMC.....we shall continue to have the problems we do.

Aerobot 6th Jan 2012 13:18

Congratulations, Shy. I have never had anything I've posted be so amazingly misunderstood. I'd explain it, but I see that SAS gets it so I don't have to.

Thanks, SAS. I had a bad moment there while I wondered if I'd really said some bonehead thing. I meant something along the lines of "safety equipment is nice, but concentrate on pilot's judgment." Nice to see I got that message across.

[email protected] 6th Jan 2012 13:22


It's well and good to propose new bigger more capable machines, but where does the dough come from? I suspect the IFR, two pilot twin with all available bells and whistles was only Sasless thinking out loud.
Change the way EMS is funded in the US.

Try the UK model of charity funding with Medicare paying a certain amount as well into the coffers. Enough is raised in UK to support HEMS and AA and all provide twin-engine, IFR capable helicopters.

Complaining that Medicare only pay a certain amount per flight and that dictates the spec of the aircraft just ignores what needs to be changed in order to improve the safety of HEMS in the US - remove the bottom line so operators don't have to cut corners and provide the minimum spec aircraft and allow new blood into the business.

Devil 49 6th Jan 2012 13:58

Aerobot-
Amen, Brother! And "hallelujah" somebody else sees the forest...

Jack Carson 6th Jan 2012 14:01

Big $s vs Good Judgment
 
Changing the funding model will do little to effect the results if we don’t have a system ultimately driven by prudent PIC decisions. The Maryland AS-365 mishap provides an example of this. Maryland’s HEMS program is fully funded as part of the cost of every driver license fee. As such Maryland operates SPIFR AS-365 helicopters. However, being a state government organization they were not obligated to operate under FAR- Part 135 but rather under Part 91 allowing for VFR flight operations at significantly lower weather conditions than required by their commercial counter parts. There has to be a point where good judgment trumps rules, regulations and minimum equipment requirements.

rotorspeed 6th Jan 2012 14:27

Just caught up with this interesting thread!

Jack Carson; pleased you agree we’re closing in a sensible proposal and interesting ref AMC.

SASless; to deal with your main points in your post #188.


Rotorspeed.....if you do not like the answer...don't ask the question!
Well how exactly am I supposed to know your answer before I ask a question?! Of course I am pleased to read alternative views – that’s how we learn.


You pointedly asked for my input....you got it....deal with it!
I did indeed deal with it, in my post. But you got tetchy, because I was objective and criticised elements your reply. Quite validly I maintain, and I suspect a few others might have agreed with me.


Does your Helicopter EMS experience equate to the time you spent doing that research by any chance?
My HEMS experience is zero. But I have considerable helo flying experience including at night and in poor weather, VMC and IMC. I also have considerable experience running a business, so understand commercial realities, and matters of safety and medical care. So I feel qualified to contribute to this subject, as well as welcoming input from those with direct HEMS experience.


Some slight problems with your thinking on "Singles".....you have any concept of the impact of putting two pilots in a 206L, 407, 350 helicopter has on the ability to carry a patient? If you do...you would not have suggested that at all.
No, I hadn’t considered where a second pilot might go in a 206/AS350. Good point, though one made, typically, somewhat sneeringly by you, but constructively and sensibly by ShyTorque, whose posts I have great respect for, dealing knowledgeably, intelligently and pertinently with issues.

It doesn’t really matter though, as in that case the alternative of having an autopilot would be required. Regardless of space, my own view would anyway be that in a single (and light twin) a good autopilot would be preferable, given a balance of payload, cost and safety.


Your equipment list sounds very much like that I proposed as my personal preference....are you poaching from my list?
What a telling remark! This is not about “poaching” from anyone’s list, but about using any information anyone proposes that contributes to the debate and adds to our Pprune consensus (should we ever get that far!) on a regulation way forward. It would be a great testimony to the expertise amongst Pprune if we could prove to lead the way here. Might even influence regulators worldwide – you never know! Where is there a better forum for getting input from a broad range of mainly sensible opinions and constructively debating to a valid conclusion?


Do you assume there is insufficient data on record to be able to make a decision re Engine Failure rates for the various single engine helicopters used for EMS operations currently? Why do we need you "phase" concept.
No I don’t. You’re probably right – there maybe sufficient info on failure rates now. But I was more thinking that maybe C20s on 206s might not be as good as AS350 Arriels or 407 250 C-47s, and allowing the opportunity to phase out 206s if they are deemed not reliable enough for effectively SE IFR long term. Perhaps you could tell us what failure rates each of these engines have then and propose a suitable minimum failure rate for SE IFR?

The main point is that I believe this forum should provide a platform for opinion, objective robust debate and information. Sometimes SASless I feel you come over as if you were holding court in your own bar, expecting everyone to bow to your superior experience and wisdom. You can shy away from responding succinctly to questions raised, yet get defensive, affronted and haughty with those who take you to task. Be nice if you could be more objective and have a bit more respect for the many intelligent, reasoned comments others post.

Having said that, I’d love to be in bar and listen to your views and stories – I’m sure they’d be fascinating! And I agree with 170 – you certainly make a great contribution to Pprune.

And finally Crab's last para is right, HEMS businesses, whether Europe or US, should be ones that are primarily run to sensible operating procedures and regulations, not according to what payments are offered. If it can’t afford to be done safely enough it shouldn’t be done at all. Evolution should be on a sensible timescale though.

Agree with your theory, Aerobot and Devil 49, but better training could/should have been in place for years and accident rates are still unacceptable. So it seems it alone cannot be replied upon. Regulation change, including that referred to by Jack Carson ref Part 91, needs to come too.


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