NTSB says EMS accident rate is too high
 

Does that mean if you crash your EMS helicopter there may be a chance that it was not 'needless'?
Hard to show how you can crash and the crash be needed?
Sigh.

But in a more serious vein - they're right. Some of these crashes do raise the question of 'what are we trying to do?' and are we always doing it in a seriously professional way?

Shawn

... "what are we trying to do" ...

Seriously, that has to be the ground zero question HEMS needs answered!

WIII

They should read Pprune. They would have found out ages ago. :ugh:

I cannot agree more with the idea that the accident rate is TOO HIGH.
However on the article mentioned above they make too much enphasis on the use of NVG while we all know that the main cause of accidents in EMS either night or day is unintended flight into IMC conditions.

I believe that all pilost flying by night must have a current IFR ticket and if possible all HEMS ops during night time should be made with 2 pilots so if you encounter IMC condiions one of them that should be focusing on instruments all the flight should take control of the aircraft and inmediately gain altitude above the MSA of the area.

Helicopters for such operations must be fully IFR and must be adequately equiped with appropiate technology to lower the workload imposed on a HEMS crew flying by night and that encounters inadverted IMC conditions.

Operators must train regularly their crew to face the nightmare posibility of encountering IMC conditions by night at low leve and must make sure all crews are trained to transition safely into IFR.

Of course this also implies properly trained dispatchers that know what icing conditions are so no night flights are performed if marginal weather conditions are present along a low freezing level.


NVG are a very big help but will not navigate IFR through the clouds. They are better for obstacle avoidance and for take off and landing operations.
However the only way to avoid the too common accident involving inadverted IMC is a proper and safe transition to IFR.

Go - No Go
 

Would the ability to say "No." be the hardest thing in aviation?:sad:
I'm not an EMS pilot, but whether it is charter ops or EMS or airwork, saying "No, I'm not doing that." is the hardest thing, but it should happen.
I think it gets even harder when you fly all the way there and have a look and then make the decision, no it's not safe, time to go home.
We as pilots need to know that the boss/bean counters will support us when we are in the air and change our minds based on what we see, or can't see as the case may be.
It doesn't matter what the task is, we should be confident that the boss will respect our decisions. :ok:

The last time I felt safe saying "no" was when someone else booked a photo job for our R22. I turn up at the end of a 40 min ferry flight to find the photographer is 130 kilos! :mad: I said "No" and they had to find another photographer PDQ. They were told about weight issues and would still have had to pay for that ferry, but how often are we afraid to say "No."?:oh: And push on to get the job done.
All the best gear in the world will not overcome the fact we need to train management (and the client) that some times, some jobs are not going to happen.
And that's okay.

It is not correct to imply that nothing is being done.

Before effective action can be taken, it is first necessary to establish the root causes of the accidents. Once the causes have been established (and it is not as simple as it first appears), they can be addressed.

As will be seen, the causes will be many and varied; there will be clusters and trends, and this is where systematic measures will have the best chance of success (single accident mitigation achieves only a 'sticking-plaster'/'band-aid' effect).

Here is an extract from the latest IHST Newsletter:

http://ihst.org/images/stories/docum...wsletter-3.pdf

The OSI-HEMS Team
By Ira Blumen
“Opportunities for Safety Improvement in Helicopter EMS”

(OSI-HEMS) is a research project that has brought together aviation and medical experts to undertake the most comprehensive review of U.S. HEMS accidents to date. A root cause analysis is being conducted on an estimated 120 HEMS accidents dating back to 1998. Through this research and analysis, concrete recommendations will be made to compare the potential benefits, cost, effectiveness and feasibility of various factors that can prevent HEMS accidents or reduce the impact of accidents.

Key to the experimental design and analysis of our data (the HEMS accidents) is the scope, strength and experience of the research team that has come together. Bringing together such a team was one of the goals established by theoriginal core group that set out to develop this project. It was concluded that the best way to attract the support, knowledge and expertise that we needed to undertake and complete this research was to invite participation from throughout the air medical community. Air medical associations, aviation operators and manufactures were approached and the response was overwhelming. Our research team has now expanded to over 40 aviation and air medical professionals, with an average of 25 individuals present at each meeting. Our team currently represents:

Associations
- Air & Surface Transport Nurses Assoc (ASTNA)
- Air Medical Physician Assoc (AMPA)
- Air Medical Safety Advisory Committee (AMSAC)
- American Assoc for Respiratory Care (AARC)
- Assoc of Air Medical Services (AAMS)
- Commission on Accreditation of Medical Transport Services (CAMTS)
- Helicopter Assoc International (HAI)
- International Assoc of Flight Paramedics (IAFP)
- National Assoc of Air Medical Communication Specialists (NAACS)
- National EMS Pilots Assoc (NEMSPA)

Helicopter operators (currently 10 different 135 certificate holders)
- Air Evac Lifeteam
- Air Methods Corporation
- CareFlite (Dallas/Fort Worth)
- EraMed
- Intermountain Life Flight
- Med-Trans Corporation
- Metro Aviation
- Omniflight Helicopter, Inc
- PHI Air Medical
- REACH

Manufacturers
- Bell Helicopter
- American Eurocopter
- Turbomeca USA
-Federal Aviation Administration Aviation training
- FlightSafety International Aviation insurance- AirSure Limited

Members of the research group first met in early 2007 and the first “working” team meeting took place in January 2008. We anticipate continuing our work through the summer of 2009.

Editors note: due to recent events in the HEMS community, the IHST will be working with Dr. Ira Blumen, a well known HEMS accident analyst. His team is using a process similar to that developed by the US JHSAT team. The IHST plans to use the recommendations developed by Ira's team to form a HEMS specific implementation team late in 2009.

Jim

Yes, too many accidents in US EMS. Would somebody please post a US EMS accident rate? I suspect there is no sound statistical means to assess our accident rate, and I'm convinced that were there such it would be heavy on pilot error.
It's not a single/twin issue, you don't have to go very far into the history to see twins involved.
It's not a VFR/IFR issue, see previous.
It is a day/night issue- NVGs and scheduling.
It's a training issue, night training especially.
It's a managerial issue: all give safety lip-service, but often fail when the almighty dollar becomes an issue.
It's a regulatory issue. EMS is not just 'unscheduled fly-for-hire', and that is obvious to everybody flying the line. There are industry specific Parts for Ag and External work- EMS needs one too.
Finally- I'm coming around to the conviction that this is a single-pilot issue above all else. Pilots who can do this well by themselves are a minority and the safety advantages of a 2-pilot crew are inarguable.

Now whole case seems much better. Hopefully, and I am sure that OSI-HEMS team take care of this with good results. Good thing is that all parties are involved. Wishing them all best.:ok:

Mean while, fly safely out there.

Hostile

Devil 49 et.al.
Agree that there should be a separate part for the industry. I have a sneaky feeling in the gut that if somebody with a super computer were instantly able to compare Part 135 Fixed Wing ops.(Freight, Charter,etc.) with Fixed Wing EMS ops. the crashes in the latter would exceed those in the former.
Maybe it is just an EMS issue-----.
Alt3.

NTSB should insist on more experience and training for US EMS operators and crew to help stop these needless accidents

NTSB can't insist - my understanding is their role is the same as that of our own AAIB in that they investigate, make findings and can make safety recommendations.

Only the FAA can regulate but, if the point you're trying to make is that the act needs cleaning up, then if the industry gets in there first with a proper "code of conduct" including equipment, training and flight decision criteria - which overrides commercial interest, then they're ahead of the game. However, the words "commercial interest" are the killer :)

How about raising the night VFR min and doing away with the "competition" model for ems work

I think everyone here has identified a bit of the solution. The difficult part is implementing it in an environment that's governed almost solely by profit. On the one hand we want to make transport by HEMS safer, while on the other, we are reluctant to regulate someone out of business.

There are business models that work well in terms of profit, and there are those that work well in terms of safety. Occasionally, they are found in the same operation. But by the same token, the absence of accidents does not necessarily imply the presence of safety.

For years we've attempted to solve the problem with incremental measures, focusing on the proximate cause of the latest accident. It's time to look at broader solutions from a "systems" perspective.

Starting from the top:

1. How do we determine that a program is necessary in the first place? Will the community really be better served or is this just a business opportunity? Perhaps the "certificate of need" process needs to be more realistic.

2. How do we fund the service? Does the call volume directly affect the program's survivability? Is there pressure (real or perceived) to keep the "numbers" up?

3. Are the aircraft and crews equipped and trained to be able to surmount the challenges of the operating environment right up to the point of clearly defined mission abort criteria? Once a mission reaches an abort criterion is there a safe alternative?

4. Is the program staffed sufficiently and scheduled properly so as to prevent fatigue-related deficiencies in performance and judgement?

For years we've left it to the operators to make these decisions. Isn't it funny how they can always find a way to justify their operation, in spite of common sense. I think increased government regulation in these areas is the only measure that will ultimately produce an improvement in the the safety record of the HEMS industry.

-Stan-

model time regime fatal cause
bell 206 day departure 3 wire ?.
bell 407 day approach 4 mid air
bell 407 day approach 3 mid air
bell 407 night en route 4 cfit ?
ec 135 night en route 3 cfit ?
as 350 night approach 3 water
bk 117 day en route 4 water
bell 206 night at scene 3 mech failure
27

others in same period 32

From NTSB site total Helicopter incidents year ending oct 11.
26 occurances , 8 EMS .

If you filter out turbine accidents only 8 of 11 turbine fatal accidents were EMS. And 100% of twin.

Aviation Query Results Page

Lot of good replies.

As to root cause analysis that is something that should have been ongoing such that we don't have years of delay while a few folks fiddle with stats to come up with some sort of conclusion/s, which may or may not have any implementable elements.

My frustration is that Common Sense has taken a back seat to what can be done right now - such as requiring all EMS pilots to at least gain and maintain 135.297 IFR status, irrespective of the helicopter they fly, so they might have the confidence to climb in to the weather when required in order to avoid dangerous CFIT situations.

So are we saying that the problem is systemic, that the interests of safety have been overridden by commercial concerns for too long, and that the HEMS industry remains too governed by profit?

Are some HEMS programmes really established more to generate profit than to serve a real need in the community?

Do funding arrangements rely too heavily on call volumes, putting too much emphasis on operators to ‘keep the numbers up’, and on pilots to press on (perhaps into deteriorating conditions) and to avoid mission aborts?

Is there sufficient incentive for operators to train crews to the best possible standard, to acquire the most suitable aircraft, and to equip them properly?

Are the HEMS programmes adequately resourced to ensure proper engineering, and to avoid the inevitable penalties that arise when crews are over-worked, over-stretched or simply tired?

Yes, I think systemic failure is an accurate assessment of fault.

Starting at the top of the ladder, the FAA believes that EMS is just another helicopter charter. It isn't. To get the helicopter EMS job you have to have significant night experience, which most Part 135 operations avoid. Example- In 13 years in the Gulf of Mexico, I did 2 night flights as a VFR pilot, and the company tried to avoid those two flights. Night flight just isn't commonplace air taxi operation, not to mention 24/7 operations.
Often, air taxi's allowed to "take a look" and/or land short of destination. That was a mixed blessing, in that I learned weather very well as an air taxi pilot by flying into it at minimums well below my present weather minimums. Most EMS operations want to be reasonably certain of getting the patient to the receiving hospital, so "taking a look" doesn't happen.
On the subject of nights and regulations, it's stupid to pretend that "10 hours of uninterrupted rest" adequately addresses the pilot's condition going from a day assignment to a night shift. Yet, it's not uncommon (and perfectly legal) for a pilot to work a day shift, sign out at 2000 hours, take 24 hours off, and sign in the next night at 2000 hours. That's a major sleep and circadian disruption, it's well known that that affects mentation- and it's not addressed in training, policy or regulation.

EMS companies generally don't exceed the letter of the law. They act in the real world of 'profit equals existence'. If you don't make money, you don't exist for very long. The industry does pretty well within those limits, with these exceptions:
Scheduling, scheduling, scheduling!;
NVGs are decades over-due;
And training is done on the cheap and treated as a necessary evil, mandated by government. The training department can be a major asset in driving quality and safety, but not when it's scattershot by a very few overworked pilots, and especially not when done by 'management' types intent on enforcing the 'book' and all it's failings.

Pilots aren't blameless in any of this.

As stated above, the NTSB has no regulatory power of any kind. They just investigate accidents and make recommendations, which the rest of the world is free to ignore, and generally does.

The FAA has been very reluctant to regulate operators - see the Eclipse soap opera, detailed in the current issue of AIN. HEMS in the US is a commercial operation, and few officials are ready to use socialist-seeming regulation to force anything on the operators. In the US, anyone with some capital is free to try to make more by any legal, or even illegal, means, and if someone gets hurt or killed, that's regrettable, but just part of the cost of doing business. I don't expect much regulation in the short term, and perhaps more deregulation, especially if the Republicans can maintain their current Congressional seats and McCain can manage to win. McCain has historically been hell-bent on deregulation, especially for the industries he's been paid to help. A little bribery goes a long way with politicians, and it's totally legal in the US, as long as you call it a campaign donation.

If the Democrats win big, there might be some tightening of the rules, but I don't foresee all that much, because they can be bought just like any other politicians, and we have the best government money can buy.

I don't think the crew rest issue mentioned above has much to do with it.

I do think NVGs would help, I sure as hell am not comfortable flying without them at night to an unimproved LZ.

But if the presumption that inadvertent IMC is the real killer, I think flying dual pilot would probably be the most expediant "fix."

Why am I so inclined to buy that answer? Well everyone I fly with is fully instrument capable, the aircraft I fly is a very good IFR platform, and I still cringe at having to fly in the weather. I don't do it very often, and I imagine most helo drivers don't do it very often, even when rated to do so. I'm ok with having to do it, mainly because if I'm the pilot on the controls, I can focus on just flying, while the non-flying pilot does all the "thinking."

Good thoughts Devil 49,

I was thinking about same. EMS operation should separate from other operations and it needs own SOP. It has so much differences. Night flying is different world and especially with (hopefully) NVG's. Like its been told many times, NVG's are not X-rays. You still need to have approved and good weather limits. Also crew coordinator should be included in that SOP. If operated in one pilot, somebody else must use radios between accident scene/other rescue crews. No pilot. There are many other things also, but main thing is that all is published.:rolleyes:

So what's the point of SPIFR machines?

I don't doubt you, chaps, but would welcome an explanation.

SPIFR is as demanding as any flying there is. It requires constant practice in order to be reasonably proficient, and the constant practice isn't possible in EMS, where there is relatively little flying at all. SPIFR machines are mostly for recovering from inadvertent IMC, but that's where the most proficiency is required, and where lack of it will kill you. In short, SPIFR machines are for eyewash, just a marketing tool. Many programs with SPIFR capable ships are prohibited from filing IFR. There is actually a point of view that they're more dangerous than less capable machines, because they may tempt pilots into flying in worse weather. With a 206, you know without question that you don't want to fly into weather. I'm not sure that I subscribe to that view, but it seems that some do.

Just for clarification:

I hope you don't mind, Gomer. I didn't want Jack' getting the wrong idea about SPIFR aircraft in general.

Thanks for the explanation/clatification, BOTH of you.

I'm not sure I agree with everything Gomer Pylot said.

SPIFR is demanding but I don't think it's eyewash, it expands our capabilities and increases safety. I fly a SPIFR ship in EMS and I've found it to be a great tool and a safety enhancement. By virtue of the the fact that we must take a 135.297 ride every six months with study and recurrent flight training added on, I believe we are more prepared to deal with IIMC than a VFR pilot.

I don't launch VFR in marginal weather, I'll file IFR and if our customer doesn't want to wait a little longer while I file and maybe meet us at the closest airport, they will find another mode of transportation.

If we encounter marignal VFR enroute, fly unaided at night, or can't see the ceiling, the auto pilot is a great tool. Let it fly, it has no idea whether it's in the clouds or not. If you have the misfortune of going IIMC the autopilot will not panic, you can command it to climb to MSA while you contact ATC for a clearance and vectors to VFR or an approach.

If the weather is deteriorating, you have the opportunity to get a clearance and climb to safety early instead of mucking around in the mud and going IIMC or CFIT.

I agree with whoever said that it was pilot error more than anything else. We must make good decisions, even when they are unpopular and may put our job in jeopardy. A company that won't accept a reasonable, safe decision isn't worth dying for, I'll move on.

Devil 49,
I think we work for the same company and thankfully haven't had the same training experiences you've had. Maybe the difference is CBM vs HBM?

V/R

430, SPIFR can enhance safety, if used wisely. One checkride every 6 months isn't nearly enough to keep anyone proficient, each pilot has to be determined to practice at every opportunity. Since many programs prohibit actual IFR, that can be hard, and if pilots are prohibited from filing IFR, then the SPIFR machine is indeed eyewash. Whether it is safer depends on the pilot. If the pilot stays in practice and doesn't push weather, then safety can be increased, but if the pilot pushes weather, then the opposite can result. VFR only pilots, in VFR only machines, don't have IFR to fall back on and should be more conservative, and stay out of dangerous weather. I suspect the actual situation is a mixture of all the above, and more. IMO safety depends mostly on the pilot's ability to stay immune to perceived pressure from the crew and management to take flights (whether it exists or not) and from his own instinct to go out and try to save lives. In truth, we seldom save lives, but do often reduce morbidity. In no case is it worth risking our own lives or those of the crew in the back. Ground ambulances still work.

Would better safety tend to mean the use of the more modern twins (capable of meeting Class 1 at normal weights) for HEMS, rather than ageing 206s?

The only thing stopping a recapitalisation based around bigger, better-equipped helicopters is money, right, and the FAA's unwillingness to upset commercial operators by insisting on it?

Twins are welcome, absolutely. But, using Class 1 is more complicating. It's because all aircraft has different kind of approval how to meet all Class 1 parameters. Some parameters just doesn't fit in HEMS-operations. Better start talking Class 2, if this will be the issue.

It is unlikely that any HEMS operation will be capable of PC1 at the HEMS Operating Site (scene).

All Category A procedures require the surface, size and obstacle environment to be established by survey; PC1 requires that all obstacles be cleared OEI by 35ft -for approach, balked landing, take-off and continued take-off. It is obvious that this is not possible at the HEMS Operating Site.

'Hostile' is absolutely correct that PC2 is the best that can be achieved.

Jim

Twins are absolutely not the answer. First, take a look at the recent accidents, and you'll see multis at least proportionally represented. If that's not convincing, there are statistics that seem to demonstrate that light twins have a marginal if any safety advantage over singles (look for the OGP(?) published stuff on this, for instance). There's lots of qualifiers intentionally included in that sentence, and it contradicts intuition. My opinion as to why: The extra systems are extra management load in the best of times; When something goes wrong, systems management can become a distractor from your main job- flying the aircraft and NOT CRASHING into something (This one is very well documented, fixed and rotary wing); Finally, and the discussion itself strengthens my last point, what I call "twin engine invulnerability", is very wide spread. I've seen lots of guys fly twins into an unsurvivable engine failure situation because they have "two engines".

430EMSpilot-
I hope it isn't a 'class issue', HBM vs. CBM. I see a conflict of interest in that training are required to be management and not 'craft/trade/profession' oriented. The mindset shows in the application of redundant checklists. Identify and fix the root cause, not the symptom.

busdriver02-
We fly the same legs to the same places in the same weather and the same equipment, day and night. Yet, night is far more dangerous. My opinion-
Jet lag (circadian disruption) is a widely understood and accepted factor- By everybody but EMS?
There are also studies of mental efficiency with sleep loss, showing every hour after 3 hours being roughly equivalent to the standard alcoholic beverage. Again, doesn't apply to EMS?
Add that unaided human night vision can be as bad as 20/200 or 20/400...

Spoken like a real VFR EMS Astar Pilot Devil.:ugh:
I believe 430EMSPilot nailed it.

Even within the same corporate identity the separation between HBM and CBM services, and their continued comparation in the quarterly financial reports evidentiates the different mindset.
This is however a problem endemic to this company and one that does not apply per se to EMS operations, or perhaps does it?

I said it before and I'll repeat it.
Get the customer out of the cockpit, out of the cockpit decisions and out of OPERATIONAL decisions.

The problem is that in 'community based' programs the pilot is generally part of the customer and (specially these days) the completion of a certain number of flights may or may not mean the continued existance of a particular base (where he/she happens to live).
Also, since CB programs are notoriously for profit the need to cut expenses is far more evident than in a program where the customer is highly visible within the community and willing to avoid the bad publicity resulting from a crash.

So let's add yet another comparison parameter in this year accidents and establish the percentage of CB and HB crashes as compared to the respective program numbers.

I.e. what is the percentage of CB crashes vs the number of CB programs and HB crashes vs the number of HB programs?
How did THOSE crashes take place and what type of equipment was being flown.
One more suggestion, one I've made before:
Anyone establishing a "rural" pad for "community" service ought to be made responsible for establishing an FAA accepted WX reporting station (one of those Super AWOS comes to mind, about 75,000$) and within a set amount of time have approved GPS approaches to it; two things shall come out of that: virtually ensuring that program is not a fly by night (no pun intended) and the commitment to safety.
Not to mention the aircraft has to be IFR and NVG certificated and EQUIPPED for night operations, until there exists a will to enforce those conditions ya'll are an accident waiting to happen and a statistic on the drawing board.

Edited three times for content and spelling.:uhoh:

Gomer,

I agree, all things being equal no one should have a problem. As far as pushing weather, it would be interesting to me to compare SPIFR qualified pilots and aircraft vs SPVFR pilots and aircraft that go IIMC and fail to survive or CFIT.

Just off the top of my head I can think of maybe one that had a .297 current pilot and an IFR equipped aircraft.

Devil - I agree about the checklists, but my experience with the check airmen has only been positive.

Complexity is an issue with the twins, it amazes me when someone wrecks a perfectly good aircraft because of a small problem not requiring immediate action.

Totti - I love the rural equipment requirements!

tottigol- Ten years in twins, flew them every duty day. Quite comfortable in them, don't fool myself about the issues of having 2 engines, and in the right situation, prefer twins. This job (EMS) is not, generally speaking, that situation.
Also, at various times, IFR crew. I'm not arguing against the advantage of IFR or IFR equipment in EMS. I would love to have the options proficiency, currency, and equipment would give me on my next IIMC encounter. I'm saying those aircraft, twins and IFR equipped, are at least proportionally represented in EMS accidents- they're not the answer. The common element is human failure. The obvious physiological issues that would explain the increased rate of error in EMS night flying need to be addressed.

430EMSpilot- You bet, we have some top notch folks. I would dearly love to have them as pilots who teach, not managers who fly.

430 and Devil, I can think of at least two outstanding individuals who are part of the Certificate Standards folks.
One is an older (only by age) cavalry type from upstate NY and one is a (relatively) younger one from South Texas.
I only wish the rest were up to par.

Devil, we only know of the IFR twin(s) that crashed, but how many were able to get back home after encountering IIMC, just because they had the equipment and the training/mindset to use the equipment?
Climb, Confess, Check, Communicate.

How do you do that in a single pilot VFR only aircraft, do you rely on inconsistent training?

We mention twins because twins generally come with IFR equipment and an autopilot.
The day (or better, the night) we are able to come up with a single with enough HP and equipment to have a "panic/level-the-rotor and climb-go direct" button, and with enough useful load to carry a patient (we already have two passengers) and enough fuel beyond 10 miles, then I'll consider singles for night EMS work.
I don't know you guys, but I flew enough times from SLC to Price in Carbon County with a 206 @ night to age prematurely.

Devil, I did not mean to imply sleep deprivation is no big deal. Just that swapping from days to nights has not been a problem for me at this point in my career. I will offer that I only fly with two pilots, two scanners and NVGs. So the slight circadian disruption may be offset by the extras, that I'm still in my twenties probably helps quite a bit as well.

devil, I regret to disagree with several of your remarks on that post. Equipment and training matter, and amtter a lot.

When we are talking Twins I guess most of us have in mind that we are talking about having Perfomance I CAT A MTW helicopters. The kind of mchine that if properly operated would make the difference if you have one engine out.
Twins but CAT II are surely not the answer.

IFR currency (operational currency I would call it) should be a must for any HEMS pilot flying by night. And with special enphasis on procedures for inadverted entry into IMC conditions.

If you want SAFE HEMS by night, then think in CAT I perfomance helicopters fully IFR equiped, a crew of 2 fully qualified a current IFR pilots and an properly trained dispacher that knows how to read weather maps and know what icing conditions and its effect on helicopters are.
Then add NVG or a nice FLIR and then you will have a SAFER HEMS night program.

The above mentioned equipment and conditions would not guarantee a 100% accident free but it is the best we can have for now, provided of course that the operators/customers value more safety than profits.

Furia, by now you ought to have figured out that HEMS in the USA is nothing like HEMS in Europe.
Also, JAR OPS3 are not quite as permissive as the FARs when it comes to performance requirements for helicopters in determined types of use.
Come to think of it the FARs do not set any minimum standards for performance except for IFR in a twin.
That is why we still fly singles off-shore and singles at night in EMS and over congested areas.
PC1 here in the States is a huge scarecrow, and all operators are doing their darn best to stave away (read lubricating the FAA) the ghost of the JARs.
The lax attitude and tolerance demonstrated by the FAA towards HEMS is also why some programs still manage to fly VFR at night without the use of aids to vision notwithstanding rules set forth in 135.207.

It seems to me the key words, and the common thread in the recent spate of HEMS accidents are “pilot workload.” The majority of HEMS flights are conducted in conditions where the workload is easily manageable by a single pilot in a VFR-only machine. The economy of such operations is indisputable. The trouble can come when a situation arises for which that single pilot is not equipped or prepared, or the VFR-only machine is not capable. The workload can increase insidiously, and depending on the skill of the pilot, may exceed his abilities. At that point a successful conclusion to the flight may be solely a matter of luck.

Many HEMS operators in the U.S. base their operation on the premise that they simply won’t operate in situations where the workload is high. The unfortunate reality is that the line of demarcation is impossible to clearly define. Inevitably, someone will blunder across it, either through poor judgement or due to inadequacies in the information available for making their decision. Most of the time it results in no more than a bit of a scare and a good “there I was” story for the next safety meeting. The lesson is soon forgotten.

The major airlines conduct all their flights under instrument flight rules regardless of the actual conditions. Thus, when they do encounter weather it’s a “non-event.” Apparently, they’ve found that preparing for the worst pays off in a business sense – it allows them to run on schedule (much of the time) and it has contributed significantly to the low accident rate.

Not to compare HEMS with airline flying by any means, but the same philosophy of preparing for the worst would seem to make a lot of sense. If you want airline-like reliability in transporting medical patients it requires a higher level of equipment, training, and crew composition than the minimum the government currently mandates.

There are any number of fine aircraft and a variety of supplemental equipment available which could permit safe operation in all but the most severe conditions. The advantage of a second pilot is obvious. It all goes toward keeping the workload manageable all the time. The problem, of course, is that it’s expensive to go that route.

The solution to the disproportional accident rate doesn’t lie with a magic bullet – a piece of equipment, increased inadvertent IMC training, etc. It lies with a far-reaching change in operating philosophy. It lies with creating an environment predisposed to the successful completion of every flight that is accepted.

So, the question is, are we ready to change the regulations to enable a “high-end” operator to compete in what has become a market driven, in most cases, solely by economics. Honestly, I think the answer is no. One has to look no further than the horrific accident rate of automobiles in this country. There are any number of simple and obvious measures that could be taken to reduce the carnage, but perish the thought of depriving someone (either by regulation or by making driving unaffordable) of what has become essentially their right to drive when, where, and for however long they please.

-Stan-

It's easy enough for all of us to sit at our computers and come up with all sorts of requirements, but the fact is that the FAA is not going to regulate much, if any, of it. That's not the way things work here. Requiring ASOS for every base, and all IFR ships sounds nice, but it ain't gonna happen. Not in our lifetimes, and probably not in our grandchildrens' lifetimes. We live (or die) with what we get, and what we get is the minimum required by regulation, because the USA is a capitalist country, driven by profits, not safety or moral rectitude. Whether more regulation should be enacted is moot - it won't be.