NTSB Hearing on Most Wanted: Improve the Safety of EMS Flights
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The typical old solution for EMS accidents is to simply sit at home and tell the patient "tough beans, old chap." I guess the Canadians are better at that.
Seriously, the issue is not to derive safety by stopping operations, it is to make those operations safer while doing them. No?
Seriously, the issue is not to derive safety by stopping operations, it is to make those operations safer while doing them. No?
SASless, many of the European HEMS operators are already doing night outlandings, and have been for more than 20 years.
I think one of the strongest impediments to the low level IFR helo structure in the US is some of the current IFR laws - and weather requirments in particular. I dont know the ins and outs of the Euro system, but I will explain the differences that I believe may be impeding the spread of IFR by contractin the situation with Australia where the EMS norm is go IFR.
Take off weather forcast is generally required at popint of depaerture. Not in Oz. We can use weather foceats from nearby airfields as an indicative and use them to recover to. I am not talking IFR take off minima here.
Alternate aerodromes rule in the USA is overly complicated and restrictive. Simplified (I know it is a little more complex) you must be able to get to an alternate airfield AND hold 45 mins cruise fuel remaining when you get there. Good fixed wing rule, very poor helo rule especially with the introduction of help specific stuff. in our environment, we plan into one helo specific approach (our hospital) and the alternate due weather and aids is the major airport nearby. You just need to get there with fuel (not fly past it for 45 minutes at cruise burn). 45 minutes at cruise has the outcome of removing all light twins (read IFR cost effectiveness) from the job. Instead of EC135, A109, B230/430, and BK117 you will need B412/EC145/Dauphin. Big cost jump when you are trying to replace a LongRanger.
The fact that you are not supposed to even try an approach if it is reported below minima, even though the approach takes 10 plus mins some times, and the pilots are all trained to "go around". Several times in Oz we would patiently conduct a couple of approaches waiting to get legally visible.
Special Alternate Minima available for helos in Australia getting HAT(Hieght above threshold) right down which means major trauma centres like Sydney have a really good low wx minima that you can be relaxed and sure about to recover too if you cannot get into the hopital. A simple road transfer from the airport is all that is required. this impediment in the US system also goes with the higher DH for pilots not specially trained and experienced. Most SPIFR autopilots are good to go down to 50 ft above the runway and level off perfectly hands free. Why then are we resticted to 200ish ft HAT?
See Nick's dissertations on the low level WAAS/GPS autopilot coupled approaches which resulted in consistent hands off arrival decellarating through 40 KIAS and at 75ft above pad hieght with a consistency that meets all ceetification requirements.
There are some more "funnnies" that are untintentionally affecting the desired outcome of helos going to IFR. We need to start with the legislation to make it operationally attractive firstly! But it is, as we have argued many times, more than just a revamped infrastructure that will help the larger issues of "free market pressures".
I think one of the strongest impediments to the low level IFR helo structure in the US is some of the current IFR laws - and weather requirments in particular. I dont know the ins and outs of the Euro system, but I will explain the differences that I believe may be impeding the spread of IFR by contractin the situation with Australia where the EMS norm is go IFR.
Take off weather forcast is generally required at popint of depaerture. Not in Oz. We can use weather foceats from nearby airfields as an indicative and use them to recover to. I am not talking IFR take off minima here.
Alternate aerodromes rule in the USA is overly complicated and restrictive. Simplified (I know it is a little more complex) you must be able to get to an alternate airfield AND hold 45 mins cruise fuel remaining when you get there. Good fixed wing rule, very poor helo rule especially with the introduction of help specific stuff. in our environment, we plan into one helo specific approach (our hospital) and the alternate due weather and aids is the major airport nearby. You just need to get there with fuel (not fly past it for 45 minutes at cruise burn). 45 minutes at cruise has the outcome of removing all light twins (read IFR cost effectiveness) from the job. Instead of EC135, A109, B230/430, and BK117 you will need B412/EC145/Dauphin. Big cost jump when you are trying to replace a LongRanger.
The fact that you are not supposed to even try an approach if it is reported below minima, even though the approach takes 10 plus mins some times, and the pilots are all trained to "go around". Several times in Oz we would patiently conduct a couple of approaches waiting to get legally visible.
Special Alternate Minima available for helos in Australia getting HAT(Hieght above threshold) right down which means major trauma centres like Sydney have a really good low wx minima that you can be relaxed and sure about to recover too if you cannot get into the hopital. A simple road transfer from the airport is all that is required. this impediment in the US system also goes with the higher DH for pilots not specially trained and experienced. Most SPIFR autopilots are good to go down to 50 ft above the runway and level off perfectly hands free. Why then are we resticted to 200ish ft HAT?
See Nick's dissertations on the low level WAAS/GPS autopilot coupled approaches which resulted in consistent hands off arrival decellarating through 40 KIAS and at 75ft above pad hieght with a consistency that meets all ceetification requirements.
There are some more "funnnies" that are untintentionally affecting the desired outcome of helos going to IFR. We need to start with the legislation to make it operationally attractive firstly! But it is, as we have argued many times, more than just a revamped infrastructure that will help the larger issues of "free market pressures".
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Most SPIFR autopilots are good to go down to 50 ft above the runway and level off perfectly hands free. Why then are we resticted to 200ish ft HAT
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Ramen Noodles
Yes, the HAI Flight Ops Committee is a central spark point for the development of low altitude IFR infrastructure. Exactly 10 years ago that was the marching order given the new Chair to develop. I'm told it was a tough two year development but, in any case, the 'task master' was recruited because he was one of only, possibly, one in the world, who had the capability to create what has come of that committee and its quest to put low altitude IFR infrastructure products to market. One cannot imagine the arrows taken by some pioneers in this equation but at least that committee is a certified focal point as was envisioned.
Brian and helmet fire
The bottom line in EMS accidents is the pilot is the last line of defense. Either give the pilot in command all the tools, and support, to deal with the vagueries and contingencies of 24/7/365 any-point to any-point HEMS or perhaps we best not be in the business excepting the most favorable of overall circumstance.
In the Vietnam era US Army pilots (can't speak first-hand for the other services) generally came out of flight school with what was known as a Tactical Instrument Flying certificate - i.e., "stay out of the clouds because it will kill you, and use these skills if misfortune has struck - 'good luck and God speed to you' sort of thing", with no proviso to maintain currency or add to the skill/s during the subsequent year of operations in RVN.
Today, as with the RVN era pilots, the average US Army pilot coming from the service to HEMS has little or no actual IFR, and little night unaided time, but lots of what I call "crutch" flying with Night Vision Goggles. Some of these pilots, to include pilots from other services, could not pass an IFR flight check if they were trained for the next year, and some so concerned about flying at night unaided that they wash out of the industry, albeit the latter is quite few. The civilian pilots I have flown with and trained in this industry have little or no problem with night and no problem with IFR excepting proper orientation to what is required to handle IIMC.
The point to all this blather is that our military pipeline trains pilots to be dependent upon night vision goggles, and not the overall skills required to deal with all contingencies - the least proficient of which is IMC/IFR flying - inheriting these pilot's limited skill set/s is the single reason operators shy away from what they consider the complex art form SPIFR. It is complex, but not insurmountable, given the appropriate training and simple rules of the road in conducting those operations. Given a training regimen, and ongoing training regimen of simulator, hooded flight, and some actual IMC flight, over time most pilots get it down, and can pass a 135.297 check, and do quite well. It is the implementation schedule that has to be realized will be quick for some, and painfully slow for others.
With respect to support for the pilot there are so many entities with their fingers in the pie the general advice of "Lead, Follow, or Get Out of the Way", as well as "One is either part of the solution, or part of the problem - make sure it is the former in all speech and action" definitely applies. Think the solution is not this simple? Go follow a HEMS pilot for a day, and formulate your own opinion.
WIII
Yes, the HAI Flight Ops Committee is a central spark point for the development of low altitude IFR infrastructure. Exactly 10 years ago that was the marching order given the new Chair to develop. I'm told it was a tough two year development but, in any case, the 'task master' was recruited because he was one of only, possibly, one in the world, who had the capability to create what has come of that committee and its quest to put low altitude IFR infrastructure products to market. One cannot imagine the arrows taken by some pioneers in this equation but at least that committee is a certified focal point as was envisioned.
Brian and helmet fire
The bottom line in EMS accidents is the pilot is the last line of defense. Either give the pilot in command all the tools, and support, to deal with the vagueries and contingencies of 24/7/365 any-point to any-point HEMS or perhaps we best not be in the business excepting the most favorable of overall circumstance.
In the Vietnam era US Army pilots (can't speak first-hand for the other services) generally came out of flight school with what was known as a Tactical Instrument Flying certificate - i.e., "stay out of the clouds because it will kill you, and use these skills if misfortune has struck - 'good luck and God speed to you' sort of thing", with no proviso to maintain currency or add to the skill/s during the subsequent year of operations in RVN.
Today, as with the RVN era pilots, the average US Army pilot coming from the service to HEMS has little or no actual IFR, and little night unaided time, but lots of what I call "crutch" flying with Night Vision Goggles. Some of these pilots, to include pilots from other services, could not pass an IFR flight check if they were trained for the next year, and some so concerned about flying at night unaided that they wash out of the industry, albeit the latter is quite few. The civilian pilots I have flown with and trained in this industry have little or no problem with night and no problem with IFR excepting proper orientation to what is required to handle IIMC.
The point to all this blather is that our military pipeline trains pilots to be dependent upon night vision goggles, and not the overall skills required to deal with all contingencies - the least proficient of which is IMC/IFR flying - inheriting these pilot's limited skill set/s is the single reason operators shy away from what they consider the complex art form SPIFR. It is complex, but not insurmountable, given the appropriate training and simple rules of the road in conducting those operations. Given a training regimen, and ongoing training regimen of simulator, hooded flight, and some actual IMC flight, over time most pilots get it down, and can pass a 135.297 check, and do quite well. It is the implementation schedule that has to be realized will be quick for some, and painfully slow for others.
With respect to support for the pilot there are so many entities with their fingers in the pie the general advice of "Lead, Follow, or Get Out of the Way", as well as "One is either part of the solution, or part of the problem - make sure it is the former in all speech and action" definitely applies. Think the solution is not this simple? Go follow a HEMS pilot for a day, and formulate your own opinion.
WIII
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PHPA Response March 5, 2009
PROFESSIONAL HELICOPTER PILOTS ASSOCIATION INTERNATIONAL
Office and Professional Employees International Union
Recommendations on Helicopter Emergency Medical Services (HEMS) Operations pursuant to the NTSB Hearings of February 2009
March 5, 2009
The Professional Helicopter Pilots Association (PHPA) has a membership of over 4,000 helicopter pilots around the United States and Canada, over 1,300 of which are active HEMS pilots.
The members of PHPA are gratified that the issue of HEMS safety is receiving the acute attention from government agencies, industry, the media, and the public that it has long required. No stakeholders in this issue have more to gain (or lose) than do the men and women who fly these aircraft, and while we are certainly encouraged by the attention currently focused on our industry, we remain wary that talk will not be transformed into meaningful action.
We are all too aware that "pilot error" is cited as the cause in the majority of helicopter accidents, and recognize that "heal thyself" is often the call from those who look at this issue from outside the cockpit.
Were it so easy as to order pilots to stop crashing aircraft.
The International Helicopter Safety Team is putting a significant effort into reviewing accident reports in an effort to identify causal factors and develop recommendations based on hard statistical evidence. Unfortunately, most helicopters do not carry the type of recording devices available to investigators for large fixed wing aircraft. In the end, few investigations can determine with certainty why a qualified pilot flying a functional aircraft is involved in a CFIT accident, with the result being another "pilot error" statistic.
The members of PHPA are certain of this: pilots are more often victim than villain in this arena where good intentions are often not supported by good equipment, good training and good practices. Yet pilots have, for years, remained silent on these issues, conceding to operators who claim that the financial realities of the industry prohibit the adoption of the best equipment and training which for years has been required for our airline brethren. This silence has been born from the fear of losing a job that provides immense satisfaction as well as a source of income, and the absence of a structure such as PHPA from which we could voice our concerns as a group.
It is easy and perhaps correct to blame the pilot, operating a single engine aircraft at its maximum allowable weight, at night, with no vision enhancing system, no terrain warning system, no co-pilot or auto pilot, attempting to transition from the glare of lights at an accident scene to the pitch darkness of an overcast sky who hits wires or gets disoriented and plows back into the ground. Yet placing such blame does not make the next flight safer.
We all recognize that there is no cheap, easy fix to the issue of HEMS safety. Yet if this industry truly wants its operational safety to approach the level that has been achieved and sustained by the airlines, the model has only to be copied. Who in their right mind would subject themselves to an airline operation that resembled the above paragraph? Unfortunately, those being transported rarely have any input regarding the operator, or type of equipment that they or their family members are placed in, when being evacuated from an accident site.
It is our contention that relying on voluntary compliance for essential equipment and practices will only result in a continuation of the status quo, with perhaps a slight bias towards compliance accompanying the media glare of each "new" accident.
The recommendations below address both immediate requirements and long term goals. They represent the combined concerns of professional career pilots who simply want the tools to go along with the responsibility for insuring that every flight is brought to a safe and successful conclusion.
EQUIPMENT:
1. Night Vision Goggles or Night Vision Imaging System: Priority - Critical.
Recommendation - Require one of these systems to be onboard and functioning in each aircraft in the current HEMS fleet as quickly as equipment can be purchased, aircraft modified and crews trained. Restrict noncompliant aircraft to day-only flight beyond mandatory implementation date of 24 months.
2. Helicopter - Terrain Awareness and Warning System (H-TAWS): Priority - Critical.
Recommendation - Require installation in the current HEMS fleet within 36 months, with equipment based on the FAA's recently published TSO. Require on all HEMS aircraft purchased for replacement or expansion.
3. Wire-strike Protection System: Priority - Very Important.
Recommendation - Require installation in the current HEMS fleet where systems exist for individual models. Require on all HEMS aircraft purchased for replacement or expansion.
4. Color Moving Map GPS: Priority - Very Important.
Recommendation - Require installation in current HEMS fleet within 18 months.
5. Flight Data Recorder / HUMS: Priority - Very Important.
Recommendation - Require installation in current HEMS fleet within 48 months to include cockpit voice recorder and instrument monitoring through video (as a minimum) where full flight parameter monitoring on legacy aircraft is not practical. Data developed should be used pre-accident for recurrent training as part of a FOQA program.
6. Multi Engine: Priority - Very Important.
Probably no single issue generates more heated debate than that of the potential impact of multiple engines on safety. While we will not attempt to resolve that debate in this document, we will simply highlight several reasons for our position on the issue.
A large percentage of HEMS pilots come from the U.S. military. Practically all helicopters operated by the military today are twins. Therefore the majority of these pilots have no power-off experience or training beyond their initial qualification, and the minimal transition training required prior to their operating a single engine HEMS aircraft. Add to that the difficult environment in which these aircraft are being operated (over crowded cities, forested, mountainous, and other unimproved terrain, at night), and the results from a power failure in a single engine HEMS aircraft when the next one inevitably occurs, will likely be undesirable.
Beyond the obvious benefit of power plant and various subsystem redundancies, multi engine aircraft are larger, providing for separation of cabin and cockpit. This separation provides many important safety enhancing benefits such as:
a.) Preventing the various aspects of patient care from distracting the Pilot,
b.) Reducing or eliminating the potential for a combative patient to interfere with the Pilot or reach the aircraft's power or flight controls,
c.) Allowing for a second Pilot (either training, orienting, or acting as second in command) during patient transports.
Recommendation - Require replacement or expansion HEMS aircraft to meet ICAO Category A, Class 1 or 2 requirements.
7. IFR Certified Aircraft / Two Pilot Crews: Priority - Very Important.
PHPA takes the position that the standard for HEMS operations should be a multi engine, fully IFR certified helicopter crewed by two qualified pilots. That there are operations around the world that meet this standard argues against those who claim it is not feasible.
a. Two Pilot Crews: The safety value of two qualified pilots is undeniable. New HEMS pilots would have the opportunity to develop experience under the tutelage of a veteran pilot, and experienced pilots would have a trained and certified assistant to help manage the ever increasing tasks required to operate safely in the HEMS environment. While not a substitute for a second pilot, a functioning auto-pilot is essential to help reduce pilot workloads to manageable levels during task intensive phases of flight and to reduce fatigue on long distance transports.
Recommendation - Require an auto-pilot on all expansion or replacement aircraft, with current fleet modifications required within 48 months.
b. Full IFR Certification: Required to provide the pilot with the option to abandon the VFR environment before being faced with an inadvertent IMC emergency. Given a night flight with deteriorating weather, currently the pilot has to make the difficult choice between attempting a risky off field landing or declaring an emergency subsequent to entering IMC conditions. We believe that an IFR pilot should have the option of simply requesting a (non-emergent) IFR clearance and recovering to a well illuminated airfield. In addition, WAAS enabled GPS will soon provide the capability for ILS equivalent approaches to hospital helipads. The HEMS community will need IFR certified aircraft to take advantage of this and other rapidly developing technology that will continue to enhance the safety of its operations.
Recommendation - Require Full IFR certification on all expansion or replacement aircraft. Current fleet upgrades should be required within 60 months.
TRAINING:
1. Initial HEMS Qualification: Priority - Concern.
PHPA is concerned that the availability of highly experienced pilots suited to the HEMS workforce is declining and that pilots lacking requisite experience are being placed into an environment for which they are not fully prepared. Former military pilots in particular are of concern as they no longer fly solo, not even during their initial pilot qualification. All of their experience has been as part of a crew. Yet current regulations do not account for this lack of solo experience when qualifying new HEMS pilots into a single pilot helicopter. Contributing to this problem is the fact that a significant number of the helicopters in the HEMS fleet are single engine and do not have the capability for a flight instructor to accompany a new HEMS pilot on a flight with medical crew and patient on board. For some, their first exposure to the HEMS environment in their local area is solo.
Recommendation - PHPA urges the review and standardization of pilot qualification requirements for HEMS operations.
2. Recurrent Simulator Training: Priority - Important.
Airline pilots fly the same type of airport to airport IFR flight day in and day out, average 1,000 hours in the air per year, yet to a man (or woman) they routinely train on the most sophisticated flight simulators available. A HEMS pilot might log 20% or 30% as much time in the air, operates in an environment that changes daily, and usually receives little more than an annual aircraft proficiency check.
Recommendation - Require recurrent Scenario based Simulator Training for all HEMS pilots on at least an annual basis. This training should use aircraft specific simulators and data bases that place pilots in their own area of operation for maximum effect. (Scenarios should incorporate lessons learned from past mishaps or close calls, and could even be tailored to site specific lessons developed through a FOQA program.)
ENVIRONMENT:
1. Crew Rest: Priority - Important.
PHPA supports a maximum work shift of 12 hours and the requirement for a dedicated rest area where a pilot can sleep if tired. The lack of guidance from regulators in this area has increased the risk of tired pilots accepting flights when opportunities for rest were denied due to operator policies.
Recommendation - Incorporate NEMSPA's recent white paper on the subject as the basis for an industry wide standard which includes training on dealing with fatigue in the HEMS community.
2. Medical Personnel Flight Veto Power: Priority - Concern.
A much touted policy by many in the industry is "Three to go, one to say no". Having a second opinion on a proposed course of action is a valuable tool for a pilot. However, even in a crew of two qualified pilots, the second in command (SIC) seldom has veto power over the Captain. At best, these well intentioned policies can be frustrating to an experienced pilot when paired with a nervous rider. Moreover, decisions made by untrained individuals are often little more than an indication of trust. If the pilot is well liked and trusted by the crew, they will remain silent as he drives them into the ground, whereas an unknown pilot can be pounded with concerns to the point of distraction on a relatively routine flight.
Recommendation - PHPA supports the encouragement of input during flight from all crew members, as well as providing them access to a post-flight reporting system to alert flight standardization personnel to operations with which they have a concern. However, we believe it is important to remind all concerned that FAR 91.3 (a) properly assigns final authority for the operation of the aircraft to the pilot in command (PIC), and that authority cannot be shared or delegated.
3. "Hard" Liftoff Times: Priority - Important.
Some pilots are reporting operator imposed requirements to be airborne within a set amount of time subsequent to receiving a flight request. This arbitrary setting of the amount of time available to properly plan a flight as well as complete the many checklist items required to safely start the aircraft and initiate flight, is unwise on a number of levels. Every flight is different, as is the time required to properly plan and initiate it.
Recommendation - Hard liftoff times are an unsafe practice that should be banned by the FAA.
4. ASAP & FOQA Programs: Priority - Important.
PHPA supports the implementation of non-punitive ASAP & FOQA programs that encourage pilot participation and reporting of safety related issues. A well designed and managed program can provide pilots with invaluable feedback to improve overall safety performance.
Recommendation - Encourage the implementation of these valuable programs.
The Professional Helicopter Pilots Association appreciates the continuing efforts of the NTSB to improve the safety of HEMS operations. These flights, conducted by professional men and women, have had and will continue to have a substantial impact on the lives of those they transport. The efforts of the Board in addressing the safety of this industry will have no less substantial an impact on those passenger's, as well as the crews who serve them.
Butch Grafton
President PHPA Int.
Office and Professional Employees International Union
Recommendations on Helicopter Emergency Medical Services (HEMS) Operations pursuant to the NTSB Hearings of February 2009
March 5, 2009
The Professional Helicopter Pilots Association (PHPA) has a membership of over 4,000 helicopter pilots around the United States and Canada, over 1,300 of which are active HEMS pilots.
The members of PHPA are gratified that the issue of HEMS safety is receiving the acute attention from government agencies, industry, the media, and the public that it has long required. No stakeholders in this issue have more to gain (or lose) than do the men and women who fly these aircraft, and while we are certainly encouraged by the attention currently focused on our industry, we remain wary that talk will not be transformed into meaningful action.
We are all too aware that "pilot error" is cited as the cause in the majority of helicopter accidents, and recognize that "heal thyself" is often the call from those who look at this issue from outside the cockpit.
Were it so easy as to order pilots to stop crashing aircraft.
The International Helicopter Safety Team is putting a significant effort into reviewing accident reports in an effort to identify causal factors and develop recommendations based on hard statistical evidence. Unfortunately, most helicopters do not carry the type of recording devices available to investigators for large fixed wing aircraft. In the end, few investigations can determine with certainty why a qualified pilot flying a functional aircraft is involved in a CFIT accident, with the result being another "pilot error" statistic.
The members of PHPA are certain of this: pilots are more often victim than villain in this arena where good intentions are often not supported by good equipment, good training and good practices. Yet pilots have, for years, remained silent on these issues, conceding to operators who claim that the financial realities of the industry prohibit the adoption of the best equipment and training which for years has been required for our airline brethren. This silence has been born from the fear of losing a job that provides immense satisfaction as well as a source of income, and the absence of a structure such as PHPA from which we could voice our concerns as a group.
It is easy and perhaps correct to blame the pilot, operating a single engine aircraft at its maximum allowable weight, at night, with no vision enhancing system, no terrain warning system, no co-pilot or auto pilot, attempting to transition from the glare of lights at an accident scene to the pitch darkness of an overcast sky who hits wires or gets disoriented and plows back into the ground. Yet placing such blame does not make the next flight safer.
We all recognize that there is no cheap, easy fix to the issue of HEMS safety. Yet if this industry truly wants its operational safety to approach the level that has been achieved and sustained by the airlines, the model has only to be copied. Who in their right mind would subject themselves to an airline operation that resembled the above paragraph? Unfortunately, those being transported rarely have any input regarding the operator, or type of equipment that they or their family members are placed in, when being evacuated from an accident site.
It is our contention that relying on voluntary compliance for essential equipment and practices will only result in a continuation of the status quo, with perhaps a slight bias towards compliance accompanying the media glare of each "new" accident.
The recommendations below address both immediate requirements and long term goals. They represent the combined concerns of professional career pilots who simply want the tools to go along with the responsibility for insuring that every flight is brought to a safe and successful conclusion.
EQUIPMENT:
1. Night Vision Goggles or Night Vision Imaging System: Priority - Critical.
Recommendation - Require one of these systems to be onboard and functioning in each aircraft in the current HEMS fleet as quickly as equipment can be purchased, aircraft modified and crews trained. Restrict noncompliant aircraft to day-only flight beyond mandatory implementation date of 24 months.
2. Helicopter - Terrain Awareness and Warning System (H-TAWS): Priority - Critical.
Recommendation - Require installation in the current HEMS fleet within 36 months, with equipment based on the FAA's recently published TSO. Require on all HEMS aircraft purchased for replacement or expansion.
3. Wire-strike Protection System: Priority - Very Important.
Recommendation - Require installation in the current HEMS fleet where systems exist for individual models. Require on all HEMS aircraft purchased for replacement or expansion.
4. Color Moving Map GPS: Priority - Very Important.
Recommendation - Require installation in current HEMS fleet within 18 months.
5. Flight Data Recorder / HUMS: Priority - Very Important.
Recommendation - Require installation in current HEMS fleet within 48 months to include cockpit voice recorder and instrument monitoring through video (as a minimum) where full flight parameter monitoring on legacy aircraft is not practical. Data developed should be used pre-accident for recurrent training as part of a FOQA program.
6. Multi Engine: Priority - Very Important.
Probably no single issue generates more heated debate than that of the potential impact of multiple engines on safety. While we will not attempt to resolve that debate in this document, we will simply highlight several reasons for our position on the issue.
A large percentage of HEMS pilots come from the U.S. military. Practically all helicopters operated by the military today are twins. Therefore the majority of these pilots have no power-off experience or training beyond their initial qualification, and the minimal transition training required prior to their operating a single engine HEMS aircraft. Add to that the difficult environment in which these aircraft are being operated (over crowded cities, forested, mountainous, and other unimproved terrain, at night), and the results from a power failure in a single engine HEMS aircraft when the next one inevitably occurs, will likely be undesirable.
Beyond the obvious benefit of power plant and various subsystem redundancies, multi engine aircraft are larger, providing for separation of cabin and cockpit. This separation provides many important safety enhancing benefits such as:
a.) Preventing the various aspects of patient care from distracting the Pilot,
b.) Reducing or eliminating the potential for a combative patient to interfere with the Pilot or reach the aircraft's power or flight controls,
c.) Allowing for a second Pilot (either training, orienting, or acting as second in command) during patient transports.
Recommendation - Require replacement or expansion HEMS aircraft to meet ICAO Category A, Class 1 or 2 requirements.
7. IFR Certified Aircraft / Two Pilot Crews: Priority - Very Important.
PHPA takes the position that the standard for HEMS operations should be a multi engine, fully IFR certified helicopter crewed by two qualified pilots. That there are operations around the world that meet this standard argues against those who claim it is not feasible.
a. Two Pilot Crews: The safety value of two qualified pilots is undeniable. New HEMS pilots would have the opportunity to develop experience under the tutelage of a veteran pilot, and experienced pilots would have a trained and certified assistant to help manage the ever increasing tasks required to operate safely in the HEMS environment. While not a substitute for a second pilot, a functioning auto-pilot is essential to help reduce pilot workloads to manageable levels during task intensive phases of flight and to reduce fatigue on long distance transports.
Recommendation - Require an auto-pilot on all expansion or replacement aircraft, with current fleet modifications required within 48 months.
b. Full IFR Certification: Required to provide the pilot with the option to abandon the VFR environment before being faced with an inadvertent IMC emergency. Given a night flight with deteriorating weather, currently the pilot has to make the difficult choice between attempting a risky off field landing or declaring an emergency subsequent to entering IMC conditions. We believe that an IFR pilot should have the option of simply requesting a (non-emergent) IFR clearance and recovering to a well illuminated airfield. In addition, WAAS enabled GPS will soon provide the capability for ILS equivalent approaches to hospital helipads. The HEMS community will need IFR certified aircraft to take advantage of this and other rapidly developing technology that will continue to enhance the safety of its operations.
Recommendation - Require Full IFR certification on all expansion or replacement aircraft. Current fleet upgrades should be required within 60 months.
TRAINING:
1. Initial HEMS Qualification: Priority - Concern.
PHPA is concerned that the availability of highly experienced pilots suited to the HEMS workforce is declining and that pilots lacking requisite experience are being placed into an environment for which they are not fully prepared. Former military pilots in particular are of concern as they no longer fly solo, not even during their initial pilot qualification. All of their experience has been as part of a crew. Yet current regulations do not account for this lack of solo experience when qualifying new HEMS pilots into a single pilot helicopter. Contributing to this problem is the fact that a significant number of the helicopters in the HEMS fleet are single engine and do not have the capability for a flight instructor to accompany a new HEMS pilot on a flight with medical crew and patient on board. For some, their first exposure to the HEMS environment in their local area is solo.
Recommendation - PHPA urges the review and standardization of pilot qualification requirements for HEMS operations.
2. Recurrent Simulator Training: Priority - Important.
Airline pilots fly the same type of airport to airport IFR flight day in and day out, average 1,000 hours in the air per year, yet to a man (or woman) they routinely train on the most sophisticated flight simulators available. A HEMS pilot might log 20% or 30% as much time in the air, operates in an environment that changes daily, and usually receives little more than an annual aircraft proficiency check.
Recommendation - Require recurrent Scenario based Simulator Training for all HEMS pilots on at least an annual basis. This training should use aircraft specific simulators and data bases that place pilots in their own area of operation for maximum effect. (Scenarios should incorporate lessons learned from past mishaps or close calls, and could even be tailored to site specific lessons developed through a FOQA program.)
ENVIRONMENT:
1. Crew Rest: Priority - Important.
PHPA supports a maximum work shift of 12 hours and the requirement for a dedicated rest area where a pilot can sleep if tired. The lack of guidance from regulators in this area has increased the risk of tired pilots accepting flights when opportunities for rest were denied due to operator policies.
Recommendation - Incorporate NEMSPA's recent white paper on the subject as the basis for an industry wide standard which includes training on dealing with fatigue in the HEMS community.
2. Medical Personnel Flight Veto Power: Priority - Concern.
A much touted policy by many in the industry is "Three to go, one to say no". Having a second opinion on a proposed course of action is a valuable tool for a pilot. However, even in a crew of two qualified pilots, the second in command (SIC) seldom has veto power over the Captain. At best, these well intentioned policies can be frustrating to an experienced pilot when paired with a nervous rider. Moreover, decisions made by untrained individuals are often little more than an indication of trust. If the pilot is well liked and trusted by the crew, they will remain silent as he drives them into the ground, whereas an unknown pilot can be pounded with concerns to the point of distraction on a relatively routine flight.
Recommendation - PHPA supports the encouragement of input during flight from all crew members, as well as providing them access to a post-flight reporting system to alert flight standardization personnel to operations with which they have a concern. However, we believe it is important to remind all concerned that FAR 91.3 (a) properly assigns final authority for the operation of the aircraft to the pilot in command (PIC), and that authority cannot be shared or delegated.
3. "Hard" Liftoff Times: Priority - Important.
Some pilots are reporting operator imposed requirements to be airborne within a set amount of time subsequent to receiving a flight request. This arbitrary setting of the amount of time available to properly plan a flight as well as complete the many checklist items required to safely start the aircraft and initiate flight, is unwise on a number of levels. Every flight is different, as is the time required to properly plan and initiate it.
Recommendation - Hard liftoff times are an unsafe practice that should be banned by the FAA.
4. ASAP & FOQA Programs: Priority - Important.
PHPA supports the implementation of non-punitive ASAP & FOQA programs that encourage pilot participation and reporting of safety related issues. A well designed and managed program can provide pilots with invaluable feedback to improve overall safety performance.
Recommendation - Encourage the implementation of these valuable programs.
The Professional Helicopter Pilots Association appreciates the continuing efforts of the NTSB to improve the safety of HEMS operations. These flights, conducted by professional men and women, have had and will continue to have a substantial impact on the lives of those they transport. The efforts of the Board in addressing the safety of this industry will have no less substantial an impact on those passenger's, as well as the crews who serve them.
Butch Grafton
President PHPA Int.
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Interesting that the equipment upgrade gets a "critical" rating and all human factors (training, environment etc) merit only a "concern" or an "important".No amount of bells and whistles can change the EMS safety record. It has to be a multi pronged effort.
Of course, since that means doing several things together and since the FAA or the operators are incapable of walking and chewing gum at the same time it will be just another bandaid for a bullet wound.
Pilot training, pilot attitudes, scheduling, duty time and operational control all need to be addressed urgently and concurrently with all the other gizmos. Just my 2c.
Alt3.
Of course, since that means doing several things together and since the FAA or the operators are incapable of walking and chewing gum at the same time it will be just another bandaid for a bullet wound.
Pilot training, pilot attitudes, scheduling, duty time and operational control all need to be addressed urgently and concurrently with all the other gizmos. Just my 2c.
Alt3.
I agree with Alouette on this one.
The Bells and Whistles play an important role but the training, procedures, and general mindset amongst the players is where the most effective and most immediate change needs to take place.
Until the industry accepts they are in medical transportation and not "Life Saving" and thus kick the "Hero" mindset to the curb the safety environment will not change.
The rub comes when revenue, flight count, and profitability is considered and cautious, careful, deliberate operations cannot be sustained and kept profitable.
Perhaps, the industry is over sold and some of the dodgy outfits need to fold their tents.
The Bells and Whistles play an important role but the training, procedures, and general mindset amongst the players is where the most effective and most immediate change needs to take place.
Until the industry accepts they are in medical transportation and not "Life Saving" and thus kick the "Hero" mindset to the curb the safety environment will not change.
The rub comes when revenue, flight count, and profitability is considered and cautious, careful, deliberate operations cannot be sustained and kept profitable.
Perhaps, the industry is over sold and some of the dodgy outfits need to fold their tents.
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Mindset is what it is, and will always exist. Some people have a desire to be a hero and nothing will change that. They need to be weeded out of the industry somehow, before they kill somebody, but I'm not sure how that could be done. For those of us who have long since realized we'll never be heroes, but just want to stay alive and collect our paychecks, better equipment will certainly help us to do that. Give me the equipment the PHPA proposes, and I can survive most situations, whether inadvertent IMC or an engine failure. There will always be accidents, no matter what equipment is being used, because there will always be unexpected and unusual events, as the airlines continue to show us, but if we have the most probable events covered, we've done a lot. I do agree that training needs a higher priority, and I think Butch covered it to some extent. We need frequent IFR training, either in sims, the aircraft, or both, because without currency and proficiency, that fancy equipment will kill you in a heartbeat. But without the necessary equipment, you're probably going to die anyway.
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Ah Gee.....you mean folks that have been the worst serial killers in the country are miffed someone is taking them to task on how they operate?
I would suggest a quick review of their accident stats and we can probably guess who they are.
Just why does it take a builder of helicopters to do this study.....and not the very industry that was the subject?
Reckon some folks have yet to realize there is a problem?
I would suggest a quick review of their accident stats and we can probably guess who they are.
Just why does it take a builder of helicopters to do this study.....and not the very industry that was the subject?
Reckon some folks have yet to realize there is a problem?
There are no limits
More grist to the mill.
This from the Flight Safety Foundation today.
I totally agree with all the previous posters on the person factors associated with this. No amount of bells and whistles will reduce accidents without the appropriate correction in attitudes.
This from the Flight Safety Foundation today.
I totally agree with all the previous posters on the person factors associated with this. No amount of bells and whistles will reduce accidents without the appropriate correction in attitudes.
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Alt 3, Sasless, WIII: spot on with the human factors comments. The most wanted list declared by the "Union" has its priorities out of whack in my opinion. All those toys listed as "critical" are wonderful for what I would call "Positional Awareness" (NVG's, Color GPS moving maps, Terrain Alerts), but those things don't do much for a pilot who has lost "Situational Awarenesss" (in the conventional sense of the term). These "critical" gadgets should be secondary to proper risk management training and a mission analysis process that takes into account the true probability of success based on the training and experience of the aviator, vice the probability of a good payday. Poor decision making and "missionitis" are always going to be the achilles heel of this industry no matter how many things you put in the aircraft to overcome the weakest link. I am comforted to see that the press for multi-piloted operations seems to be high on the most wanted list, it will definitely help matters.
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Time
The more bells and whistles present, the more probability at some point a pilot will lose situational awareness, especially if he/she does not know how to declutter all the info to JUST that required. Trying to deal with too much info in a short period of time is like trying to speed read on a professional level while still in grade school.
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From Aviation Week today
HEMS Hearings Explore Safety Issues
The House aviation subcommittee hearing that we told you had been scheduled last Wednesday explored multiple issues relating to Helicopter Emergency Medical Services (HEMS) air ambulance safety. It was broadcast by streaming video from the Transportation Committee web site.
Subcommittee Chairman Jerry Costello (D-Ill.) noted that helicopter air ambulances operate in challenging conditions, including bad weather, unfamiliar and often confined landing sites, and at night, simply because their services are so vital.
At the meeting, FAA Flight Standards Director John Allen testified that the agency has taken a multipronged approach to address HEMS safety, including the release of an operation specification (OpSpec) that increases weather and visibility minimums, FAA-recommended best practices and multiple notices, bulletins and advisory circulars covering HEMS operations and equipment.
"We recognize that relying on voluntary compliance alone is not enough to ensure safety operations," Allen said in testimony. "In that regard, the FAA has initiated a formal rulemaking project that will address many of the HEMS initiatives . . . over the last several years." Allen added that the agency hopes to have a notice of proposed rulemaking published in late 2009 or early 2010.
House Transportation and Infrastructure Committee Chairman James Oberstar (D-Minn.) agreed that, "while voluntary guidance and increased weather and visibility operating requirements are steps in the right direction, this is not enough." He said the FAA must also address safety technology enhancements such as TAWS, GPWS and night vision goggles - along with human factors that affect mission-oriented HEMS pilots performing mercy flights, he said. "FAA must commit to long-term action to ensure that patients and flight medical crew aboard HEMS flights reach their destinations safely."
"The regulatory issues involved here are not easily parsed, so we need to be sure that in our efforts to accomplish this goal we do not create unintended consequences that create additional problems," Costello said.
Some HEMS operators are reportedly already balking at the prospect of new equipment requirements and to stricter dispatch rules.
Bolding mine. With all the evidence before them (lost lives, bent metal) it looks as though the operators can't see the woods for the trees. Any lumberjacks out there able to clear a forest?
HEMS Hearings Explore Safety Issues
The House aviation subcommittee hearing that we told you had been scheduled last Wednesday explored multiple issues relating to Helicopter Emergency Medical Services (HEMS) air ambulance safety. It was broadcast by streaming video from the Transportation Committee web site.
Subcommittee Chairman Jerry Costello (D-Ill.) noted that helicopter air ambulances operate in challenging conditions, including bad weather, unfamiliar and often confined landing sites, and at night, simply because their services are so vital.
At the meeting, FAA Flight Standards Director John Allen testified that the agency has taken a multipronged approach to address HEMS safety, including the release of an operation specification (OpSpec) that increases weather and visibility minimums, FAA-recommended best practices and multiple notices, bulletins and advisory circulars covering HEMS operations and equipment.
"We recognize that relying on voluntary compliance alone is not enough to ensure safety operations," Allen said in testimony. "In that regard, the FAA has initiated a formal rulemaking project that will address many of the HEMS initiatives . . . over the last several years." Allen added that the agency hopes to have a notice of proposed rulemaking published in late 2009 or early 2010.
House Transportation and Infrastructure Committee Chairman James Oberstar (D-Minn.) agreed that, "while voluntary guidance and increased weather and visibility operating requirements are steps in the right direction, this is not enough." He said the FAA must also address safety technology enhancements such as TAWS, GPWS and night vision goggles - along with human factors that affect mission-oriented HEMS pilots performing mercy flights, he said. "FAA must commit to long-term action to ensure that patients and flight medical crew aboard HEMS flights reach their destinations safely."
"The regulatory issues involved here are not easily parsed, so we need to be sure that in our efforts to accomplish this goal we do not create unintended consequences that create additional problems," Costello said.
Some HEMS operators are reportedly already balking at the prospect of new equipment requirements and to stricter dispatch rules.
Bolding mine. With all the evidence before them (lost lives, bent metal) it looks as though the operators can't see the woods for the trees. Any lumberjacks out there able to clear a forest?
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There'll be an interesting article in a future issue of Vertical about what the industry groups have done. (and not written by me - I've seen the draft and it's not going to make these groups look good)
Whirlwind,
Complexity a threat to Situational Awareness?
Yes it can be.
The opposite can be just as deadly....that being no complexity.
For example.....
Single pilot marginal weather....unstabilized aircraft...basic instrumentation....paper map in hand....NIGHT!
How many of us really use a paper map at night and do a proper job of it?
A moving map GPS....with a screen big enough to be seen easily beats hell out of the other situation does it not?
Let's add NVG's into the mix.....now we can actually "see" in the dark....instead of trundling along waiting to see some lights somewhere on the ground.
Add a hands off autopilot so all we have to do is attend to the conduct of the flight and not be splitting our attention to hand flying the aircraft and all that other stuff we do to "manage" the flight.
If one is too dull to keep up with the "hired help" then perhaps one should step out of management....and seek a day time VFR only job.
Complexity a threat to Situational Awareness?
Yes it can be.
The opposite can be just as deadly....that being no complexity.
For example.....
Single pilot marginal weather....unstabilized aircraft...basic instrumentation....paper map in hand....NIGHT!
How many of us really use a paper map at night and do a proper job of it?
A moving map GPS....with a screen big enough to be seen easily beats hell out of the other situation does it not?
Let's add NVG's into the mix.....now we can actually "see" in the dark....instead of trundling along waiting to see some lights somewhere on the ground.
Add a hands off autopilot so all we have to do is attend to the conduct of the flight and not be splitting our attention to hand flying the aircraft and all that other stuff we do to "manage" the flight.
If one is too dull to keep up with the "hired help" then perhaps one should step out of management....and seek a day time VFR only job.
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I watched portions of the testimony on the web. The panelists were evenly divided on whether this was a medical enterprise which just happens to use helicopters or an aviation enterprise which just happens to have sick people as passengers.Equally split were opinions whether the states should have the ability to regulate HEMS thereby being able to control how many helicopters operate in their state and what kind of equipment should be mandated.One of the guys went as far to say that the Airline Deregulation Act of 1978 should not apply to HEMS as it was passed with only the scheduled airline operations in mind and not HEMS, which was still in it's infancy.
To me, the key lies in resolving the first issue (i.e. aviation or medical). But,the pessimist (or realist) that I am, I think this will go down as another eternal debate, on par with Global Warming, Abortion, Gun Control etc.
Alt3
To me, the key lies in resolving the first issue (i.e. aviation or medical). But,the pessimist (or realist) that I am, I think this will go down as another eternal debate, on par with Global Warming, Abortion, Gun Control etc.
Alt3
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SASless (where did you get that moniker dear friend?)
Complexity is that which is required to be processed by the pilot per given unit of time. Simplicity is a moving map, until it fails.
Complexity is a completely overcoddled medical crew with their mouths constantly in motion distracting the pilot.
Complexity is the corporate arm of an Air Carrier thinking they can control to their benefit from their comfie chairs afar through directing and disciplining their line swine thus creating safety through ten thousand pilot' and maintenance technician' computer key strokes per minute, all aghast at filling out endless thoroughly ignorant forms that lead to statistical discovery completely after the fact of their distraction via flight operations taken place through the ground zero delegated Operational Control placed with the pilot (golly gosh, ya thinks - is this something new?) - you know, the Ivory Tower Syndrome.
Dumber is just getting more fascinated with dumber!
Complexity is an industry thinking they can out - technologize the attention required to the human element of this HEMS operating equation by night vision goggles and all sorts of other technical goodies.
This industry needs to get fascinated with its line workers and the basics required to support them and make their jobs easier, thus more effective, and more safe. This is NOT what is currently happening, and we all see it.
Just think, Canada have been doing this for 30 years, with no upsets - what are we missing?! I know.
WIII
Complexity is that which is required to be processed by the pilot per given unit of time. Simplicity is a moving map, until it fails.
Complexity is a completely overcoddled medical crew with their mouths constantly in motion distracting the pilot.
Complexity is the corporate arm of an Air Carrier thinking they can control to their benefit from their comfie chairs afar through directing and disciplining their line swine thus creating safety through ten thousand pilot' and maintenance technician' computer key strokes per minute, all aghast at filling out endless thoroughly ignorant forms that lead to statistical discovery completely after the fact of their distraction via flight operations taken place through the ground zero delegated Operational Control placed with the pilot (golly gosh, ya thinks - is this something new?) - you know, the Ivory Tower Syndrome.
Dumber is just getting more fascinated with dumber!
Complexity is an industry thinking they can out - technologize the attention required to the human element of this HEMS operating equation by night vision goggles and all sorts of other technical goodies.
This industry needs to get fascinated with its line workers and the basics required to support them and make their jobs easier, thus more effective, and more safe. This is NOT what is currently happening, and we all see it.
Just think, Canada have been doing this for 30 years, with no upsets - what are we missing?! I know.
WIII