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Butch GraftonUser is Offline
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05 Mar 2009 01:18 AM QuoteQuote ReplyReply  
Please post your thoughts on PHPA's position with the regulators concerning HEMS issues.

Thanks!

Butch

PROFESSIONAL HELICOPTER PILOTS ASSOCIATION INTERNATIONAL

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 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.

RotorDriver (guest)
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14 Mar 2009 07:21 AM QuoteQuote ReplyReply  
Why is it that I never see any recomendations that the Chief Pilot or Director of Operations assume some responsibility in ensuring that pilots and aircraft are properly trained and equipped? I have said for many years that if the CP and or the DO were to face some strict penalties should they be deemed to be remiss in their duties, the CP and DO would pay a lot more attention to who is flying their machines and what kind of condition those machines were in....

Using the Anchorage accident as an example, if the pilot was found to not have been properly qualified to fly NVG's or not prepared for Alaskan flying conditions (and I do not know either condition to existed) then the CP should have been immediatly suspended. If the it could be shown that the DO was aware of a problem either with the pilot or equipment then he should also be suspended. I would propose that having been suspended, neither could serve in that capacity with ANY certificate holder for at least one year.

Pilots can and do launch into a bad situation when the CP and the DO know that they should not be there. They are only there because the operator could not find another body to fill the seat.
FL270 (guest)
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14 Mar 2009 07:45 AM QuoteQuote ReplyReply  
I think everything mentioned in the recommendations are right on the mark. Unfortunately, I put little trust that any of these recommendations will ever be implemented. The big two....PHI and AMC will do everything within their reach to counter any wordage that will cut into their profit margins. They have plenty of quality insurance to pay off the balance of a crashed helicopter and the life insurance of crewmembers. They only care about the loss of revenue due to poor public relations because of an accident. Quick to blame pilot error and not hiring selection, training, equipment, or operational practices. I'd love to see twin engine, dual pilot, IFR, NVG aircraft and crews at all HEMS bases.....nice dream! But damn good pitch on recommendations. Clearly a well thought out and well written document.
Steve (guest)
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14 Mar 2009 08:02 AM QuoteQuote ReplyReply  
What caused the accidents? Recent crashes have had two pilots IFR twin engine aircraft. It looks to me like some things never change. Bad weather. When you push weather it pushes back. It's always been a problem which can be better and more cheaply handled in the short run at least by raising the minimums and losing a few flights. Flying a VFR only aircraft right to the edge of minimums is foolish and dangerous but the push for numbers drives this action. I wish we flew to the edge to save the life of a patient but that is rarely the case. We fly on the edge to make money. It is that simple. Proper equipment is a no brainer and irresponsible to not install it as fast as possible. Again the bean counters are driving the bus. I wish one of them would fly with me one dark night, unaided, over the forest, at minimums. Any takers?
peacemaker (guest)
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15 Mar 2009 08:44 AM QuoteQuote ReplyReply  
Work on HEMS issues by PHPA is excellent, thank you.

I would put much more priority to pilot IIMC training as when the goggles fail to keep the aircraft VMC, when TAWS indicates an obstruction or terrain problem, when weather boxes an aircraft in, etc. the pilot is likely to be required to either maneuver in an area of reduced visibility or with none of the same, requiring solid instrument flying skills.

To my way of thinking all the goggles and TAWS, etc. in the world cannot make up for a pilot being confident in his/her capability to enter IMC and sort things out properly. Confidence is the pivotal issue here and it comes from training and experience with handling such situations. If @60% of recent accidents involve CFIT or spatial disorientation I think this argument bears more attention.

Also, the mandates of wearing personal protective equipment (PPE) such as nomex and high top leather boots and helmets etc., is fine, excepting in hot weather. The military address this issue as they know heat stress impairs judgement. As yet this appears not to be of concern to the HEMS community albeit we fly around in barely air conditioned helicopters that behave like greenhouses with respect to the insolation of heat. Every HEMS pilot and crewmember I have spoken with is at odds with this equipment in hot weather but indicate they feel it is a holy grail sort of subject that is just not going to change. Well, we are missing a critical human factors issue here if the military address this for their very fit personnel and the HEMS community, manned by personnel who are possibly amongst the least fit of our population, does not. We should be able to modify this PPE in hot weather to maintain comfort and excellent crew performance. For HEMS operators, PHPA, and other entities not to address this issue is surprising to many.
HEMSLAWS (guest)
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16 Mar 2009 05:18 AM QuoteQuote ReplyReply  
Where has this position paper been sent/posted besides here? Has it been sent to anyone with any sort of interest and governmental clout?

This proposal contains timely and accurate assessments of some of the problem areas in HEMS, and gives definitive corrective actions with reasonable timelines for compliance. I would hope that this is not just sitting on this website with the expectation of someone that can get these things done might stumble upon it.
Butch GraftonUser is Offline
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16 Mar 2009 11:19 AM QuoteQuote ReplyReply  
Here is an explanation on how this paper came to be.

PHPA recently sent four pilots to the NTSB hearing in Washington D.C. concerning HEMS safety issues. PHPA was one of seven parties allowed to question the witnesses during this hearing. Based on what we learned at this hearing, as well as information we have collected from pilots not only across the U.S. but also from a number of other countries, we have formulated our position on many of the issues confronting HEMS pilots and have forwarded our recommendations to the NTSB.
Ojames2525 (guest)
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17 Mar 2009 12:05 PM QuoteQuote ReplyReply  
What about TCAS!! I fly in the Wash. D.C. ADIZ area. Lots of controlled and uncontrolled airspace and aircraft of all shapes and sizes all over the place! Give me NVG's and TCAS and I'll be a very happy camper!
Chprsafety
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20 Mar 2009 09:36 AM QuoteQuote ReplyReply  
An extremely well thought out and drafted document. I would assume that NVIS as one of the critical recommendations refers to Enhanced Vision Systems (EVS) however the FAA does not include EVS as a subset under this acronym contrary to their earlier guidance and recommendations. IFR is a very significant enhancement and risk mitigator within the HEMS environment regardless of the use of single or dual pilots in the operation. Certainly the giants in the industry are VFR predominately ... however statistics show that operations within protected airspace from takeoff to landing and take terrain and obstacles into consideration as an inherent part of the design. IIMC doesn't come nearly as much into play if you're already intending to be IFR .... I think one of the critical elements that must be pushed is the inclusion of a low-level helicopter segment integral to the next gen airspace system. The NTSB is making excellent recommendations .... the FAA is asleep at the wheel and working with technology and airspace architecture that is way out of date.
spudgrower53
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22 Mar 2009 01:32 AM QuoteQuote ReplyReply  
sound like a great read but where is it?
darnsillius
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11 Apr 2009 08:38 AM QuoteQuote ReplyReply  
I've only been in the HEMS industry for a little over 2 years, so I don't know what it was like before that time. I've heard stories of the past and I have my own experiences, so I'll address my comments from that point of view.

My take on HEMS is that aviation is not the driving factor. It is a means to an end and it is reactionary, not proactive. I think I'm pretty accurate in my analysis, judging from the previous comments. From the type of aircraft, supplemental equipment (NVG's, TAWS, GPS, Wx data, automated flight control systems, etc), crew composition, duty day-length, pay, training, quarters, regulations and policies, we all have our own ideas on what we (aviators) think is necessary, but we are not the decision makers. CEO's, hospital staff, the government and the free-market dictate what we get, how much we get and when we get it. From what I've seen, aviators are not in the higher management positions; they're medical people (again, from what I've seen). Therefore, there is more "catering" to the medical side of our industry.

Now, I understand that if you go by numbers, the medical people make-up the larger portion of our companies (2:1 on average), so there would seem to be justification in management being heavy on the medical side. But I look at it from a "risk" perspective, and my (biased) conclusion is that avaition inherently has more risk than the medical side. As I chide my med crews, "You only work 1/3 of the flight...I work the whole flight." (based on the average 3-leg flight). I, therefore, believe that more aviators need to be in the higher management positions.

The current situation puts in management individuals with no aviation experience in charge of making aviation decisions. When (or maybe I should say "if") they do their risk:cost:benefit analysis, they will go for the smallest gun with the biggest bang. That usually leaves us with the short end.

Now some programs have the dual-engine, pilot & co-pilot, IFR & NVG systems and are living high, but I know most programs don't have those luxuries. And they are luxuries when you look at the market. Should they be the standard? Perhaps. But I feel you'd be asked to "do more with less." There would be less competition, individual companies would have fewer bases, so you'd have to do more flights to pay for those types of aircraft/systems and the end result is fewer job opportunities. I unequivocally do not suggest compromising safety for job opportunities. Some operations do not need all of the above mentioned equipment.

I would suggest that if your program doesn't have NVG's, then you are restricted to inter-facility transfers and/or scene responses to improved areas (airport/heliport or base) only when flying at night.

If your aircraft is VFR-rated, then the weather minimums need to be increased (AO21 good start but...). Same if you are single-pilot IFR.

I would like to see the avionics become more helicopter-friendly. While the Garmin 430/530 are good systems, they are made for fixed-wings. They require too much attention be practical, especially when things go pear-shaped. Same with some of the other radios. We need GPS's & radios that are a couple of button pushes to get our necessary info to us. Putting in a lat/long while flying towards cumulo-granite at night or when you get an LZ change is not fun, nor safe. Oh, and the buttons need to be bigger so you can see them at night...same for theose damn Kolsman window numbers...(I hate getting old!)

I also agree with Chprsafety in that the FAA needs to set-up a low-flying system (like they have in the UK) that is structured to handle the helicopter and General Aviation community.

I've ranted enough...for now.
ali5106
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21 Apr 2009 11:20 AM QuoteQuote ReplyReply  
hi thanks i need one with a logo of play it again sports
Wally HawnUser is Offline
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24 Apr 2009 08:21 AM QuoteQuote ReplyReply  
Bells and whistles won't make the difference in helicopter EMS safety, with one big exception- NVGs. The scenario common to the highest hazard is night duty, a situation I've seen since Vietnam. It doesn't seem to make much difference whether the aircraft involved is a single or a twin; IFR/VFR capable. The common element in tis scenario is a human pilot making poor decisions and not resolving the issue. You don't resolve poor decisions with equipment. I think equipment adds to the problem by promoting the illusion of capability and increasing work load in a situation where the pilot's already over taxed.
I'm afraid I see some real problems with formal risk assessment and operational control programs as well. Very few professional pilots are unaware that the cost of an error in this business is often a fatal accident, knowing that should make safe conservative responses, that is- aborts and declines the result in the accident scenarios. Add that a major part of our risk assessment is interpreting very, very fine points that can't be predicted, much less placed in a matrix, making them a very blunt instrument when direct finesse is required for credible decisions. Operational control centers share that non-specificity, plus the committee weaknesses of diluting responsibility and a decision by passion of presentation.
Human/pilot error is the problem, and the industry has yet to address it it in any meaningful way. Quite the reverse, the industry seems to promote the problem by ignoring known physiological factors affecting mental functioning when scheduling pilot duty. We commonly schedule for long duty days, too many consecutive long duty days, and rotate to nights continuing that error, often with only a 24 hour break between day and night duty assignments.
Twelve hour duty days may be acceptable in low work-load situations, but you can't predict those days in this industry. Yet, it's the standard and traditional, because we've always done it that way. A pilot suffering from fatigue after a 12 hour duty has an unwritten if not formal demand to continue, a 'real pilot can hack it'. Add the fact that 12 hour duty days are not infrequently 14 hour plus duty days, and we're expected to recover in the regulatory minimum 10 hours...
Seven sequential 12 hour days is one too many. The only evidence I have to support this is from the Railroad industry.
Sleep loss, sleep disruption and circadian upset are well known factors. The industry ignores those when scheduling pilot night duty. It magnifies the error by making the normal night rotation day to night with a 24-hour break at the end of a seven day duty schedule and not training management if not line pilots in assessing the issue.
Foreman1
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27 Dec 2009 12:45 PM QuoteQuote ReplyReply  
Hey guys. Im Dillon. Im a senior in high school and im determined to become a helicopter pilot. Id like to work for an offshore oil rig someday but getting there is my problem. Ive been researching but i wanted to get some input by professionals. Any advice would be greatly appreciated. What to look for... who to talk to... where to go. Anything, please. contact me.
------- dillonforeman1@yahoo.com -------
tom wayne
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29 Dec 2009 09:06 AM QuoteQuote ReplyReply  
I was once a member of PHPA and worked for Air Log. I have a question. I was called back on active duty after 9/11. I was on leave of absence for about five years and received a call from the HR division sometime last year. They wanted to know if I were to come back and I responded no as the government hired me and am still working with the government. Once Air Log found out I was not coming back they zeroed out my Vanguard 401 plan, not only their % given to me but even the funds I contributed while working with them. I have left them repeated messages for about 10 months and they will not return my call. My question, how can I have my old Local 107 Employees Union help me with the issue or could someone steer me in the right direction?

Thanks

email: tg12896@charter.net
Wally
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28 Apr 2015 04:09 AM QuoteQuote ReplyReply  
Where are the PHPA comments?
https://www.federalregister.gov/articles/2014/02/21/2014-03689/helicopter-air-ambulance-commercial-helicopter-and-part-91-helicopter-operations#h-44


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