Butch Grafton
New Member
Posts:17
 |
| 20 Mar 2009 01:13 AM |
|
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 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.
|
|
|
|
|