Europe reviews regulations for helicopter EMS operations
EMS operators in Europe are providing some input in the ongoing debate in the U.S. about helicopter emergency medical service (EMS) safety. Reacting to a series of stories in AIN, Friedrich Rehkopf, managing director of German EMS provider ADAC Luftrettung (the flying arm of the country’s automobile club), was eager to highlight how the European approach to safety differs from that in the U.S. He also pointed out some areas where European operators could improve safety. Finally, he noted that the tighter operating rules in the Old World are not suited to every EMS organization.
When AIN asked Rehkopf whether he considers European helicopter EMS (HEMS) operations safer than those in the U.S., he said he could not answer officially because of the lack of statistics on HEMS operations in Europe. However, he did say that European operations at least seem to be quite safe.
First, all HEMS flights operate under commercial rules in Europe. There is no equivalent to the Part 91 rule that still covers part of HEMS operations in the U.S.
“We do a lot of training and undergo frequent checks,” Rehkopf added. JAR-OPS 3 rules call for one proficiency check per year for pilots and operating companies, and some training is required between the annual checks.
Rehkopf explained that the role of the paramedic on board differs in Europe and the U.S. Under European rules, the paramedic is assigned a full mission as the “HEMS crewmember” and assists the pilot with navigation and communications duties. “He or she is very useful at night,” Rehkopf said.
JAR-OPS 3 requires the helicopter to be flown by a crew of two pilots at night, except when it is within 50 kilometers (27 nm) of base. In that instance, a crew of one pilot and one assistant is sufficient.
Pilot/Medical Staff Interactions
However, the operator’s ability to implement these rules depends on its overall organization. ADAC, for example, employs both the pilots and the medical attendants. But in France, in many instances, the HEMS operator employs pilots but no medical staff. They come from the hospitals, which are local public administrations.
“How could the pilot have authority over external people who can be seen as customers?” Nicolas Letellier, president of the French association of HEMS-user doctors, asked rhetorically. A solution could be adding the paramedic to the operating company’s payroll (though he would continue to draw his salary from the hospital as well). The question remains unresolved in France.
The aviation training for the HEMS crewmember includes airspace designations, navigation by the map and radio operation. Most important, crewmembers learn crew resource management (CRM) during a 10- to 15-day initial training course and take an annual refresher course.
In the near future, CRM will be taught jointly to pilots and doctors. The aeromedical CRM course focuses on decision-making under difficult circumstances. “For example, when the aircraft is carrying a severely injured child, the doctor might be tempted to influence the flight crew, but they will learn together how to find solutions in this situation,” Rehkopf explained. He emphasized that the atmosphere is more relaxed and professional with a well trained crew.
However, he conceded that commercial pressure might remain. “This has to do with the management,” Rehkopf said. In other words, the issue of the relationship between competition for market share and safety has not been addressed yet.
An insurance company in the U.S. had suggested that the distractions of multiple instruments and systems in the cockpit could cause serious problems. Rehkopf dismissed this concern, saying, “In fact, full-authority digital engine control [fadec] has done a lot for de-complication, as did autopilot and GPS-based navigation.”
Future Safety Improvements
ADAC is not using night-vision goggles (NVGs) yet but is considering doing so. “It would be a great improvement, as 40 percent of our flights are conducted at night,” Rehkopf said. He believes NVGs will enhance vision in the existing weather minimums.
But a couple of obstacles remain before ADAC can install this equipment in its helicopters. First, the German interpretation of JAA recommendations does not allow the use of NVGs yet. A draft regulation is currently circulating in the industry. Second, “the U.S. does not export the latest in commercial NVG technology,” he claimed.
The NTSB has recently recommended the installation of terrain awareness and warning systems (TAWS) aboard EMS helicopters. Asked about this recommendation, Rehkopf questioned cost efficiency in Europe. “It would add weight and cost, while the distances covered here are short–around 30 nautical miles, so the pilot’s knowledge of the usual area of operations is better,” he said.
Rehkopf mentioned one recent controlled flight into terrain (CFIT) accident, and although the cause of the crash has still not been officially published he asserted that “in fact, we do not know whether EGPWS-like equipment is necessary.”
Rehkopf has great hopes for GPS-guided approaches, which are currently under test in a couple of European locations. Current IFR rules are ill suited to helicopter operations. A satellite-guided approach to a “point in space” close to a hospital, for example, would be safer than marginal VFR and more practical than IFR. The shape of the approach flight path could take into account helicopter performance.
The European HEMS and air rescue committee (EHAC) has been lobbying for cost-efficient safety rules since it was founded in 2000. The association’s Web site says, “JAR-OPS 3 has demonstrated that without the feedback of the HEMS operators, regulations were likely to turn into impediments rather than favor development [of air rescue in Europe].”
Industry input deflected some costly measures, according to Rehkopf. For example, the JAA once considered mandating the retrofit of cockpit voice recorders on the existing fleet. “It would have cost more than €100,000 [$120,000] per aircraft,” Rehkopf asserted. Another example was the needed redundancy on attitude indicators. “We agreed on two displays, but EHAC managed to avoid the expensive and bulky addition of a second gyroscope,” Rehkopf explained.
The Munich-based association has proposed 35 changes during the JAR-OPS 3 writing process. “Some 90 percent have been implemented and often yielded a more practical regulation,” Rehkopf said.
A change on the dry-lease rule is still under discussion. “For example, if a German company dry-leases a helicopter to a Dutch operator, the German authority still requires a physical inspection of the aircraft when it returns to Germany after the leasing period,” Rehkopf explained. But this does not make sense when the aircraft is consistently maintained by the German company, even during the leasing period, he emphasized.
European HEMS Safety Statistics
No safety statistics are available for helicopter EMS flights in Europe. The number of HEMS missions flown annually is estimated to be between 200,000 and 250,000. Due to the small distances flown per mission, the number of flight hours is certainly much lower. In the U.S., about 300,000 HEMS flight hours were flown in 2005.