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Commentary and Summary of the NTSB special report on EMS Operations

The entire report can be downloaded from this link.

Helicopter EMS operations has literally exploded in size in the last ten years. With this growth comes accidents, sometimes more or less, but always relatively proportional to the number of flights/flight hours. Of course there were more accidents, there were more flights. EMS accidents are also high profile, like an airline accident is, I don't care where you live, you will hear about it; whereas you will not likely hear about many other aviation accidents unless you are more local to the area where it occurred.

There is a serious problem with the way the FAA and the NTSB records and tracks EMS accidents, in that if there is not a patient on board the aircraft, it is not considered an EMS operation, and is not recorded as such. Interestingly enough, the NTSB recognized this for their special report and therefore included both situations in their report as an EMS accident. The afore mentioned however, makes a study of this category of accidents difficult, and requires a lot of research. In 2008 the NTSB held a special hearing as a result of the apparent high number of fatalities in 2007. One of the problems with general aviation is that total flight hours are not reported so it is impossible to know with any degree of accuracy how many accidents actually occur per 100,000 flight hours. I have read many reports which would seem to indicate that the FAA has this knowledge, but they really don't, and there is no possible way since it would require some sort of mandatory reporting system which does not exist. A representative from HAI (Helicopter Association International) testified to this fact before congress last year. The FAA arrives at its counts by a sampling poll, which as can be seen in the information in both NTSB reports, is highly flawed as stated by the NTSB.

Non-profit vs For-profit operations. This is a topic which comes up from news agencies and employees of some operators as an argument against for profit operations especially in the event of an accident. The persons using this logic don't know what they are talking about since this is a tax status only. ALL operators, Non-Profit or For-Profit must make money to exist, and they all have a similar billing system. One thing they will never tell you is that often times the non-profit agencies bill at a much higher rate. When this argument is used, one might think the employees are working for free, NOT THE CASE! Tax status only; everyone is getting paid, and in many cases more than their for-profit counterparts. Non-profit vs for-profit has nothing to do with the accident rate either, although some would have you think it does. Take for example the Maryland State Police crash that occurred 9/27/08; this was a non-profit, large Aerospatiale (Eurocopter) helicopter, incidentally also Public Use.

For anyone who did not watch the hearings, they were boring to say the least and you didn't miss much. Although there was a tremendous amount of valuable testimony, there was also a lot of bullshit. For example, there was a representative from Eurocopter who was obviously trying to sell their brand of helicopters. He basically blamed accidents on poorly equipped helicopters, and implied that if you bought Eurocopters you wouldn't have accidents. I guess he was not aware of the fact that most of the fatal accidents in 2007 occurred in larger twin engine helicopters. There was a representative from the Mayo Clinic that hated independent EMS operators and he made this obvious during his testimony claiming that an IFR service was the only way to go. But when further questioned, he also admitted that less then two percent of their total annual flight time is actual IFR which is just about how much of the total flight time is spent doing initial and recurrent pilot training; meaning that very little if any time is actual IFR with a patient on board.

Air medical flights nationwide consist of about forty percent scenes, and sixty percent hospital-to-hospital transfers. On a typical scene flight, the helicopter will be landing in an unimproved area where no one has landed before and has no prior knowledge of the landing area. People on the ground who have usually been given some training however minimal may be providing some sort of landing brief to the crew and maintaining security to the best of their ability. These landing zones are often surrounded by obstacles such as power lines, tall trees, road signs, communications towers, and sometimes multiple types of debris. The size of these landing zones can be very small, from 80ft x 80ft and up. A large percentage of these scene flights occur at night when obstacles are hard to see, and determining wind direction and ground slope is a challenge to say the least.

Pilot training background varies between military trained, civilian trained, and police trained. There are a large number of military pilots, most likely leading civilian trained by a small percentage, followed by police trained pilots which amount to a very small number of the total. Interestingly enough, having been involved in the training department at a large EMS operator, the civilian trained pilots had the best overall control technique. The military guys were good pilots, but many had come from large helicopters with significant disposable horsepower, and therefore had some power management challenges. The police trained pilots were the poorest skilled overall and represented the highest washout rate; but don't get me wrong, in the police group, there are some very good pilots.

Another interesting aspect relative to EMS flying is the fact that the demand for pilots far exceeds the availability of highly skilled individuals, this leads to scraping the bottom of the bucket so-to-speak. All that a pilot needs to get started in EMS these days is 2,000 hours total time, with the absolute minimum in instrument time (49 hours total which may be all simulated (hood)), and in nearly any make and model helicopter with nearly any background. Well guess what, when you take the least experienced, youngest pilots, and put them in the riskiest flying environment, that will lead to accidents in itself. Personally, I think this needs to be changed; EMS flying needs to be reserved for the best of the best, not simply anyone who happens to come along; you know, something like 4,000 hours minimum total time with some higher minimum instrument experience. The FAA will not do this. This leads me to the Wall Street Journal article which came out 10/7/2010:

By ANDY PASZTOR

Federal aviation regulators on Thursday are expected to propose long-awaited regulations imposing more safety equipment, enhanced pilot training and tighter operating restrictions on hundreds of emergency medical helicopters flying around the U.S.

Concerned about persistently high nationwide crash rates for medivac helicopters, the Federal Aviation Administration's proposed rules are expected to track many of the previous recommendations issued by government crash investigators, according to people familiar with the details.

The package, these people said, is likely to propose more widespread use of night-vision goggles and terrain-avoidance warning systems. In the past, FAA officials also have publicly pledged to require beefed-up training for pilots.

If the agency follows its earlier direction, the proposals also will call for enhanced training for dispatchers, along with tighter operator oversight and tracking of emergency helicopter flights -- particularly when picking up or transporting patients in bad weather or difficult terrain.

An FAA spokeswoman on Wednesday declined to comment. But in early 2009, when FAA officials testified before the National Transportation Safety Board, they indicated the agency was leaning toward mandating additional safety measures in all of these areas.

John Allen, a senior FAA official, said at the time that agency officials wanted across-the-board efforts to improve risk assessment by operators before launching medical helicopter flights in low visibility.

For years, the FAA relied largely on voluntary company compliance for this segment of the industry. But with 29 fatalities from medical helicopter crashes in 2008, and more than a dozen fatalities already recorded this year, FAA officials have shifted toward mandatory rules.

"We've been waiting for this for six years," said Gary Robb, a plaintiff's attorney based in Kansas City, Mo., specializing in helicopter accidents. Study after study has found "lapses and deficiencies in maintenance at some of the small operators," he said.

Helicopter manufacturers and operators also have been anticipating the FAA's move. Some of them already have opted, on their own, to install extra safety hardware as standard equipment on certain helicopter models.

The FAA's proposal could put additional pressure on other companies to do the same, or to quickly install flight-data recorders designed to help investigators unravel what happened in the event of a crash.

But the FAA's package, according to people familiar with the details, will stop short of proposing some controversial changes advocated by a number of safety experts. Mr. Robb, for example, has pushed for two-pilot crews, rather than a single pilot, on most news helicopters and those providing scenic tours, as a way to prevent accidents caused by distraction. Such safeguards aren't expected to be proposed by the agency.

Write to Andy Pasztor at andy.pasztor@wsj.com

This article demonstrates just how out of touch the FAA is with what is causing the accidents. The FAA keeps mandating more checklists, and other paper fixes for issues that don't have a thing to do with paper. Well, maybe that is not entirely true, maybe if these pilots had more total flight experience tracked on paper, the accident rate would be reduced. Maybe if the pilots had a minimum age requirement for EMS like say 35, after the majority of pilots have all the sport flying out of their system, the accident rate would be reduced. Maybe if the FAA required a minimum visibility of 4-miles and a minimum average area ceiling of 1,000 ft AGL or greater the accident rate would be reduced. Maybe if the FAA required a higher enroute altitude of say 500 ft AGL as opposed to the 300 ft now permitted, the accident rate would be reduced. Maybe if the FAA encouraged pilots to do the right thing instead of threatening them if they do, the accident rate would be reduced.

Another issue which I feel is extremely important with regard to EMS accidents is the pressure by the FAA. As you can see, I blame the FAA for a lot of problems since they are so much more concerned with job justification than they are with real safety issues in aviation. This shows very much in EMS flying. You have so many checklists that you need a checklist to ensure you have completed all your checklists. This is utterly ridiculous since all the checklists in the world won't keep pilots from making bad decisions, and won't cure bad technique. One of the most significant issues is the problem with flight into IMC, or inadvertent flight into IMC (IIMC). This is one of the most frequent accidents in EMS. The FAA, instead of encouraging pilots to do the right thing, and climb to safety, constantly threatens pilots who may encounter IIMC with a violation. This leads to pilots choosing to descend rather than climb which is the most dangerous thing to do; but when a pilot is faced with a violation for doing the most prudent thing, they sometimes make the wrong choice. I know of three pilots who have done this very thing in the past couple of years; one of them is dead as a result, and the other two just plain got lucky.

The FAA does not treat all operators the same; they have their pets in the industry, and it is usually the smaller operators, while the large operators are commonly nit-picked for every little thing. Of course they will deny this, its what they do best, but the news report below (of Sep 2010) proves that it is true. What is not known however is just how prevalent this issue is, it goes on at several other FSDO's as well but they have not been caught yet. Notice in paragraph three how the FAA has ensured that they are not linked to the accidents mentioned; do you really think they would admit it?

PITTSBURGH — The U.S. Office of Special Counsel says a Pittsburgh-based Federal Aviation Administration inspector was right when he claimed his office was lax in following up on safety problems - most involving a company that supplied emergency medical helicopters.

That company, C.J. Systems of West Mifflin, has since been sold and has surrendered its FAA repair certificate.

Tuesday's special counsel report says the company had 10 accidents involving five fatalities from November 2005 to November 2007. None of the safety problems overlooked during that time by the FAA's Allegheny Flight Standards District Office is linked to those crashes.

But investigators found the Pittsburgh whistleblower was right in claims including one that FAA officials overlooked temporary helicopter repairs made with improper parts and fudged logs to cover it up.

There is another significant issue (two-fold) especially with regard to EMS, but not exclusive to EMS. This factor is FAA and company management denial of what takes place in the field. I have attempted in many cases to address this, but the bottom line is simply that they are in such denial that nothing is ever done about it. I suppose that part of the reason is that there is such demand for helicopter up time, and for pilots, that it is easier to turn a blind eye to the situation than to do something about it. The unwritten rule is that the squeaky one will get fired at some point, so the only solution is to go along. Get someone to admit that!

The first case of importance is a maintenance issue. There is a tremendous amount of pencil whipping maintenance that goes on. Now everyone knows that aircraft break down, yet the number of pilot write-ups is very low; do you think this is because the aircraft don't break, or do think it is because pilots are under pressure to work with maintenance? Even more significant; everyone knows that it takes a certain amount of time to do a given inspection. When on paper, that inspection is completed in a fraction of the time required, guess what? It has been pencil whipped!! This is done all the time, but both the companies and the FAA are in denial about it. Now this could be easily tracked, but no one is going to do that when the people who write the checks demand up-time. The FAA don't give a rats ass as long as they get to go home by 1600 and their job has been justified by some simple means.

The other issue in the field is pilots playing around. If you take the most challenging job and put irresponsible pilots at the helm, guess what? Your risk goes way up. I have listened to numerous conversations by crew talking about the playing around that some pilots do. Sometimes when I hear the stories, it really alarms me. For example, I was listening to crew talking about a particular pilot who continues to do low-g pushovers in a Bell 206L because he likes to hear the nurse scream in the process. They described it as the pilot lowering the collective while pushing the cyclic forward diving the helicopter until they come out of the seat, then a nose high attitude that makes them feel like they are flying backwards. The same pilot likes to put the aircraft out of trim for a rapid descent, you know, what is called a slip in an airplane. What does low-g lead to? What rotorcraft flight manual approves an out of trim rapid descent? Sooner or later this pilot will hurt or kill someone. But guess what? he is still flying EMS, and no one gives a rats ass about how he plays in the field.

The majority of pilots are good responsible individuals, it is the few who do not abide by the rules and conduct themselves unprofessionally that gives everyone else a bad name. It is the willingness of company management and the FAA to deny and ignore such issues rather than address them simply because that is the easy thing to do. I can assure you it is much easier for the FAA to harass pilots and mechanics for easy items like the things mentioned in the final paragraph below than it is to really address the issues that matter most.

It is ridiculous for VFR aircraft to have an en route altitude of 300 feet AGL permissible, and a flight visibility minimum of 3-miles and in many cases much less. Imagine that at 3-miles visibility, even the slowest EMS helicopters, if they did not see each other at 3-miles on a converging course, could collide in 51 seconds or less. Two of the faster helicopters could collide in 36 seconds or less. Me, I won't fly with 3-miles visibility even though it is permitted, but I would use that visibility to get safely on the ground.

I can tell you one thing for sure; the FAA inspectors going around harassing pilots and mechanics about petty issues such as the wording in sign-offs and write-ups, the completion of fire extinguisher inspection dates, the clarity of signatures on airworthiness cards, whether or not the fuel hose is to close to the pad, Whether or not the pilot has sumped the fuel tank and completed the fuel farm checklist, whether or not the mountain of other hitch change, shift change, crew briefing, and other checklists are completed on a daily basis is not what is going to reduce HEMS accidents.

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Last modified: 12/31/2011