NTSB blames Part 91 for deadly EMS helo crashes
On January 25 the NTSB Office of Aviation Safety presented a special investigation report on EMS and helicopter EMS (HEMS) operations, attributing a number of EMS accidents to the safety deficiencies allegedly inherent in the less stringent Part 91 rules, which are in place when no patients or organs are on board. The agency invested 3,500 man hours investigating the 55 most recent accidents, 35 of which occurred without patients aboard.
The Board recommended that the FAA require all EMS operators to comply with Part 135 during flights with medical personnel on board, regardless of whether the flight is carrying passengers, patients or organs. The NTSB said that the medical personnel make “minimal contribution” to flight, so Part 91 is not justified.
The Board also called for requirements to develop and train crews in a flight-risk evaluation program; to use formalized dispatch and flight-following procedures with current weather; and to install TAWS.
About 650 EMS helicopters operate under Part 135. Between 1995 and 2004, the number of accidents doubled, with 83 since 1998. Main causes are controlled flight into terrain (CFIT), inadvertent operation into IMC and spatial disorientation or lack of situational awareness at night.
Of the 55 accidents reviewed, NTSB staff selected five helicopter and two fixed-wing accidents typical of “systemic safety issues” to highlight at the January meeting. Each involved fatalities as a result of CFIT during low visibility. Some of the accident flights were Part 91 repositioning flights, while several were Part 135 at the time of the collision. No formal flight-risk evaluation program was in place; TAWS was not installed; and the crew was tasked with the decision to launch because there was no aviation-specific dispatch.
Renewing Safety Commitment
In August 2004 the FAA sought to improve the HEMS safety culture, and has not ruled out regulation, but before the NTSB’s recommendation had simply asked for enhanced training, encouraged new equipment and clarified its oversight. Last year, after meeting with the Association of Air Medical Services, HAI and the National EMS Pilots Association, the FAA issued three notices for operational guidance and risk assessment, and two manuals toward stricter VFR minimums, to reduce CFIT, to review pilot and mechanic decision skills, adhere to procedure and to improve crew resource management.
In the last decade, the FAA approved 15 of 28 STC applications for night vision enhancement systems, which average $7,000 for each of the several units required per helicopter, as well as the cost of training.
Flight data recorders are not required for HEMS, though the FAA has solicited research to reduce their weight and cost and to set a standard for survivability given the lower speeds and altitudes.
Since last September the FAA has examined the operations specifications for EMS VFR minimums, but the accepted level of lighting for night operations has yet to be identified.
A new International Helicopter Safety Team consisting of the FAA, EASA, Transport Canada and ICAO aims to reduce accidents 80 percent by 2015. Last month the FAA Flight Standards Service formed a task group to focus on the largest operators.
Mark Rosenker, acting chairman of the NTSB, asked if the FAA had studied whether the degree of medical urgency and competition for revenue affected an operator’s risk assessment and the decision to fly. John Clark, NTSB director of the office of aviation safety, responded. “We have enough trouble thinking like pilots and engineers, let alone thinking like doctors.”
1. Require all EMS operators to comply with Part 135 operations specifications during the conduct of all flights with medical personnel on board.
The Board concluded that the contribution of medical personnel to a safe flight was not sufficient to justify positioning flights under Part 91. The new regulation would eliminate Part 91 operation even when no patients or organs are being carried and mandate stricter limits on crew rest time and weather minimums.
2. Require EMS operators to develop and implement flight-risk evaluation programs that include training all employees involved, procedures to support the systematic evaluation of flight risks and consultation with others trained in EMS operations if the risks reach a predefined level.
Any regulation would likely begin with language issued in Notice N8000.301
in August 2005, “Operational Risk Assessment Programs for Helicopter Emergency Medical Services.”
3. Require the use of formalized dispatch and flight-following procedures that include up-to-date weather information and assistance in flight-risk assessment decisions.
None of the operators in the 55 accidents the NTSB studied had such a
program. Most EMS missions were dispatched by local 911 or hospital staff without aviation expertise. Language in the new regulation would begin with the conversion of at least two 1991 Advisory Circulars into requirements: AC 135-14A, “Emergency Medical Services/Helicopter,” and AC 135-15.
4. Require EMS operators to install terrain awareness and warning systems on their aircraft and to provide adequate training to flight crews. The Board concluded that in 17 of the 55 accidents studied, TAWS might have helped the pilots to avoid terrain.
The Board also concluded that some EMS operators were using night vision enhancement systems effectively in appropriate conditions, but did not recommend that they be required, because the units are not always feasible near dense population centers with strong ambient light