France’s civil aviation authority, the DGAC, has approved the idea of training medical personnel to serve as the HEMS “technical crewmembers” required by the EASA’s IR-OPS regulation. Beginning October 8, a technical crewmember will be required on some HEMS flights that thus far have been conducted by a single pilot. Operators’ reactions vary from wariness to strong support, but one pilot union vigorously opposes the move.
With the exception of search-and-rescue missions, the new rules will require a second set of eyes up front when the helicopter is flying to an unprepared site in day VFR to pick up a patient. On the assumptions that hospitals would deem the additional cost of a second pilot to be excessive and that the extra weight would cut into the aircraft’s useful load, AFHSH, the lobbying association for French doctors using HEMS, issued a motion last year calling for the second flight crewmember to be a trained physician or nurse. At the association’s annual assembly this year, a senior representative of the DGAC gave the AFHSH idea the agency’s blessing in principle, on the understanding that the authority must approve the training program. The technical crewmember must help the pilot avoid other air traffic and obstacles and help select the landing site.
Inaer France (part of Avincis), a company that was recently awarded multi-year contracts by several groups of French hospitals, supports the plan. “We are already devising a three-day course with additional e-learning,” CEO Frédéric Goig told AIN. The course draws on those in other countries in which Inaer provides HEMS. In these countries, however, the paramedic who acts as a technical crewmember is employed by the operator. In France the medical professional will be employed by the hospital.
Inaer’s training program includes other aviation tasks listed in the EASA’s “acceptable means of compliance” document, including assistance with navigation, selecting radio frequencies, reading checklists, monitoring parameters and preparing the helicopter. The tasks extend to “assistance in the application of safety measures during ground operations with rotors turning, including crowd control, embarking passengers and refueling.”
The EASA document makes it clear that see-and-avoid and landing-site selection assistance are “primary” tasks that the technical crewmember should be able to perform, with only rare exception.
The controversy arises from the remainder of the assignment: from navigation assistance to refueling safety, tasks pilot union SNPNAC wants the technical crewmember to perform. Nicolas Letellier, president of the AFHSH, disagrees and suggests helping with see-and-avoid and selecting a landing site is sufficient. Asked for clarification, the EASA deferred to the DGAC. “An operator has the privilege to introduce an alternative means of compliance; this must demonstrate a similar safety level and must be approved by the competent authority,” an EASA spokesman told AIN.
SNPNAC representative Jean Bec rejects the entire concept of placing a part-time aviation person in the copilot seat. “You can’t be proficient in both medicine and aviation,” he said. He raised the question of whether, in the trial following an accident, a court would support the arrangement. “Can someone reasonably act as a crewmember in charge of flight safety on the outbound leg and take care of the patient on the inbound leg?” he asked rhetorically.
He even challenged the legitimacy of the AFHSH. However, no other organization has suggested any other means of compliance that would be palatable to hospital business administrators.
As a member of the French council of crews, the SNPNAC is permitted to submit bills to the ministry of transport. Bec intends to use this privilege to seek stricter enforcement of the IR-OPS regulation. Ultimately, HEMS pilots could go on strike, he warned.
Another pilot organization has a more conciliatory approach. Mathieu Vandenavenne, president of the French HEMS pilot association (ANSMUH), attaches less importance to the origin of the technical crewmember as long as he or she is properly trained. He also wonders where liability will rest since the technical crewmember assisting the pilot will be on the hospital’s payroll rather than that of the helicopter operator.
The ANSMUH’s view is aligned with that of major HEMS operators in France. According to a source familiar with SAF Hélicoptères and Mont-Blanc Hélicoptères, while those two operators do not oppose the AFHSH’s idea they are uncomfortable about liability and want to see their concerns addressed and clarified. For example, an operator will have no oversight on the technical crewmember’s rest periods. The operators also do not want to irritate pilot unions, the source said.
NHV, a Belgium-based HEMS operator that flies for several French hospitals, has been operating with a dedicated technical crewmember for years and it does not seem concerned with cost, Letellier noted.