Proposal for Standards by Bill Roy The following is a proposal submitted by NEMSPA member Bill Roy f r o m St. Vincent Life Fb'ght in To/edc~ Ohia Mr. Roy has over seven years o f E M S experience and prior to that f l e w helicopters offshore in the North Sea. Because o f the impressive credentials and experience o f Mr. ROY, his proposal should carry considerable weight when flnah'zing the NEA4SPA pilot and aircraft standards. I4~ are publishing Mr. Roy's proposal f o r two reasons" because o f the narrative which helps explain how he arrived at his conelusio~ and to stimulate interest and hot~eful/y some feedback on these recommendations.. We would like to thank Mr. Roy f o r the time and effort p u t forth on this proposal, and solicit comments either pro or con. - N E M S P A During the past winter, the number of major accidents and fatalities that have occurred will suggest to even the most complacent in the helicopter EMS industry that serious, well-thought out steps must be taken to radically improve the objective conditions under which these flight operations will be conducted in the future. The flying environment in which these operations routinely take place is the most demanding in the entire field of aviation. Whereas military aviation, arguably a most demanding flying environment, roqtinely prescribes dual-piloted, fully instrument flight capable aircraft, the U.S. helicopter EMS industry has, over the past ten years evolved, dependent upon the flying skills of pilots, to do without these and other aids to safety. Clearly, in the light of the extraordinarily high accident rate in this industry, these skills have been insufficient, even though of a very high caliber. Very few of the accidents in the history of this industry have been due to mechanical causes. Pilot error has been the cause to an overwhelming degree. Some eighty percent of these accidents have occurred at night in marginal weather conditions. A pilot on duty at a hospital is virtually alone in making decisions to go on a mission or not, and whether to turn back when he meets with conditions affecting safety of flight. Too often these decisions are made on a case-by-case basis and are based upon subjective criteria of the moment. In most operations, the pilot performs a 24-hour duty period. When he is called for a flight, he typically has a goal of five minutes to be airborne (this oftentimes means from sleeping to flying within that
period). The decisions to be made concerning fuel requirements, route familiarization and, not least, reported and forecast weather, place a very serious stress on the pilot, in conjunction with the stress implicit in the fact that his decision may well make the difference for a seriously ill or injured patient. The pilot in such an environment will feel subtly powerful pressures to perform. His medical crew will make unspoken (and sometimes only too loudly spoken) requirements of him, and his judgment as to flight safety may be impaired, along with the contemporaneous impairment of his physical reaction times and his ability to make quality instant judgments. The airline pilot, on the other hand, possesses an institutional complement of aids and absolute standards to help him in achieving a high degree of flight safety. He operates in a controlled aviation environment; his flight planning is standardized; his weather briefing is comprehensive and definitive for his decision to take the flight; he has the benefit of the assistance and advice of a co-pilot and often that of a flight engineer; he flies a planned route and is followed, usually on radar, by concerned, well-trained ground personnel; if his passengers do not reach their destination immediately, their lives or health are not impaired; he has no institution nor medical flight crew to criticize his decisions-even implicitly. Anyone knowledgeable in the field of aviation will wonder how it is that these very experienced pilots will have acceded to such conditions. It is undoubtedly true that these pilots have, through a combination of self-confidence in their flying abilities and professional judgment, and the economic and institutional facts of the growth of this industry, found themselves personally and professionally locked into a situation which they could never have consciously chosen nor condoned. Their choice heretofore has been to accept these conditions or quit the work that is their livelihood. Such a knowledgeable person will also wonder how it is that this new and recently quite large industry (one hundred+ hospital-based programs comprising over one hundred modern aircraft and 350 professional pilots) can be so bereft of safety standards as to permit some 40 deaths of flight personnel between the years 1980 and 1985. We can
say with confidence that this condition exists and persists because there is no industry standard for flight safety. Heretofore there has been a hiatus as between the business/commercial aspects of this industry and the question of safety. Hospitals planning to enter the field of hospital-based helicopter EMS operations have relied upon the aviation vendors who would supply them with aircraft, pilots, mechanics and backup support. These aviation companies, while not unconcerned with the question of aviation safety, have always assured their erstwhile customers that they have excellent safety records and that their pilots and mechanics can assure that those records will continue safe. But the pressure to obtain contracts on the part of aviation vendors and the pressure on hospital institutions to achieve a helicopter EMS program at the lowest cost, while understandable from a business standpoint, are inherently inimical to considerations of flying safety. In the end, now as always in this industry, the question of safety has fallen to the level of the lowest financial common denominator. It is the considered opinion of all in the National EMS Pilots Association (NEMSPA) that this conflict must be resolved for the benefit of all concerned. It is perhaps not possible under the pressure of commercial and financial considerations, which are proper for commercial interests such as aviation vendors and hospital institutions, that questions of the greatest urgency concerning aviation safety will be given sufficient consideration. Recent history in this industry gives force to such an argument. We of the National EMS Pilot Association believe that there must be a voice for flight safety in this industry; one that is separate from commercial considerations. This association was formed, belatedly, from among the professional helicopter EMS pilots, all within the year 1985. We now are represented in 75 % of hospital-based helicopter EMS programs; our membership comprises 60% of these pilots at the present moment. It is the professed task of this association of pilots to very significantly improve the safety of our chosen field of aviation. It will be appreciated that we have a significant and most reasonable interest in such a goal. We do realize that safety of flight and financial/commercial interests
AirNet is the official voice of the National EMS Pilots Association, published within each issue of Hospital Aviation. Opinions expressed herein do not necessarily represent those of the publisher. 16
HOSPITALAVIATION, MAY 1986
must be integrated; but we believe, not without cause, that the former has had short shrift. It is our announced intention and task to provide remedy for this condition. It should at the outset be understood that this task is undertaken IN O R D E R to preserve the viability of this industry. We have come to know that the insurability of helicopter EMS operations is at risk. We have also come to know that we cannot personally and professionally condone any longer an unregulated aviation industry in which so m a n y - n o t only ourselves, but the injured whom we transport and the highly trained medical crews who are dependent upon u s - a r e at risk. We believe that it is time that we presented ourselves as the agency for reform and improvement. We cannot, in the light of the history of this industry, decide to depend for improvement upon any other body associated with this industry. No one else associated with this industry either will or can decide upon the question of helicopter EMS safety questions. Our interest is safety; for we suffer, along with some others, from the lack of i t - a s must be obvious. But, while others may suffer with us, they can provide no sensible possibilities for resolution of the problem. No nurse or doctor, no hospital administrator, can pronounce effectively upon this question of aviation safety. Also, it is our considered opinion that aviation companies, vendors, who obtain commercial contracts in this industry cannot, owing to the business pressures to which they must invariably respond in order to be in business, be the repositories for considerations of aviation safety. In a like way, owing both to their commercial requirements and to their lack of expertise in aviation matters, the hospital institutions cannot be relied upon to be such a repository. We understand that there must be a recognized professional body so constituted as to exercise some influence over matters of aviation safety in this industry. We take this to be our writ. What follows is our carefully considered recommendation, to any who will listen, concerning the way for improving substantially and observably the safety conditions and the safety record within the helicopter EMS industry. The following are the recommendations of the National EMS Pilot's Association members for the radical improvement in aviation safety standards in the industry: Type of aircraft Twin-engine helicopters must be the standard. While it is true that most EMS helicopter accidents are encountered enroute, it is generally considered (by those who know best) that the greatest danger to
be encountered by the EMS pilot is during takeoff and landing. This is because these flight evolutions take place in conditions of vertical flight when the loss of an engine will place the pilot in that position from which his expertise will least benefit him. It is commonplace among our pilots that the situation they fear most to be placed in is that of powerless flight at altitude over a severely restricted landing or takeoff area; from which situation there are only the most dire results to be expected. Twin-engine helicopters give enormously improved possibilities for reasonable recoveries to both persons and aircraft.
Equipment on aircraft EMS helicopters should have full instrumentation and, at the least, some system of stability augmentation so that they may reasonably be flown in the condition of inadvertent IMC. It is most desireable that these machines should be equipped with full autopilot s y s t e m s - a s is universally recommended for single-pilot operations where IMC conditions are obtained. Because the great majority of catastrophic helicopter EMS accidents have occurred in conditions of darkness and marginal weather, the need for some standard of flight stabilization equipment cannot be ignored. When the EMS pilot
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finds himself alone in these conditions and, contrary to his flight planned expectations, inadvertently in instrument weather, quite without visual reference, he has entered a realm of flight to which he and his equipment are not equal. Th e problem for this pilot is one of a decision as to whether he will attempt to maintain visual contact or decide immediately and without professional concern to enter instrument flight. In this industry, as it is now constituted, virtually all pilots will, if only for intuitive reasons, decide for the course of maintaining ground contact (VFR). The pilot knows that his machine is not equipped for IFR flight and that he is not current in IFR procedures and training. His "gut" reaction at the significant moment will be to cling to that regime of flight in which he is most comfortable. There are conditions of weather and lack of pilot training wherein disaster will too often result if reasonable flight standards are not maintained. What is wanted in this most demanding field of the aviation industry are professional standards of equipment, of pilot proficiency and of minimum weather conditions beyond which the pilot knows he may not g o - - s o that the implicit pressures on his decision-making are radically reduced. The balance between personal safety and business viability and the institutional pressures to perform must be clearly established. (The public, provisional evidence stemming from the investigations of the President's Commission on the "shuttle disaster" indicate a parallel need for the establishment of such a balance, and are a good model of the argument we advance here for changes in the operations of this helicopter EMS industry.)
Pilot standards It is uniformly the case in the helicopter EMS industry that for every three pilots there will be not less than five nurses. But the situation is that on each flight there is one pilot and one nurse. It will pass the understanding of any dispassionate observer how this can reasonably be. The nurse, as the result of national standards, cannot be required to observe a 24-hour schedule as do the EMS pilots. The EMS pilot is on duty for 240 hours in any 30 days. If, as is only too common, he works with only one other pilot to serve a single aircraft, he will be on duty for, literally, one-half the hours in one month. The significant factor here is that the pilot is the one on whom lives actually depend, of which his is one. His working conditions are the least considered-either by his "vendor," for whom he conditionally works, or by the hospital institution, for which he actually works. No nurse or doctor who is a member of the medical "crew" of an EMS flight must 18
HOSPITALAVIATION, MAY 1986
at the outset of that flight be at his/her utmost of professional and personal capacity; but the pilot must be so absolutely. It is this question of crew complement that the pilots of our association feel is at the root of the problem. We believe that a 12-hour duty period should be the standard of this industry for pilots (in this we do not ask even for parity with nurses, never mind with doctors). And this means that this cannot be done with the existing number of pilots per aircraft. It is our considered opinion that not less than four pilots per aircraft can be the minimum in this industry. At present it is the growing tendency to employ three pilots per aircraft. But this will not suffice. No pilot in the EMS industry should serve more than a 12-hour duty p e r i o d - f o r reasons of safety. If there are some persons who think that these operations can reasonably be done with two or three pilots, then they must be apprised of the data that have come from recent academic studies concerning just these conditions of over-scheduling of persons in arduous and technically demanding specialties. The realities of the accident rate and fatality rate among hospital helicopter EMS operations are an indication not of the impossibility of such operations, but of the utter failure of professional and management personnel who have been involved historically in these endeavors to seriously consider the question of flight safety P R I O R TO commercial considerations. The desire of hospital institutions to keep costs low and of aviation operators to compete for contracts in the EMS industry cannot take precedence over safety of flight. This helicopter EMS industry has grown very rapidly in the past five years. Possibly this is why we now see that its rate of catastrophic accidents has become unconscionable and a matter of the most serious commercial concern. These accidents are the proximate result of the judgments of pilots. There can be no other conclusion. If, however, we are to make some changes in the objective conditions from which pilot decisions are to be made, then we must have standards to which pilots are held. And these must be institutional standards imposed upon the pilot, so that be may not feel himself at the mercy of so many influences-as they have obtained in the past. The experience of the pilots who initiated this industry was that of military s e r v i c e - a n d specifically the war in Viet Nam. There can be no doubt that these w e r e - a n d a r e - a m o n g the finest pilots in the world, those who remain. Many of those same initial EMS pilots are still to be found in this industry. But now, with the rapid expansion of this industry, there has come the requirement for more pilots.
We have said that this is a more demanding field of aviation than any other, short of actual warfare. Who will be the pilots who can reasonably fulfill the arduous requirements of this EMS industry? Vendors will offer pilots to contracting hospitals; but will these pilots always be able to consistently and safely complete the requirements of the EMS environment? And, if they are not, will they attempt to do so anyway? It is the intention and goal of the National EMS Pilots Association to espouse and work for standards which will make safety in this industry an achievable goal. We believe new pilots hired to fly EMS should be given training that exceeds that now provided by the EMS operators. Some operators will have high standards and others, often under the pressure of contractual requirement, will give short shrift to this vital element of flight safety. We propose to work with the insurance industry, with operators and with hospital institutions to standardize such training.
Minimum objectives The M I N I M U M objective factors which should be present for safe EMS operations are these: 1. Four pilots serving 12-hour duty p e r i o d s - w i t h a mandatory ratio of one day off duty for every half-day worked. 2. Night weather minima outside of metropolitan areas of 1000 ft. ceiling and 3 miles visibility. 3. A system of stability augmentation for all night flights that is certified for single-pilot IFR. 4. Lacking stability augmentation, night flights must be flown by two pilots. 5. Four thousand hours total helicopter flying time. More than aircraft handling proficiency is demanded in EMS flying; a well-developed judgment in operational decision-making, based upon long and varied experience, is necessary as well. 6. The EMS pilot must be licensed and recurrently trained in instrument flight procedures. These standards are the minimum that the U.S. public has a right to e x p e c t - a n d does expect and get in other types of flight operations licensed to serve the public. It is no longer possible to continue in this industry as before, Positive, progressive steps must be taken very soon to gain the upper hand in safety of flight. The National EMS Pilots Association stands ready to serve as consultant to the industry in matters of safety Standardization. All concerned, the public not least, will benefit from our concern for professional standards.