NEMSPA Opportunity to Improve

Transcription

1 Opportunity to Improve correlated with Recommendations for HEMS Safety Introduction In February of this year, the (National Transportation Safety Board) met with representatives of professional associations and other interested authorities and stake holders of the air medical transport industry. The topic of this historic hearing was the safety of Helicopter EMS (HEMS) operations and the disturbing upward trend in apparent human error accidents during the 14 months preceding the hearing. The National EMS Pilots Association () was represented at the hearing by five members of the Board of Directors. In preparation for the deliberations that took place, had submitted to the a detailed statement entitled An Opportunity to Improve. The document identified, from the pilot s perspective, the problems affecting HEMS safety and included recommendations for safety enhancements. During the first week of September, 2009, after months of processing both the verbal testimony and the written documents submitted, the issued their initial list of 21 recommendations directed to the FAA, to HEMS providers, and to other entities involved with the nationwide air medical transport system. leadership hesitates to claim any undue credit for the influence of their participation on the outcome of the hearing. The recommendations made by the were likely influenced most by those recommendations that were common to a number of the documents provided by industry experts. Even so, is encouraged by the overall correlation of the recommendations with the substance of s submission to the hearing. In the summary that follows, the checkmark indicates that a particular recommendation was included as one of NEMPA s Top 10 recommendations in the document An Opportunity to Improve. September 2009 Page 1 of 5

2 Opportunity to Improve correlated with Recommendations for HEMS Safety Pilot Training SMS 1. Pilots receive more comprehensive initial, recurrent and transition flight and ground training that is specific to HEMS operations. 2. Mandate Scenario Based (LOFT) Training: LOFT (Line Oriented Flight Training) training should be incorporated into all phases of HEMS operations, including a requirement for training scenarios which will require pilots and medical crews to make decisions regarding all aspects of a HEMS flight. 3. Increase in oversight from FAA Principal Operations Inspectors to insure quality training design and implementation. 4. FAA Principal Operations Inspectors should receive training specific to EMS operations. 5. Pilots receive, at least on an annual basis, training in an appropriate flight simulator or FTD (Flight Training Device). It continues to be a common theme in this notice that the pilot needs to see him/herself as part of a system that extends beyond his role in the cockpit. Pilots must understand and participate in the overall system of safety assurance that each HEMS provider must implement in their organization. RECOMMENDATION #1: Develop criteria for scenario based helicopter emergency medical services (HEMS) pilot training that includes inadvertent flight into instrument meteorological conditions and hazards unique to HEMS operations, and determine how frequently this training is required to ensure proficiency. RECOMMENDATION #2: Once the actions recommended in Safety Recommendation (1) are completed, require helicopter emergency medical services pilots to undergo periodic FAA approved scenario based simulator training, including training that makes use of simulators or flight training devices. RECOMMENDATION #3: Require helicopter emergency medical services operators to implement a safety management system program that includes sound risk management practices. FDR and FOQA 1. Develop a standard EMS aircraft minimum equipment list. The EMS MEL/MMEL would be used regardless of type of operation (VFR/IFR) or airframe (single or multi engine), and would be based on the mission profile of the operation. 2. Include in the list described above the following items: HTAWS TCAS Flight recording devices Another blossoming initiative resulting from this technology is the possible use of these devices in FAA approved FOQA programs as part of a safety management system in conjunction with Just Culture. RECOMMENDATION #4: Require helicopter emergency medical services operators to install flight data recording devices and establish a structured flight data monitoring program that reviews all available data sources to identify deviations from established norms and procedures and other potential safety issues. Indicates Opportunity to Improve Recommendation September 2009 Page 2 of 5

3 Opportunity to Improve correlated with Recommendations for HEMS Safety Data Weather Reporting Although not included in s Top 10, fully supports the collection and analysis of statistics regarding flight activity in the HEMS industry. This data may provide insight into the use and abuse of air medical resources and is essential to the accurate determination of the effectiveness of the safety management strategies that have been, or may be implemented. The need for optimal decisions regarding weather in HEMS operations is a given... The HEMS pilot community has warmly received the ADDS HEMS Weather Tool, but problems with generating accurate interpolations of weather due to spotty coverage restrict the use of that tool so that it can only be used to support a No Go decision. Recommendations are made for enhancement of that system. We also feel that the potential for the future development of the ADS B system is worthy of consideration. RECOMMENDATION #5: Require helicopter emergency medical services operators to report activity on at least an annual basis to include total hours flown, revenue flight hours flown, revenue miles flown, patient transports completed, and number of departures. RECOMMENDATION #6: Permit the helicopter emergency medical services Aviation Digital Data Service Weather Tool to be used by helicopter emergency medical services operators as an official weather product. RECOMMENDATION #7: Conduct a systematic evaluation and issue a report on the requirements necessary for a viable low altitude airspace infrastructure that can accommodate safe helicopter emergency medical services (HEMS) operations. The evaluation should consider improved collection and dissemination of weather data, the role of automatic dependent surveillance broadcast, approaches to helipad and designated landing zones, and integration into the National Airspace System. Include in the evaluation process HEMS operators, related industry associations, and hospitals, among others. RECOMMENDATION #8: Once the evaluation and report as recommended in Safety Recommendation (7) are completed, initiate action to develop this infrastructure. Indicates Opportunity to Improve Recommendation September 2009 Page 3 of 5

4 Opportunity to Improve correlated with Recommendations for HEMS Safety NVG In May of 2008, conducted a survey of HEMS pilots to collect their opinions regarding the utility of NVG s for night HEMS operations. The pilots who responded to the survey were nearly universal in their support of this technology. If fact, it was interesting to note that the only respondents who expressed reservations about the effectiveness of night vision aids were a few pilots who had no experience at all flying with NVG s. Note that while has always been a strong proponent of NVG use, it is unclear how beneficial other NVIS (Night Vision Imaging Systems) technologies might be in a HEMS environment. urges caution in classifying such technology as equivalent to NVGs as safety enhancements for night HEMS operations. RECOMMENDATION #9: Require helicopter emergency medical services operators to install night vision imaging systems and require pilots to be trained in their use during night operations. (#1 in the Top 10) Autopilot Public Include in the [Minimum Equipment List] the following items: HTAWS TCAS Flight recording devices Global Positioning System (GPS) with moving map AFCS/SAS/Force Trim/ or Autopilot: EMS aircraft should be equipped with some type of stabilization system to reduce pilot workload, pilot fatigue, and to allow the pilot to perform other hands off activities. Previously listed. RECOMMENDATION #10: Require helicopters that are used in emergency medical services transportation to be equipped with autopilots, and that the pilots be trained to use the autopilot if a second pilot is not available. (T 10) RECOMMENDATIONS #11 #15: The five recommendations made by the in this category all correspond with recommendations made to the FAA in the previous section. All 5 are included in s Top 10 as submitted to the prior to the hearing. Indicates Opportunity to Improve Recommendation September 2009 Page 4 of 5

5 Opportunity to Improve correlated with Recommendations for HEMS Safety FICEMS Medicare These recommendations to the Federal Interagency Committee on Emergency Medical Services (FICEMS) address issues that are somewhat outside of the primary area of focus of. Even so, we believe that care must be taken at the federal level to avoid establishing mandates that would best be made at the state level where local resources and needs are best understood. Guidelines or regulations established at the federal level should be general in nature and should address primarily those aspects of air medical operations that are clearly essential for the safe and ethical conduct of all air medical providers. Furthermore FICEMS would benefit in such an endeavor by consulting with the appropriate professional associations within the air medical industry. Issues pertaining specifically to aviation operations should be deferred to the FAA for action. The issue of performance based reimbursement was addressed only indirectly in the submission to the. It has a relationship to s recommendations regarding the minimum equipment that should be installed on HEMS aircraft. In addition to the autopilot and other systems listed above, and although night vision goggles are not an aircraft component, per se, they would clearly fall within the intent of this recommendation, which is to recognize operators that spend additional capital on equipment and training to enhance safety, and to compensate such providers accordingly. generally supports this concept. Recommendations to FICEMS: 1. Develop national guidelines for the use and availability of helicopter emergency medical transport by regional, state, and local authorities during emergency medical response system planning. 2. Develop national guidelines for the selection of appropriate emergency transportation modes for urgent care. Recommendations to Department of Health and Human Services Centers for Medicare and Medicaid: 1. Evaluate your existing helicopter emergency medical services (HEMS) reimbursement rate structure to determine if reimbursement rates should differ according to the level of HEMS transport safety provided. 2. If the findings from the evaluation conducted in response to Safety Recommendation 1 reveal that higher levels of reimbursement are required to increase the level of safety, establish a new reimbursement rate structure that considers the level of helicopter emergency medical services transport safety that is required. The full list of the recommendations can be viewed on the internet at HEMS.htm. s submission to the hearing, An Opportunity to Improve can be reviewed and downloaded from the Web site at by clicking on the Publications tab and then selecting Position Papers. Indicates Opportunity to Improve Recommendation September 2009 Page 5 of 5