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December 2010

APSA Safety First Program Newsletter

On October 28, 2010, the FAA issued a Notice of Proposed Rule Making (NPRM) for Helicopter Emergency Medical Service operators. The proposed standards provide good guidance for law enforcement due to the similarities of HEMS and law enforcement operations.

The only section of the NPRM that is applicable to law enforcement is CFR 91.155, for operating in Class G airspace, 1,200 AGL and below, the clearance required goes from "clear of clouds" to one-half mile during the day and one mile at night. I agree with the FAA's proposed change. On page 75, the FAA explains the reason for the rule is that the current rule does not provide an adequate margin of safety. The number of accidents in low-visibility conditions speaks for itself.

We should ask ourselves - Do we have a problem? Answer, Yes. Second question - Are encounters with low-visibility conditions the cause of most HEMS fatal accidents? Answer, Yes. Studies show that one of the reasons high-time pilots have serious, often fatal, accidents is because their skills and experience can lull them into thinking it's OK to operate at the edge of the safety envelope. Most often nothing happens; so we think it's OK, when it's not. When high-time pilots overly rely on experience rather than safety, even small mistakes can result in an accident because there is no margin for error. That is exactly the purpose of the NPRM. And, that's exactly what gets our people killed.

As a former air operations manager, I fully expect that when a crew finds themselves in a situation that has unacceptably high risk, they should abort. Unfortunately, the closer you get to the scene, the more difficult it is to turn around. That's why policy makers need to have standards that have at least some margin for error. Standards are there to help protect people.

Six people have been killed in law enforcement accidents scud running in the last 2 years. Anyone that's flown in one-half mile visibility knows one can hardly see anything. Poor visibility is almost always accompanied with low ceilings. The combination of low visibility and mission complexity, i.e. high-risk rescues over water or mountainous terrain or landing in confined areas, puts any credible risk assessment model in the red zone. Low visibility is a killer. We need to stop trying to find reasons to accept inordinately high risk in the name of saving a life. The pre-departure risk assessment is the time to do a thorough risk assessment, not when you have almost arrived at the scene in unacceptable weather. Aborting at this point can be difficult, but it just might save your life. Encountering IIMC is fatal 80 percent of the time.

The clear of clouds rule can lead to bad decisions where we think we can fly in any weather, when we should not. That's why we need standards for "go and no go." It takes the pressure off of managers and pilots to get the mission done, no matter what the risk. It is this thinking that results in so many commercial HEMS accidents. The only difference between them and us - They are motivated by the money; we're motivated by saving a life and protecting officers on the ground and the public. Both will get you killed. Neither justifies getting our people killed. "We must change the perception that the mission is most important no matter what the risk." And this is what having an SMS is all about. It's a systematic way of identifying and managing risk to an acceptable level. You have reasonable standards, train to the standards, manage and supervise, including having a good pre-departure risk assessment, and hold people accountable, especially the leaders and supervisors. We cannot save victims or patients, but we can save ourselves by having and complying with good standards. Einstein said, "It's insane to think that doing the same thing over and over will have a different result."

Please share your thoughts on the weather standards.

Keith Johnson
APSA Safety Program Manager