Par 1-6 Page 6 pp. Principal Maintenance Inspector (PMI). The PMI at the CHDO specifically responsible for aviation safety inspection and oversight of a HAA operator.
qq. Principal Operations Inspector (POI). The POI at the CHDO specifically responsible for aviation safety inspection and oversight of a HAA operator.
rr. Residual Risk. Residual risk is the safety risk that exists after all controls have been implemented or exhausted and verified (to ensure that the risk acceptance is in accordance with a pre-existing documented risk analysis procedure.)
ss. Response Scene. Unimproved ad hoc LZ sites and other off-airport and off-heliport site locations where HAA flight landings are authorized under the authority of OpSpec A021.
tt. Risk Analysis. A formal methodology for guiding HAA decisionmaking. Its procedures, principles and policies are documented and are the subject of training by HAA operators. They include multiple people with defined roles that have been documented and are the subject of training. As total risk exceeds the operator’s pre-determined threshold, approval at higher levels is required. (Refer to §§ 135.615 and 135.617(a)(5).)
uu. Risk Assessment. Risk assessment is a key element of the broader risk analysis. The two terms assessment and analysis should not be used interchangeably. Process documentation should identify risk factors the HAA operator may consider as part of risk assessment. The operator should assign to each risk factor an appropriate numerical value reflecting both the likelihood of occurrence and severity of outcome. Section 135.617 requires HAA operators to have an FAA approved and documented Risk Analysis Program that includes procedures for elevating the final post mitigation risk to a higher management level for approval when the total risk exceeds a predetermined threshold.
vv. Safety Management System (SMS). A SMS is a formal, top-down approach to managing safety risk. It is a system to manage safety, including the necessary organizational structures, accountabilities, policies and procedures. Implementing a SMS can provide useful tools to the HAA operator for complying with the requirements of § 135.617. Additional information and resources on SMS can be found in the current edition of AC 120-92, Safety Management Systems for Aviation Service Providers, and in Chapter 8 and Appendix B of this AC.
ww. Second in Command (SIC).
xx. Shoreline. Land adjacent to the water of an ocean, sea, lake, pond, river or tidal basin that is above the high-water mark at which a rotorcraft could be landed safely. This does not include land areas unsuitable for landing, such as vertical cliffs or land intermittently under water (refer to § 135.168). Additional information is available in 14 CFR part 136, § 136.1,
i.e., “suitable for landing area for helicopters.”
yy. Standard Operating Procedures (SOP). An established or prescribed method to be followed routinely for the performance of a designated operation or in a designated situation and is used to guide training to meet such contingencies.
Par 1-6 Page 7 zz. Suitable Offshore Heliport Structure. A heliport structure that can support the size and weight of the rotorcraft being operated where a safe landing can be made.
aaa. Supplemental Type Certificate (STC). A TC issued when an applicant has received approval to modify an aircraft from its original design.
bbb. Visual Flight Rules (VFR).
1-7. RELATED SOURCE MATERIAL. The following lists documents that are applicable to HAA operations.
a. ACs (current editions). ACs can be found on the FAA Web site at http://www.faa.gov/regulations_policies/advisory_circulars.
• AC 00-64, Air Medical Resource Management.
• AC 27-1, Certification of Normal Category Rotorcraft.
• AC 27-1B MG 6, Miscellaneous Guidance (MG) for Emergency Medical Service (EMS) Systems Installations.
• AC 29-2, Certification of Transport Category Rotorcraft.
• AC 91-21.1, Use of Portable Electronic Devices Aboard Aircraft.
• AC 91-32, Safety In and Around Helicopters.
• AC 120-27, Aircraft Weight and Balance Control.
• AC 120-49, Certification of Air Carriers.
• AC 120-51, Crew Resource Management Training.
• AC 120-92, Safety Management Systems (SMS).
• AC 120-96, Integration of Operation Control Centers into Helicopter Emergency Medical Services Operations.
• AC 135-5, Maintenance Program Approval for Carry-On Oxygen Equipment for Medical Purposes.
• AC 150/5390-2, Heliport Design.
• AC 150/5230-4, Aircraft Fuel Storage Handling Training and Dispensing on Airports.
b. Handbooks, Manuals, and Pamphlets (current editions). FAA handbooks can be found on the FAA Web site at http://www.faa.gov/regulations_policies/handbooks_manuals.
• FAA Order 8040.4, Safety Risk Management Policy.
• FAA-H-8083-21, Rotorcraft Flying Handbook.
• FAA-H-8261-1, Instrument Procedures Handbook.
• Airman’s Information Manual (AIM).
• DOT/FAA/PM-86/45, Aeronautical Decision Making for Helicopter Pilots.
• DOT/FAA/DS-88/7, Risk Management for Air Ambulance Helicopter Operators.
• FAA FAASTeam Library, Flying in Flat Light and White Out Conditions.
• National EMS Pilots Association (NEMSPA), Preparing a Landing Zone. NEMSPA is located in Layton, UT 84041-9128, telephone (877) 668-0430.
Par 1-7 Page 8
c. Other:
(1) Helicopter Association International (HAI). HAI is located at 1920 Ballenger Avenue, Alexandria, VA 22314-2898, telephone (703) 683-4646. Check their Web site for other documents and links to resources, including their Fly Neighborly Guide.
(2) The National Fire Protection Association (NFPA) is located at 1 Batterymarch Park, Quincy, MA 02169-7471, telephone (617) 770-3000. They have many publications about fire protection. The 400 series may be the most helpful. For example, the current edition of NFPA 418, Standard for Heliports, has fire standards for heliports.
(3) Air Ambulance Guidelines published by both the U.S. Department of Transportation (DOT), National Highway Traffic Administration; and the American Medical Association, Commission on Emergency Medical Services.
(4) The National Association of Air Medical Communications Specialists (NAACS) is located at PO Box 19240, Topeka, KS 66619, telephone (877) 396-2227. Check their Web site for links to resources, including training courses.
(5) Special Airworthiness Information Bulletin (SAIB) SW-10-43, Non-Aviation Transmitters. (Includes, for example, 800 megahertz (MHz) radios used to communicate with hospitals.)
(6) Policy Letter (PL) ASW-2001-01, Certification Guidelines for Compliance to the Requirements for Electro-Magnetic Compatibility (EMC) Testing.
(7) DOT/FAA/AR-99/50, High-Intensity Radiated Fields (HIRF) Risk Analysis.
(8) FAA Technical Standard Order (TSO)-C194, Helicopter Terrain Awareness and Warning System (HTAWS).
(9) International Civil Aviation Organization (ICAO) Doc 9977 AN/489, Manual on Civil Aviation Jet Fuel Supply.
(10) RTCA Inc., DO-160, Environmental Conditions and Test Procedures for Airborne Equipment.
(11) RTCA Inc., DO-178B, Software Considerations in Airborne Systems and Equipment Certification.
(12) RTCA Inc., DO-254, Design Assurance Guidance for Airborne Electronic Hardware.
(13) RTCA Inc., DO-309, Minimum Operational Performance Standards (MOPS) for Helicopter Terrain Awareness and Warning System (HTAWS) Airborne Equipment.
Par 1-7 Page 9
(14) OpSpecs:
• A005, Exemptions and Deviations.
• A008, Operational Control.
• A010, Aviation Weather Information.
• A021, Helicopter Air Ambulance Operations.
• A050, Helicopter Night Vision Goggle Operations (HNVGO).
• A061, Use of Electronic Flight Bag.
• A096, Actual Passenger and Baggage Weight Program for All Aircraft.
• A097, Small Cabin Aircraft Passenger and Baggage Weight Program.
• D085, Aircraft Listing.
1-8. BACKGROUND. This AC focusses on the requirements and challenges faced by HAA operations and how these can be addressed through application of best practices which, when tailored to local and operational requirements and the appropriate scope and complexity of each organization, provide one way of many possible ways to assure safety and compliance with regulatory requirements within a HAA operation.
a. General. The typical HAA operation provides 24-hour local or regional on-call service from an operational base or multiple operational bases. Each base is assigned one or more helicopters and is staffed by one or more pilots and mechanics. A base may also be staffed by medical crew members (paramedics, EMTs, doctors, and nurses). If not, the helicopter should reposition to a trauma center or other location where medical personnel are available for assignment to support operational requirements.
b. Operational Control. An HAA operator should be organized to ensure the challenges imposed by the need to perform HAA-specific training, operations, equipment installation and maintenance and documentation are adequately addressed. Operational control over the aircraft, pilots and flight operations should remain within the operator’s organization regardless of customer prioritization, inputs, tacit expectations and pressures.
c. HAA-Specific Equipment. HAA-specific equipment (such as HTAWS, Flight Data Monitoring System (FDMS), etc.) and training are required for HAA operations, starting on effective dates provided in the applicable regulations. Such equipment and training has been identified as beneficial for improvements in flight safety and operational efficiency.
d. Maintenance. Helicopters should be maintained and serviced with particular attention to scheduling and accomplishing major inspections and maintenance while recognizing and accommodating customer expectations. Problems are likely to arise if operators defer, then extend, required maintenance to meet operational availability requirements. While the importance of helicopter availability is recognized in the HAA best practices referred to in this AC, HAA operator management, along with a pervasive “safety culture,” should ensure that deferral of unscheduled repairs or replacements are not unduly extended to coincide with previously scheduled preventative maintenance or inspection requirements.
Par 1-8 Page 10
e. OCCs. Regulations require an OCC to be staffed by one or more OCS by those operators with 10 or more HAAs. The FAA strongly encourages similar steps by other operators.
Formal Risk Analysis (composed of risk assessment and mitigation processes, not previously required of HAA operations), must be implemented by all HAA operators per § 135.617.
Operator risk analysis programs should be well documented and consistently applied to avoid over-extending aircraft or pilot capabilities. Attempting to accomplish HAA operational objectives, in the absence of well thought-out and documented operational risk analysis procedures and training, can result in misplaced priorities, second-order effects, and unintended consequences and could result in poor judgment or decisionmaking.
f. Best Practices. Appropriate HAA industry experience and strong commitment to safe operations has been identified as a best practice of effective management personnel. In particular, effective action to assure flight safety by the director of operations, the chief pilot and the director of maintenance have been seen as essential to the best practices contributing to safe operations. Equally essential are policies and procedures emphasizing professionalism among all employees from the top down.
Par 2-1 Page 11 CHAPTER 2. CERTIFICATION AND HAA-SPECIFIC CONSIDERATIONS
2-1. GENERAL. A helicopter air ambulance (HAA), Title 14 of the Code of Federal Regulations (14 CFR) part 135 operation, as authorized through the issue of Operations Specification (OpSpec) A021, Helicopter Air Ambulance Operations, is unique among other types of part 135 helicopter operations. Organizational challenges are significant. This is reflected in the requirements for such operators under the certification process. Part 135 certificate holders conducting HAA operations are subject to requirements beyond those observed by other certificate holders.
2-2. INITIAL PART 135 CERTIFICATION WITH HAA AUTHORIZATION. Prospective helicopter operators desiring to offer HAA operations as an air carrier in accordance with part 135 should refer to the current edition of Advisory Circular (AC) 120-49, Certification of Air Carriers, for methods and procedures to follow in achieving certification. A Federal Aviation Administration (FAA) Web site with information on the certification process is:
http://www.faa.gov/licenses_certificates/airline_certification/
a. Certification Team (CT). The Flight Standards District Office (FSDO) located in the area where the applicant desires to locate its principal business office will assemble a CT. This CT will provide certification process guidance to the prospective certificate holder. It will evaluate the systems, procedures, training, and documentation (manuals, etc.) that the applicant has documented and submitted (or demonstrated) toward earning their air carrier certificate.
b. Additional Information. Further detail about authorization for HAA operations, in addition to achieving part 135 certification, is included in this AC chapter.
2-3. ADDING HAA AUTHORIZATION TO AN EXISTING PART 135 CERTIFICATE.
Existing part 135 certificate holders may perform HAA operations after providing training, meeting regulatory requirements, implementing appropriate procedures and installing equipment (described in subsequent chapters of this AC). Following an application for authority to perform HAA operations, supported by demonstrations of capability, the operator may be issued, by the FAA, the appropriate OpSpecs, including A021, Helicopter Air Ambulance Operations. The approving authority for the issuance of these OpSpecs will be the principal inspectors (PI) assigned to that certificate.
2-4. REGULATORY OPERATIONAL CONSIDERATIONS. HAA operators are subject to regulatory operational requirements above those associated with other part 135 operations. These are outlined in Chapter 3 of this AC. In addition, this AC will identify HAA industry best practices applicable to operational issues.
a. Part 135, § 135.603, Pilot Qualifications. Part 135 certificate holders conducting HAA operations are subject to pilot qualifications requirements in addition to those required of such certificate holders not engaged in such operations. Pilots employed in HAA operations must hold a rotary wing (RW) instrument rating or an airline transport pilot (ATP) certificate in accordance with § 135.603. This requirement becomes effective on April 24, 2017.
b. Section 135.609, Local Flying Area(s) (LFA) Familiarity Verifications. An examination of familiarity with a LFA is required to be completed and documented in a
Par 2-4 Page 12 12-month period before a pilot can use the lower weather minimums associated with the LFA.
This examination of familiarity with a LFA may be through other means than a flight check.
However, a record of all such examinations, regardless of format, must be retained for each pilot and each LFA assigned (refer to § 135.609). In this AC, see paragraph 3-5 for LFA operational considerations, paragraph 4-2 for LFA training implementation details, and paragraph 7-2 for LFA examination documentation requirements.
c. Sections 135.611 and 135.613, Instrument Flight Rules (IFR) Procedure Documentation. It is recommended that part 135 certificate holders conducting HAA IFR operations document procedures associated with point in space (PinS) approaches and associated Obstacle Departure Procedure (ODP). (Refer to §§ 135.611 and 135.613.)
d. Section 135.615, Visual Flight Rules (VFR) Flight Planning Documentation.
Procedures for VFR flight planning must be documented by part 135 certificate holders conducting HAA operations in accordance with the provisions of § 135.615.
e. Section 135.617, Preflight Risk Analysis. An FAA-approved preflight risk analysis program must be established by each HAA operator and documented in its operational manual (or other documentation). In accordance with the provisions of § 135.617(d), part 135 certificate holders conducting HAA operations are required to use and retain preflight risk analysis worksheets. Preflight risk analysis worksheets are completed by the pilot and are reviewed and confirmed by the Operations Control Specialists (OCS) in compliance with § 135.617 if applicable. These worksheets are retained for 90 days in compliance with §§ 135.617 and 135.619. The procedure itself is outlined in paragraph 3-4 and Appendix A, which also includes examples of preflight risk analysis worksheets.
2-5. TRAINING CONSIDERATIONS. HAA operators are subject to additional training requirements above those associated with other part 135 operations. These training requirements will be outlined in Chapter 4. In addition, this AC will identify HAA industry best practices applicable to training, including providing examples of curriculum outlines and checklists as appendices.
2-6. EQUIPMENT CONSIDERATIONS. Part 135 certificate holders conducting HAA operations will utilize task-specific equipment associated with medical transport. An applicant should identify, in their initial application, any specialized equipment that may be used in their HAA operations. This equipment should include items required by regulations such as a Helicopter Terrain Awareness and Warning System (HTAWS) and a radio altimeter. By April 23, 2018, helicopters must equip Flight Data Monitoring Systems (FDMS). It may include a Night Vision Imaging System (NVIS) installation and other equipment fitted to bring each helicopter to a desired aeromedical configuration. Helicopters to be used in HAA operations are evaluated by FAA PIs.
2-7. INSPECTION AND MAINTENANCE CONSIDERATIONS. HAA operators should consider inspection and maintenance issues beyond those associated with other part 135 operations. This includes inspecting and maintaining equipment added for HAA operations. This equipment increases maintenance complexity and introduces second-order complications. These complications may include NVIS compatibility, electromagnetic compatibility (EMC)
Par 2-7 Page 13 (and 14) verification, heat shielding, fire resistance, mechanical integrity of mounting, crashworthiness and infection control procedures. Maintenance hours and cost burdens will increase because of the need to remove and replace complex on-board systems, sealed interior panels, etc., when required to access aircraft systems for inspection, maintenance and repair. The operator should factor these considerations into both routine and unscheduled maintenance decisionmaking. For example, it is not acceptable to apply for multiple extensions on deferrals of required maintenance for minimum equipment list (MEL) items solely due to the cost burden associated with gaining access to make repairs. Be on guard against such practices. Standard MEL deferral decisionmaking should be consistently applied.
NOTE: Reference materials providing further guidance include: AC 27-1B MG 6, Miscellaneous Guidance (MG) for Emergency Medical Service (EMS) Systems Installations.
2-8. DOCUMENTATION AND RECORDKEEPING CONSIDERATIONS. All HAA operators are required to document preflight risk analysis and VFR flight planning procedures. In addition to the manual requirements imposed by § 135.21, it is recommended that each certificate holder conducting HAA operations, including single-pilot and basic operators, compile and maintain manuals reflecting the implementation of HAA best practices identified in this AC. Documentation and recordkeeping requirements associated with HAA operations beyond those normally required of part 135 operators are described in Chapter 7 of this AC.
Par 3-1 Page 15 CHAPTER 3. OPERATIONS
3-1. GENERAL. This chapter outlines recommendations regarding the conduct of Title 14 of the Code of Federal Regulations (14 CFR) part 135 helicopter air ambulance (HAA) operations.
3-2. OPERATIONAL CONTROL, FLIGHT LOCATING, AND FLIGHT FOLLOWING DUTIES AND RESPONSIBILITIES. Regardless of the size and complexity of the operation, the operator is responsible for maintaining operational control, accomplishing flight locating and supporting the pilot during preflight planning, risk analysis, and en route by providing information and constructive input which would aid the pilot in effective decisionmaking.
Smaller operations may accomplish this through direct communication between the pilot and the management person to whom the authority to provide a flight authorization has been delegated.
Larger operations may accomplish the same objective through pilot communication and discussion with a trained Operations Control Specialist (OCS).
a. Operational Control. Only those individuals authorized by name in an operator’s operations specification (OpSpec) may exercise operational control. While operational control may be delegated to certain certificate holder personnel, it must never be delegated to customer hospitals or external emergency medical services (EMS) agencies.
b. Duties and Responsibilities. The pilot in command (PIC), by regulation, is the final authority for the operation of any HAA flight. It is an HAA industry best practice that a PIC may not “self-launch.” Operators should establish procedures for coordination between the pilot and OCS, or other person authorized to exercise operational control, to evaluate flight risk analyses to ensure risk is mitigated to the extent possible or a flight request is declined due to unacceptable risk. While “three to go, one to say no” is a good practice (with the three being the PIC and two medical crew members, and the one being any one of the three), it is essential that no external pressure “to go” is applied to the pilot during the decisionmaking process.
NOTE: A PIC’s decision to decline, cancel, divert or terminate a flight overrides any decision by any and all other parties to accept or continue a flight.
c. Flight Authorization and Flight Locating Procedures. Regardless of whether or not an operator uses an Operations Control Center (OCC), flight authorization and flight locating procedures should be well-considered and thoroughly documented to support training and operations. For those operators with an OCC, the description of the duties and responsibilities of OCSs and an explanation of their duty times in the current edition of Advisory Circular (AC) 120-96, Integration of Operations Control Centers into Helicopter Emergency Medical Services Operations, should amplify the above. In addition, the rule describing OCS training part 135, § 135.619(f) is an excellent guide to the subject matter considerations involved in issuing a flight authorization and with reacting to flight locating adverse outcomes. The certificate holder is required by regulation to use flight locating procedures (refer to § 135.79), unless a Federal Aviation Administration (FAA) flight plan is filed and activated.
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d. Flight Following.
(1) Flight Following Recommendations. Flight following is distinguished from flight locating. Flight locating is required for HAA operations unless an FAA flight plan is filed and activated. While § 135.619 requires an OCC to monitor the progress of a flight, for smaller operators (ten or less HAAs), it is a good practice to employ flight following.
(2) Flight Following Connectivity. Flight following should maintain voice communications with helicopter pilots during HAA operations. The operator may wish to consider employing satellite/Global Positioning System (GPS) tracking for flight following tasks as a supplement or substitute for voice radio connectivity.
(3) Flight Following Latency. It is recommended that a position and status report be made, at most, every 15 (in flight) to 45 (on ground) minutes. If communication is lost, the aircraft may be considered missing after failing to provide sequential routine position reports (usually two reports). The longer the time between position reports, the greater the radius of uncertainty of the missing helicopter’s location. The operator should also consider employing satellite/GPS tracking for flight following tasks as a substitute for voice radio connectivity.
e. Flight Following and Accident Incident Plan/Post-Accident Incident Plan (AIP/PAIP). Each OCC or other flight following office should have access to the operator’s AIP/PAIP. The plan should be reviewed and updated annually or more frequently as needed.
(1) Information in the AIP/PAIP defines and provides direction for emergency response procedures that should be used as a basis for training or for reference in the event of a mishap, accident or other emergency. The AIP/PAIP establishes standard emergency response procedures that OCSs or flight followers will carry out in all cases when an aircraft meets operator-defined criteria of being overdue or has been involved in an incident or accident.
(2) The AIP/PAIP and any other emergency response plans and guides may be formatted in a variety of ways, provided the user (that is, the individual making the initial response to the emergency) can easily determine where to find guidance for a situation and then follow a generic checklist of actions to be taken for that situation. An addendum to the main response plan should be available for every satellite base. Each local addendum should list direct-dial phone numbers for the satellite base manager, local first responder and 911 dispatch organizations, local air traffic control (ATC) and local FAA offices.
f. Communications Personnel and Procedures. Chapter 6 of this AC provides recommendations to assist HAA operators with best practices for implementing OCCs and operational control procedures.
(1) Large HAA operators have developed OCCs to maintain operational control. While there is a regulatory requirement (§ 135.619) for operators with 10 or more HAAs to have OCCs, smaller operators should consider the benefits that best practices have shown can be implemented on a scalable level to meet the needs of smaller operators.
(2) Operators without an OCC, and large operators may find it advantageous to supplement their Operational Control personnel through the addition of Communications
Par 3-2 Page 17 Specialist Staff. If this is the case, the Operator must train and qualify their Communications Specialists to the extent their duties and responsibilities reflect delegated Operational Control tasks. For example, if a Communication Specialist is responsible for performing flight locating duties via radio or other communications process, and to receive and offer the operator flight requests for HAA operations their training should include company policy and procedures for such activity.
(3) A communications specialist may be an employee of the HAA operator, a hospital
(i.e., a hospital communications specialist) or a local public safety agency (i.e., a 911 dispatch operator. If communications specialist duties are delegated beyond certificate-holder personnel, such as to a hospital or ambulance dispatch center, those individuals serving in that capacity must be trained by the certificate holder and such training programs must be documented.
(4) The primary function of the communications specialist is to support HAA operations by relaying coordination information and situational awareness information among the flightcrew, hospital, and on-scene personnel and other involved organizations and individuals. Providing and receiving in-flight updates and post-flight debriefs to flightcrews have been identified as part of their recommended functions.
(5) HAA best practices suggest that the responsibilities of communications specialists should include ascertaining, from those requesting HAA services, whether another HAA operator has previously declined to carry out a particular flight and, if so, for what reason. The response received should be conveyed to the pilot performing the Risk Analysis in accordance with § 135.617. The personnel that carry out this function may or may not be the same as those who carry out in-flight connectivity and flight locating functions during HAA operations.
(6) Depending on the size and nature of HAA operations, different communications specialist functions may be split between multiple individuals (who may also carry out other functions) or concentrated in one or more communications specialists.
(7) Communications specialist duties may include flight following. Best practices suggest that an HAA operator’s communications system should provide reliable connectivity with HAAs in flight and on the ground, enable flight locating (required by regulation for some operators and recommended for all others) and ensure that medical personnel and pilot(s) can communicate with recipients such as hospitals and ground personnel at a Landing Zone (LZ).
Some rural hospitals may not have communications capability other than by phone.
Communications specialist personnel may be required to act as an intermediary.
(8) In all cases, when communications specialists perform an OCS duty included in § 135.619(a)(1-4), the communication specialist is subject to training and checking in those subjects that support the duty performed and must be trained in the limit of authority delegated to them.
3-3. VISUAL FLIGHT RULES (VFR)/INSTRUMENT FLIGHT RULES (IFR) FLIGHT PLANNING AND WEATHER MINIMUMS.
a. Flight Planning (refer to §§ 135.613 and 135.615).