Par 4-1 Page 33 CHAPTER 4. TRAINING
4-1. GENERAL. This chapter identifies considerations for training for all helicopter air ambulance (HAA) personnel including flightcrew members, medical personnel, Operations Control Specialists (OCS), ground personnel and maintenance personnel. Emphasis is on training beyond the capabilities normally associated with Title 14 of the Code of Federal Regulations (14 CFR) part 135 operations. Most notably, HAA operations include a training program that explicitly requires well-considered and documented risk analysis and human factors issues.
4-2. HAA PILOT-IN-COMMAND (PIC)/SECOND-IN-COMMAND (SIC) GROUND TRAINING. Examples of ground training are provided in Appendix C of this advisory circular (AC). Following are some recommended HAA-specific curriculum items that are suggested by industry best practices:
a. Ground Training Curriculum.
(1) Risk analysis procedures (these are required by regulation and described in paragraph 3-4 and Appendix A of this AC).
(2) Local flying area (LFA) orientations.
(3) Flight planning and weather minimums (described in paragraph 3-3 of this AC).
(4) Flightcrew functions and responsibilities (including Crew Resource Management (CRM) as described in paragraph 4-9 of this AC).
(5) Obstacle recognition and avoidance.
(6) Aircraft systems variations, such as special electrical systems, navigational radios and instrumentation and their performance characteristics.
(7) Handling and securing of special medical equipment such as stretchers, isolettes, balloon pumps and ventilators.
(8) Appropriate restraint of infants, pediatric patients and passengers who may pose a threat to the safety of the aircraft and crew, to include prisoners.
(9) Hospital heliport operations and procedures.
(10) Day and night unimproved landing area (scene) operations.
(11) International operations and programs (if appropriate).
(12) Bloodborne pathogens, biohazard and infection control, including prevention and control of infectious diseases.
(13) Refueling procedures and methods to ensure fuel quality.
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(14) Inadvertent instrument meteorological conditions (IIMC), whiteout, brownout and flat light conditions (described in paragraph 3-9 of this AC).
(15) HAA-specific equipment training (i.e., night vision goggles (NVG), Helicopter Terrain Awareness and Warning System (HTAWS), radar altimeter, etc.).
4-3. HAA PIC/SIC FLIGHT TRAINING.
a. Use of Simulators.
(1) Helicopter flight simulation training devices (FSTDs) are rapidly becoming more advanced. Some are now capable of full-motion with realistic visual cockpit displays. A growing number of helicopter FSTDs are approved by the Federal Aviation Administration (FAA).
(2) Training in IIMC, flat light, and other special conditions can be enhanced through the use of simulators. Simulators have the capability to decrease visibility and simulate a variety of situations not possible in flight. Simulators can provide realistic training in sudden onset emergencies such as dual engine failures. It is strongly recommended that, where possible, FSTDs should be included in part 135 training and checking activities.
(3) Inspectors should become thoroughly familiar with the types of simulators and simulator practices employed by their operators.
b. Flight Training Curriculum. At a minimum, the following topics should be included in the HAA flight training curriculum. Examples of flight training and checking practices are provided through the inclusion of training material as Appendix C of this AC.
(1) LFA orientation (day/night). LFA ground (and optional flight) training should familiarize pilots with LFA terrain, airspace, air traffic facilities, weather (including seasonal sun glare, icing, fog and convective weather) and available airports, heliports, Landing Zones (LZ) and their respective approaches.
(2) Operations Control Center (OCC) interface and utilization.
(3) Hospital heliport operations and procedures (day/night and multi-aircraft).
(4) Unimproved LZ (off-airport) operations (day/night and multi-aircraft).
(5) Day and night cross-country flight to include cockpit and exterior lighting and forced landing considerations (including use of a searchlight if installed).
(6) Communications, including air-to-ground and flightcrew/medical crew procedures.
c. IIMC Avoidance and Recovery Procedures. Training and checking should emphasize the recognition of circumstances likely to lead to IIMC encounters and encourage the pilot to abandon continued visual flight rules (VFR) flight into deteriorating conditions. IIMC may occur when visual conditions do not allow for the determination of a usable horizon, such as flat light conditions (discussed in paragraph 3-9 of this AC) and night operations over unlit surfaces in
Par 4-3 Page 35 low lighting conditions. These conditions may occur in high ceiling and visibility environments.
The result may be a loss of horizontal or surface reference by which the pilot typically controls a helicopter in VFR flight. Without adequate training and checking, these conditions may lead to loss of control that may not be survivable.
(1) All HAA pilots must be trained in basic instrument flying skills to recover from IIMC, including those authorized to conduct instrument flight rules (IFR) operations under part H operations specifications (OpSpecs). Training must also be provided on unplanned transition from an intended VFR flight to emergency IFR operations, which involves a different set of pilot actions, including navigation and operational procedures, interaction with air traffic control (ATC) and CRM.
(2) IIMC training should include identification of a predetermined minimum altitude/airspeed combination which should not be exceeded. If this minimum altitude/airspeed combination cannot be maintained, a diversion to better conditions or a return to the starting base should be the first course of action. Training should emphasize that deteriorating conditions may also dictate a landing short of the destination (even an off-airport precautionary landing) or initiating an emergency transition to IFR as appropriate to the situation. It should be further emphasized that such a decision on the part of the PIC is within the pilot’s emergency authority and the pilot will not be subjected to disciplinary action solely based on the transition to IFR or the precautionary diversion or landing.
(3) An oral or written test covering procedures for aircraft handling in flat light, whiteout and brownout conditions, including methods for recognizing and IIMC conditions, is required. (Refer to part 135, § 135.293(a)(9).)
(4) Training and checking for all pilots, whether helicopter instrument rated or not, must include attitude instrument flying, recovery from unusual attitudes and ATC communications. The objective is for non-instrumented rated pilots to demonstrate their ability to be able to recover to visual meteorological conditions (VMC). Pilots should receive training, regardless of their Instrument flying qualifications or lack thereof, so following an IIMC encounter they can maneuver a helicopter from instrument meteorological conditions (IMC) to VMC solely by reference to instruments. Checking of their ability is covered in the flight test required by § 135.293(c).
(5) In the absence of an IFR-certified helicopter, training and checking should include instrument maneuvers appropriate to the installed equipment, the certificate holder’s OpSpecs and the operating environment.
(6) For checking, if the aircraft is appropriately equipped and the check is conducted at a location where an instrument landing system (ILS) is operational, an ILS approach should be demonstrated. If unable to conduct an ILS approach, a Global Positioning System (GPS) approach should be demonstrated if the aircraft is equipped with an IFR-approach-capable GPS receiver that is maintained to IFR standards (including a current IFR database) and the check can be conducted where a GPS approach is available. If neither ILS nor GPS procedures can be performed, another type of instrument approach must be performed. Very high frequency (VHF) omnidirectional range station (VOR), automatic direction finder (ADF) and airport surveillance
Par 4-3 Page 36 radar (ASR) approaches are options, depending upon available facilities and equipment. Partial panel operations should be considered for inclusion in checks if attitude and gyroscopic heading information are available from single sources. In the case of a helicopter without gyroscopic instruments, the operator should consult with their principal operations inspector (POI) for alternative training and checking methods.
(7) In the event the certificate holder does not have OpSpecs for night or instrument conditions, the aircraft is not equipped with an attitude reference system, a turn indicator or coordinator, or an attitude gyro, and the operating environment is predominantly VFR, the pilot being checked may not be required to demonstrate a VMC recovery from IIMC. Under these circumstances, it is recommended that the pilot be examined verbally in the IIMC recognition and avoidance techniques developed by the operator.
d. Night Training. Many HAA-associated accidents occur at night. Pilot night proficiency is essential for twenty-four hour HAA operations. While not required by regulations, night operations should be emphasized in flight, ground and simulator training.
(1) Night training should be tailored to the certificate holder’s specific requirements and capabilities considering the experience level of their pilots, the area of operations, type of aircraft and installed equipment.
(2) Best practices suggest night flight training should include the use of Night Vision Imaging System (NVIS); the appropriate use of HTAWS and radar altimeters. Appropriate use of these technologies will also contribute to pilot proficiency at night, in IIMC and special conditions.
NOTE: This AC is not intended to suggest training or operating a helicopter in actual IMC conditions without a qualified, competent and proficient pilot, a properly equipped helicopter and an IFR clearance. The purpose of the training described here is to provide pilots with an additional margin of safety when conducting HAA operations.
NOTE: Effective April 22, 2017, all HAA pilots must hold a valid helicopter instrument rating or an Airline Transport Pilot Certificate (ATPC) with a category and class rating not limited to VFR. (Refer to § 135.603.)
4-4. MEDICAL PERSONNEL/CREWMEMBER BRIEFING/TRAINING.
a. Required Medical Crewmember Briefing/Training. As stated in § 135.621(a), the pilot in command (PIC) or other flightcrew member must ensure that all medical personnel receive and complete a HAA medical personnel specific safety briefing prior to each HAA operation in which they participate, or, as authorized by § 135.621(b), have completed the certificate holder’s approved medical personnel safety training program within the previous 24 months. There is no grace period associated with this 24-calendar-month training period. This training must cover:
• Physiological aspects of flight;
• Patient loading and unloading;
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• Safety in and around the helicopter;
• In-flight emergency procedures;
• Emergency landing procedures;
• Emergency evacuation procedures;
• Efficient and safe communications with the pilot; and
• Differences between day and night operations, if appropriate.
b. Recommended Additional Medical Personnel Training. In addition to these required briefing/training subjects, training in the following topics has been identified through industry best practices as fostering crewmember proficiency and safety:
• External power unit (EPU) door and cart;
• Medical equipment – loading and unloading/securing;
• Oxygen system and outlets;
• Audio panel and headsets;
• Lights and vents;
• Cabin cleaning;
• Emergency locator transmitter (ELT);
• Emergency fuel shutoff; and
• Radios –VHF, FM, 800 megahertz (MHz).
4-5. OCS TRAINING. OCCs are staffed during all hours of HAA operations by one or more OCSs, trained to provide a wide range of operational support for the certificate holder’s HAA operations. At a minimum, OCSs are required to communicate with pilots, provide weather briefings, monitor flight progress and participate in the preflight risk analysis completed by the pilot (refer to § 135.617). This does not end their involvement in risk analysis, which is a continuous process until the flight is completed. OCSs must be trained in their duties and responsibilities, including duty-time limitations as developed by the certificate holder. By mirroring training requirements of § 135.619(b) into existing staff members and creating standard operating procedures (SOP) scalable to the size of the operation, it is possible for a small operator, with minimal expense, to increase the safety of their HAA operations.
a. HAA OCS Training. Section 135.619(d) establishes the requirement and § 135.619(f) establishes the minimum training for HAA certificate holders operating 10 or more HAAs.
Certificate holders operating fewer than 10 HAAs are encouraged to use the same training in all HAA operations.
(1) Preferably, although not required, HAA OCSs should be trained as helicopter pilots and, ideally, be highly experienced HAA pilots.
(2) Before performing the duties of an OCS, each person must satisfactorily complete the certificate holder’s FAA-approved OCS initial training program. Initial training must include a minimum of 80 hours of training on the topics required in § 135.619(f).
(3) Each OCS must complete a minimum of 40 hours of recurrent training, every 12 calendar-months after satisfactory completion of initial training.
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b. OCS Prior Experience. A certificate holder may reduce the regulatory requirement of 80 hours of initial training provided the individual has certain prior experience. The training may be reduced as appropriate but not less than a minimum of 40 hours. It is recommended that the certificate holder perform a training needs assessment to determine what training requirements (per § 135.619(f)) may not be needed for all for persons who have obtained, prior to beginning initial training, a total of at least 2 years of experience during the last 5 years in any one or combination of the following areas:
• Military aircraft operations as a pilot, flight navigator or meteorologist;
• Air carrier operations as a pilot, flight engineer (FE), certified aircraft dispatcher or meteorologist; or
• Aircraft operations as an air traffic controller or flight service specialist.
c. Training Requirements. OCS training requirements are specified in § 135.619(f).
Other requirements, as determined by the Administrator to ensure safe operations, may be added, depending upon each individual HAA operator’s circumstances. In addition to required initial and annual training, it is recommended that recurrent training include carrying out periodic emergency procedure drills. Recurrent training and checking must be accomplished before the end of the 12th calendar-month since the last check was accomplished.
d. Testing. OCSs must pass an FAA-approved knowledge and practical test given by the certificate holder on topics required in § 135.619(f). If an OCS fails to satisfactorily complete recurrent training and checking, within this time, the individual may not perform OCS duties until the training and checking is accomplished. There is no provision for a grace period.
Requalification of OCS following a lapse may be accomplished by satisfactorily completing the recurrent training and checking. In the event of a test failure, the OCS retest must be proceeded by retraining in the subject areas missed and retesting should cover all subject areas.
NOTE: Effective April 22, 2016, all certificate holders authorized to conduct HAA operations with 10 or more HAA-capable helicopters assigned to the certificate holder’s OpSpec must have an OCC. (Refer to § 135.619.)
4-6. COMMUNICATIONS SPECIALISTS TRAINING. Information on communications specialists and their training is provided in the current edition of AC 120-96, Integration of Operation Control Centers into Helicopter Emergency Medical Services Operations.
Communication specialists may be employed by the HAA operator, a hospital, and ambulance dispatch center or local law enforcement entities (e.g., local public safety or 911 dispatchers).
a. Training. There are no regulatory qualifications requirements for communication specialists. Employers should provide sufficient aviation-specific training to permit them to perform their intended functions and to know what their limits of authority may be.
Communication specialists not employed by the certificate holder, that provide services through either contract or agreement, must be trained in accordance with the certificate holder’s approved training program. It is recommended this training would include portions of the OCS training curriculum described above.
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b. Third Party Training Providers. Certificate holders may employ outside training resources to provide consistent training to communication specialists, providing the contractor and their training syllabus are approved by the certificate holder.
4-7. GROUND PERSONNEL TRAINING/ORIENTATION. The FAA recommends that HAA operators develop a training program for hospitals, first-responders and law enforcement personnel that includes:
a. LZ Area Evaluation. LZ area evaluation to include size, surface, suitability of terrain, hazard/obstacle identification and the effects of rotor-wash.
b. Use of Visual Cues. The use of visual cues for positioning and parking the helicopter
(e.g., standard hand signals and communications).
c. Methods of Lighting. Methods of lighting night landing zones, ground/vehicle lighting considerations, and discipline related to NVG operations.
d. Safety. Personal safety in and around the helicopter, including an overview of FAA rules and safety measures for the specific helicopters that are operated by the certificate holder.
e. Loading/Unloading with Helicopter Shut Down. Loading and unloading with the helicopter shut down.
f. Loading/Unloading with Helicopter Running. Loading and unloading the helicopter with rotors and/or engine running, including the use of a tail rotor guard or lookout.
g. Emergency Landing Procedures. Emergency landing procedures, such as emergency shut-off procedures, securing equipment, etc.
h. Other Emergency Procedures. Emergency procedures for handling fuel leaks, helicopter fires, fire suppression and other situations requiring an emergency response.
i. Helicopter Evacuation Procedures.
j. Other Procedures. Other procedures for day/night operations into and out of an unimproved landing site.
NOTE: The Aeronautical Information Manual, chapter 10, 10-2-3 provides information that may be helpful in planning outreach training. Additionally, several industry publications are available to provide information on training for LZ operations.
4-8. MAINTENANCE PERSONNEL TRAINING.
a. Training. Maintenance personnel participating in HAA operations should receive training to meet specific needs unique to these operations. This includes the mounting and maintenance of medical equipment, non-aviation radios and other communications equipment and the scheduling and performance of maintenance to facilitate the demands of either scheduled
Par Page 40 or non-scheduled HAA operations. Training of maintenance personnel is required in accordance with § 135.433.
b. Supplemental Training. Maintenance personnel should be trained on servicing and maintaining medical oxygen systems and other equipment as required. Training should include biohazard control and mitigation associated with HAA operations.
NOTE: Recurrent training (and its documentation) is recommended for all maintenance personnel in addition to initial training.
4-9. CRM TRAINING. Flightcrews may experience high stress levels in HAA operations.
CRM training is intended to prevent inappropriate actions and decisions during periods of stress.
HAA operators should implement CRM training that builds effective integration and coordination during routine flight operations as well as including issues such as the use of medical personnel to supplement flightcrew, as appropriate during emergency operations including IIMC recovery, and non-emergency operations including NVG operations and flight into unimproved LZs, etc. Due consideration should be given to the over-riding medical care priorities that medical personnel serve when training medical personnel in aviation related activities. Refer to the current edition of AC 120-51, Crew Resource Management Training.
4-10. AIR MEDICAL RESOURCE MANAGEMENT (AMRM) TRAINING.
a. General. The purpose of an AMRM training program is to create a shared safety culture, between customer management and HAA operator management cooperatively bringing together HAA operators and medical organizations. Clearly defined and consistently implemented operating philosophies, policies, safety culture, best practices and procedures should be reflected in training to create an understanding of authority and responsibility of all levels of the involved personnel. Refer to the current edition of AC 00-64, Air Medical Resource Management, to identify training issues.
b. Shared Training. Aviation and medical management personnel should collaboratively and explicitly define the safety responsibility and authority of managers and subordinates.
Shared AMRM training provides a common language and understanding to enable appropriate safety communication, responsibility and authority, within both HAA operators and medical organizations (and others as appropriate). Ideally, AMRM training should not be limited to the classroom but include engagement with high-level decisionmakers, including medical or hospital management.
4-11. JUDGMENT AND DECISIONMAKING TRAINING. Crewmember judgment is the mental process by which the crewmember recognizes, analyzes, and evaluates information about himself or herself, the helicopter and the external environment. Industry best practices recognize that judgment and decisionmaking can be developed and improved with training. Pamphlet DOT/FAA/PM 86 45, Aeronautical Decision Making for Helicopter Pilots, is a recommended tool to improve aeronautical decision-making (ADM).
a. Topics. Decisionmaking training should include topics such as LFA, refueling locations, terrain, local weather patterns, aircraft characteristics and capabilities and medical equipment. Emphasis in training should be placed on identifying and addressing the types of
Par 4-11 Page 41 (and 42) decisions likely to be required by the specific needs of HAA operations. This includes, for example, training in the decisionmaking process involved when changing weather conditions might dictate a route change or termination of flight.
b. Risk Analysis. Risk analysis is an integral component of the decisionmaking process.
It must be trained for, understood and practiced by HAA crewmembers before and during all flight operations.
c. Decisionmaking Training. Emphasizes that the best practices in the industry reflect that the medical condition of the patient should not be a factor in the PIC decision to accept or decline a flight and should not be briefed to the PIC in advance of the decisionmaking process.
d. Management Personnel. Management personnel should participate in the certificate holder’s training program. Management personnel should be familiar with the ADM process.
Knowledge of appropriate FAA regulations and guidelines related to safe operations is essential.
(See Chapter 8.)
e. Human Factors. The operator must effectively address human factors that have the potential to affect HAA operations. (Refer to § 135.330.)
Par 5-1 Page 43 CHAPTER 5. EQUIPMENT
5-1. THE HELICOPTER AIR AMBULANCE (HAA) HELICOPTER. The selection of a suitable HAA helicopter (and its subsequent modification) will include considerations exclusive to the HAA operating environment. An applicant should identify, in their initial application, any specialized flight operations equipment that will be aboard the helicopter(s) used for HAA operations.
a. Weight and Performance of HAAs. An operator should consider the effect of the significant added operating weight associated with even a basic HAA helicopter’s mission-specific modifications including equipment such as a Helicopter Terrain Awareness and Warning System (HTAWS), radio altimeter, and Flight Data Monitoring System (FDMS). In addition, weight penalties are associated with an aeromedical interior, medical equipment and supplies, and provision for medical personnel and their personal gear. Equipment such as Night Vision Imaging System (NVIS), satellite communication (SATCOM), position tracking and reporting systems and possibly equipment supporting instrument flight rules (IFR) capability provides additional operational capability but further reduces helicopter payload and performance.
b. Control and Use of HAAs. By regulation (Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.25), the certificate holder is required to have control and exclusive use (including maintenance) of at least one aircraft to be used in part 135 service. Helicopters used in HAA operations may be owned or leased by the certificate holder. In the case of leased equipment, the lessor may be the certificate holder’s customer (hospital group or community).
This common industry practice may introduce operations control complications unless the lease is executed in a manner that transfers operations control unequivocally to the certificate holder.
Operators should be on guard against the potential of perceived operations control retention by the lessor. This practice has historically led to undue pressure on the operator during flight risk analysis and flight authorization decisionmaking processes.
5-2. EQUIPMENT REQUIRED BY REGULATION FOR HAA OPERATIONS.
a. Radio Altimeter. A Federal Aviation Administration (FAA)-approved radio altimeter or an FAA-approved device that incorporates a radio altimeter, is required and must be operational unless otherwise authorized in the certificate holder’s approved minimum equipment list (MEL). Specifications for radio altimeters under this requirement are in § 135.160. Operators should establish and document procedures to be followed if operations are conducted with an inoperative radio altimeter in accordance with an MEL. Incorporating procedures such as requiring increased ceiling and or visibility and limiting flights where white out, brownout, or encounters with flight light conditions may be possible may mitigate risk. Inoperative equipment should also be addressed as a risk analysis factor as discussed in appendix A of this advisory circular (AC).
NOTE: The FAA may authorize deviations for certain helicopters (maximum gross takeoff weight no greater than 2,950 pounds) unable to incorporate a radio altimeter. (Refer to § 135.160.)
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b. HTAWS. An HTAWS that meets the specifications of FAA Technical Standard Order (TSO) C-194 and RTCA DO-309 must be installed and operational in all HAA helicopters. The operator’s manuals or other documentation must specify appropriate procedures for the use of this equipment, including the proper flightcrew response to audio and visual warnings. There is a process for operators with HTAWS covered by a deviation under § 21.618 to meet the regulatory requirements of § 135.605. The HTAWS requirement becomes effective on April 24, 2017.
c. FDMS Capable of Recording Flight Performance Data. To meet the requirements of § 135.607, the operator must install an FAA-approved FDMS in each HAA. In this context, “approved FDMS” means only that the installed FDMS be capable of recording “flight performance data” including at minimum: Latitude, Longitude, Barometric Altitude, and Date/time of recording, once per second and have sufficient memory to retain these data over 4 hours of flight time. The FDMS is approved by Supplemental Type Certificate (STC), design review, or field approval, depending upon the complexity of the installation, the interface between the FDMS and other systems installed aboard the aircraft, and that it poses no hazard to other onboard equipment, nor any hazard to occupants. Beyond the minimum parameters, additional parameters recorded by the FDMS are at the discretion of the operator. Retention and use of recorded data is also at the discretion of the Operator. The FDMS requirement becomes effective on April 23, 2018. The FDMS is not to be confused with a flight data recorder (FDR) certified under § 27.1459, though an FDR would be acceptable to meet the FDMS requirement.
(1) The FDMS must operate from the application of electrical power prior to engine start until the removal of electrical power after termination of the flight (refer to § 135.607). The FDMS design should be compliant with Design Assurance Level D (DAL-D) as set out in the latest revisions of both RTCA DO-178 (for software development) and RTCA DO-254 (acceptable airborne electronic hardware development standards). FDMS inspection and maintenance should be conducted in accordance with the manufacturer’s instructions for continued airworthiness (ICA). Additional information is in AC 27-1B MG 6, Miscellaneous Guidance (MG) for Emergency Medical Service (EMS) Systems Installations.
(2) The operator determines and maintains the FDMS data stream format and parameter documentation. The operator is responsible for determining:
• Parameters(beyond the minimum direct parameters of latitude, longitude, barometric altitude, and date/time of recording) that are recorded and which are derived from recorded data;
• Latency (how frequently each recorded parameter is recorded);
• Bit resolution of each parameter;
• Operational range of each parameter; and
• Conversion algorithms from digital or analog signal units to engineering units.
(3) Information may be directly recorded or may be deduced from recorded data
(e.g., continually updated three dimensional Global Positioning System (GPS) location data may yield ground speed, heading and course being flown and altitude). The FDMS should record digital or analog raw data, images, cockpit voice or ambient audio recordings or any combinations thereof which ideally yield at least the following flight information: