Helicopter emergency medical services "really have more in common with ambulances than they do with any airplane or runway", says David Murphy, a Metro Aviation HEMS pilot for Allegheny Lifeflight, a Pennsylvania operator.
But from HEMS pilots' marked preference for visual flight rules sorties to the unpredictable nature of HEMS missions, operators know that the differences between helicopter crews and their ground-bound colleagues are significant - and a cause for action.
RISING CRASH RATE
Visual flight rules entry into instrument flight rules conditions, controlled flight into terrain and poor visibility at night are the main causes behind a HEMS crash rate that has risen alarmingly - 85 HEMS accidents have resulted in 77 fatalities over the past six years, according to the US National Transportation Safety Board.
The issue has caught the attention of the US Congress, the Federal Aviation Administration, the NTSB and the public. Regulators are not just questioning whether better training and instrumentation could reduce accident rates, but whether HEMS operators should consider more government oversight, especially in the form of an FAA-administered safety management system.
But can a safety management system such as the FAA's Aviation Safety Action Program (ASAP), a tool widely adopted among US commercial airlines and which involves voluntary, anonymous reporting by airline employees on potentially dangerous incidents, be the answer to improving safety in the vastly different world of HEMS operators?
At least one US operator believes it can.
Douglas Garretson, chief executive of the West Mifflin, Pennsylvania-based STAT MedEvac, notes that not only is his the first HEMS operator to adopt an ASAP with the FAA, it is the first US helicopter operator in general to launch the programme. A visit to the company's Allegheny County airport headquarters, one of the operator's 17 bases, reveals the impact of this programme on a HEMS operator that logged more than 12,500 flight hours in 2009. The operator flies 21 aircraft: five Eurocopter EC145 and 16 EC135 helicopters.
STAT MedEvac has a fleet of 16 Eurocopter EC135s (pictured) and EC145s
While STAT helicopters have modern tools including IFR avionics, traffic collision avoidance systems (TCAS), enhanced ground proximity warning systems (EGPWS) and three sets of night vision goggles per aircraft, the company's safety and risk manager Jim Blakley wanted a way to harness a lesson after a glitch or an in-flight crisis receded. His answer was ASAP.
Non-punitive, anonymous self-reporting systems are not a novelty for many HEMS operators. For example, the NASA aviation safety reporting system (ASRS) features a secure online form that any pilot can anonymously access to report a problem. Pilots are typically held harmless by the FAA if they file an ASRS report immediately after an incident.
Allegheny Lifeflight's Murphy calls the ASRS a "good start" to tackling the industry's safety issues, but without formal access to the information NASA receives through the programme, he sees no direct practical repercussions, beyond perhaps better willingness in the culture to communicate on safety issues.
But Blakley sees the potential of an SMS such as ASAP that allows pilots and the FAA to learn from specific incidents. "After discussing aviation safety with a few college friends working in airline safety departments, I recognised the need for establishing an ASAP as the cornerstone of flight safety for HEMS," Blakley says.
He wanted STAT employees to be able to "identify hazards without facing repercussions from announcing the problems". ASAP programmes are designed to provide immunity for those reporting an incident or accident, assuming there was no ill-intent involved.
Blakley likens the initial process of applying for membership in the FAA programme to "filling out a lease". For STAT, the programme's first stage took the form of an 18-month "test demonstration programme", after which STAT reapplied for permanent enrolment, which it received in December 2008.
In its present form, STAT's ASAP participation is governed by a non-binding memorandum of understanding between STAT and the FAA, which is renewed every 24 months. STAT has ASAP programmes for its pilots, mechanics and flight followers. Official programmes are also available for dispatchers, flight attendants and employees in other support functions, such as ramp workers.
John Kenny, STAT's director of operations, says his company has an excellent relationship with its Part 135 certificate management team, the FAA officials who are STAT's ASAP liaisons. He says trust between the operator and the FAA team is crucial to the programme's success. Each ASAP is a distinct relationship managed between the FAA, the individual operator, and often a third party such as a labour union, although that is not the case with STAT, which currently lacks a union.
STAT's ASAP programme encourages non-punitive reporting of a variety of issues, from mechanical to procedural to crew or pilot error. STAT pilots or mechanics can choose how to submit their reports: they can print, complete and mail the appropriate form, or fill out a secure, anonymous online report.
Kenny and Blakley admit that among the system's difficulties is the complicated length of the ASAP form. To facilitate use of the programme, Blakley gives pilots the option of an anonymous phone call, where he gathers the relevant information through voicemail or conversation and enters it into the form himself.
An event review committee comprised of STAT staffers Blakley and director of safety Paul Lhote, along with the FAA certificate management team, meets monthly to evaluate reports. This team currently receives about five ASAP reports every month, although Blakley notes that a relatively low number is to be expected when most HEMS pilots use VFR - the margin for deviation from specific courses and protocols is looser outside IFR. Out of 9,800 patients flown in 2009 by STAT, 520 were transported via IFR.
Blakley says submitting the reports and undertaking corrective action is "only the first step". He says it is crucial not just to identify the problem, but to "memorialise" it along with a record of the implemented solutions, a process he says is the most valuable piece of the ASAP.
Any STAT MedEvac staffer can study an online "document warehouse" of ASAP reports and their resolutions, an informational warehouse that he says is vital to improving safety, not just for the company's present employees, but also for future employees as well.
ASAP reports and the feedback mechanism into the training regimen have helped STAT develop more efficient and effective night vision goggle training, says Blakley. Other reported incidents can have their roots in policy needing revision. Reports on a mechanical breakdown can help determine whether the trouble lies in part manufacture, its installation and maintenance, or a flawed manual.
Blakley points to a 2008 ASAP report on loose main gear box retaining flange bolts on an EC135. Less than a month later, after reports of unusual vibration on two other EC135s, more loose bolts were found. As a result of this and similar reports to the European Aviation Safety Agency, the FAA adopted a new airworthiness directive regarding maintenance of the bolts.
"There is no doubt this ASAP report and AD saved lives," Blakley says. ASAP also aids in developing better landing zone standards, and better education for first-response EMS teams on how to facilitate a HEMS landing.
While ASAP is more often used for large fixed-wing commercial carriers - more than 50 of the 77 operators in the programme are airlines - Kenny thinks the programme may be better suited to a smaller company such as STAT.
Without the extensive bureaucracy that comes with the strata of corporate management and unions, he says it is easier to implement creative solutions that might meet resistance in the hierarchies of larger organisations.
Kenny acknowledges that ASAP is not perfect. Some pilots find the forms intimidating, and he admits that not all ASAP reports are productive - they can be used "as an avenue to gripe" about things that may irk employees, but are not necessarily safety issues.
And while STAT's HEMS pilots may file reports on the hazards of, for example, oblivious hang-gliders, there is little STAT can do about those from an air traffic regulations standpoint.
FAA approval for STAT's ASAP was the first of its kind for a HEMS operator
So far for STAT, the benefits of the system far outweigh the flaws. "I'd like to see every HEMS operator using this system," Kenny says, explaining that the greater the HEMS data pool provided to the FAA, the better chance all operators would have to spot and prevent dangerous trends before an accident or incident occurs.