Fri, Aug 12, 2005
Last Chance Before Rulemaking?
A notice published by
the FAA a few days ago puts the Helicopter EMS community on notice
that their current accident rate requires strong corrective
action... but does not mandate any compulsory behavior.
The FAA's purpose for the Notice, N 8000.301, 'was developed
with the helicopter emergency medical services (HEMS) community to
provide for principal inspectors (PI) in all specialties guidance
related to risk assessment programs used by HEMS operators. This
notice also contains information for PIs to provide to HEMS
operators for developing their risk assessment program."
The FAA also notes that the notice "identifies possible risk
factors and the dangers those risks pose to both flightcrew and
patient; for this reason, all aircraft operators involved in air
medical flight should actively promote the use of risk assessment
models."
The notice says that, "HEMS operate in a demanding environment.
They provide an invaluable service to the nation by providing
crucial, safe, and efficient transportation of critically ill and
injured patients to tertiary medical care facilities. While the
contribution of HEMS is profound as a component of the nation's
medical infrastructure, from an operational standpoint, it is a
commercial aviation activity performed by air carrier operators. It
therefore must be conducted with the highest level of safety. To
meet this requirement, risks must be identified, assessed, and
managed to ensure that they are mitigated, deferred, or accepted
according to the operator's ability to do so within the regulations
and standards appropriate to the operation."
While no compulsory rule-making is implied by the notice (though
more than a few industry vets seem to think that this may be the
first shot across the bow in preparation for formal rule-making...
a conclusion that seems to make some sense), further action is not
out of the question.
The only action implied by the notice is voluntary, with the FAA
recommending that. "PIs assigned to HEMS operators should review
the content of this notice and provide a copy of this notice to
their assigned operators. PIs should encourage the operators to
distribute this notice to each of the operator's bases and
sub-bases. Operators should be strongly encouraged to implement a
risk assessment and management program, which may incorporate this
notice as a component of the program, or otherwise identify their
management processes and operational controls that ensure that safe
operating practices are applied in flight operations and to
maintain safe operations."
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