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."

FMI: www.faa.gov, www.faa.gov/library/manuals/examiners_inspectors/8000/media/n8000-301.doc