Consider that today, running a Helicopter Emergency Medical Service, as well remain compliant with all HEMS regulatory requirements as well as keeping the various EASA Civil Aviation Authorities satisfied is a very challenging task.
From the pilots perspective whilst, HEMS is a tough and demanding type of flying (it may also be considered one of the most exhilarating even some would say beautiful flying experiences).
HEMS may operate anywhere in all corners of the globe!
The good news is that we finally have detailed regulations, governing most parts of the operations from management responsibilities and issues to operational challenges obligations and problems. HEMS EASA Regulations may be found within Regulation 2012/965. It should be noted that whilst the Implementing Rules are available in all European Languages, The AMC’s currently are not. This may cause some difficulty that the hard law (the EU regulation itself) and soft law, called Acceptable A Means of Compliance (AMC) are meant to be adapted together.
A more significant problem is related to the nature of the EASA Part OPS HEMS regulations where not specifically tailored to HEMS operators rather are in cases somewhat generic in nature.
Due to the nature of the HEMS operation challenges are known in part because these new regulations were not exactly tailored to us (HEMS Operators), but in fact predominately focus on the airlines. HEMS operations are more dynamic for example with the focus changing from LZ landings to patient status, therefore it is essential that a robust system of operating procedures is implemented to support this need.
Here to identify, mention and address some of the problems which impact the HEMS Operator:
Flight and duty time: the FTL (Flight Time Limitations)is and has been always a battlefield in the airline business, because of the consequences on the required number of crews, meaning huge cost to the airline. Luckily, we are out of this battle, as the helicopter operations are exempted from the EU regulations. The problem in the HEMS business is different, due to the nature of the business, HEMS pilots are standing by long hours to fly 20-30 minutes per sortie. Therefore their main limitation is total annual duty hours, daily duty limit, minimum rest time, rather than the maximum flight time.
Security: the governing EU regulations are mainly outside the Part-OPS, which contains only a very limited number of issues (cockpit door?). The EU regulations controlling civil aviation security is typically centered around airlines and airports. It does not mention the fact that a typical HEMS mission includes a landing in the “nowhere”, and the aircraft might be protected only by the pilot not a whole security system with fences and guards. Also to be noted that our threats are very different from the airline business, a helicopter may become target not in itself, but rather as a tool used to commit another crime.
Hospital heliports: the non-compliance of hospital heliports with ICAO standards is noted in the Part-OPS, also exemption is allowed for the HEMS operator from these rules (for hospital sites that are in use for long time). Although, if the national CAA is not allowed to deviate from these standards during the certification process, then the heliport might not obtain a certificate any more(depending on national regulations).
Status of medical crew: in the new Part-OPS regulations the medical crew (doctor) is considered a passenger only, which is a bit controversial. She/He might be useful when selecting a landing site, making sure obstacle clearance, or if an in flight emergency occurs when a patient is onboard. Also it hard to explain when landing at a commercial airport, why only two of the three personnel on board, has a CREW identification card.
