Air Medical Operators are Committed to Safety Enhancements
The Air Medical Operators Association (AMOA) is committed to providing the highest level of safety
in air medical transport. As the collective body of aviation operators, AMOA members have the sole responsibility to provide
the safest possible aviation services for transporting patients and the medical crews that care for those patients. To
ensure that responsibility, AMOA is committed to the implementation of technology, procedures, and operating systems that
will help ensure the continued safe and effective operation of air medical services; these initiatives are divided into
four key areas:
Ø
Terrain
and Obstacle Avoidance:
Operators must provide the necessary tools to aid in the avoidance of terrain and obstacles; AMOA believes there are a small
range of technologies and procedures available to accomplish that goal. It is the position of the AMOA that all helicopters
performing air medical transport services operate with the necessary equipment and procedures to achieve terrain and obstacle
avoidance that the operator deems appropriate for their area and operation. This system can be achieved by any of the
following:
Ø Operating with Night Vision or Night Vision
Imaging System (NVIS), with the appropriate level of initial and recurrent
training.
Ø Operating with some type of Helicopter
Terrain Alert Warning System (HTAWS) or Terrain Awareness Warning System, with
the appropriate level of initial and recurrent training.
Ø Operating under Instrument Flight Rules
(IFR), with the appropriate level of initial and recurrent training.
Further, it is the position of the AMOA that any rule addressing
terrain and obstacle avoidance must allow for the consideration of comparable
options to achieve compliance.
Ø
Training:
Air medical services operate
in a myriad of operating environments and
with several different types of aircraft with different capabilities and
limitations. While there are other safety objectives listed here, none of them
can provide a level of risk mitigation equal to that of a frequent training
program that makes use of available Flight Training Devices (FTD's), simulators
or operational aircraft with instructors providing simulated scenarios,
including Inadvertent Instrument meteorological conditions (IIMC) on at least a
semi-annual recurrent basis.
It
is the position of the AMOA that operators provide pilots with recurrent
aviation training and that training include the following scenarios:
Ø Inadvertent Instrument Meteorological Conditions
(IIMC).
Ø Emergency Procedures (Engine & Component Failures).
Ø Night Operations.
Ø TAWS/HTAWS & NVIS.
Further,
air medical operators provide Air Medical Resource Management (AMRM) and Risk Management training to all personnel
on a recurrent basis at least annually.
Ø
Oversight: Effective management oversight is a critical safety component; it is not
enough to provide enhanced regulations and procedures- operators must also
monitor those enhancements and provide effective guidance on risk assessment
and mitigation.
It is the position of
the AMOA that air medical operators provide effective management oversight
through the development of Operational Control in compliance with Operations
Specification A008 and subsequent guidance on Risk Assessment and Operational Control Centers.
Further, those must include:
Ø
Satellite
Tracking or ADS-B Capability
Ø
Approved
Risk Assessment and Risk Management Procedures
Ø
Regional
or Centralized Operational Control Systems
Further, operators must initiate
flight data monitoring devices and coordinate that implementation with a
standardized helicopter specific Flight Operations Quality Assurance (FOQA) or
similar program.
Ø
Safety
Systems: All of these
concepts require a collective management system that combines the attributes of
these objectives into one cohesive system. Safety Management Systems (SMS), as
recommended by the International Helicopter Safety Team (IHST) should be modeled
after the International Civil Aviation Organization (ICAO) Safety Management
Manual (Doc 9859-AN/460) and FAA Advisory Circular, AC 120-92, Introduction to Safety Management Systems for Air Operators. The fully-developed SMS must represent a
structured methodology for managing safety across the entire spectrum of
aviation operations. The SMS attributes
are interdependent and must enhance the safety of every process or activity
within the collective operation or system.
The SMS is dynamic and must be updated through continuous quality
improvement.
This
SMS must include but is not limited to the following attributes:
Ø
Senior-Level
Commitment (Advocacy, Resourcing, Values & Culture)
Ø
Safety
Structure, Hierarchy & Accountability
Ø
Compliance-Based
Requirements (Policies, Procedures, Guidelines, Checklists, etc…)
Ø
Risk
Management Methodology (Systematic Process)
Ø
Safety
Reporting (Standard & Anonymous Functionality, Proactive Hazard
Identification & Reactive Occurrence/Event Disclosure)
Ø
Root
Cause Analysis/Investigation Methodology
Ø
Safety
Trend Analysis Program
Ø
OSHA
& Safety-Related Training Program
Ø
Best
Safety Practices (BSP) Sharing & Lessons-Learned
Ø
Action-Oriented
Safety Committees
Ø
Safety
Awards Program
Ø
Audit
& Surety Program
AMOA members agree that these enhancements cannot be singular in focus, but rather
a part of organizational change. We also agree that there is no stopping point; while we can advance the
level of technology, training, and management oversight to unprecedented levels, especially when compared
to other areas of on-demand aviation, we cannot forget that safety begins- and unfortunately sometimes
ends- in the day-to-day interaction between crews and aircraft. For this reason AMOA continues to support
the Vision Zero initiative which pursues personal vigilance and a daily affirmation of safety
principles.
AMOA members make these commitments to the safe operation of air medical services;
while we remain competitors in the field, we firmly believe, above all else, that we must remain...
...United in Safety.
