What Do the FAA Rule Changes Mean for EMS?

In February 2014, the Federal Aviation Administration (FAA) announced the promulgation of a series of rules requiring helicopter operators to have stricter flight rules and improvements to communications, training and on-board safety equipment. These rules were in response to an increase in helicopter accidents and designed to put increased focus on safe operations.

At the time of the announcement, the FAA gave helicopter operators 60 days to implement the changes outlined in the rules document related to flight procedures in bad weather and landing in remote locations, three years to incorporate new equipment and technology to avoid obstacles and terrain, and four years to equip aircraft with flight data monitoring systems.

In April 2014, the FAA extended the effective date for these rules for one year in order to give helicopter operators time to implement the requirements as outlined in the rules document.

These rules represent a significant change to how air ambulance agencies operate. So what do these rules mean to both these agencies and EMS as a whole, since the rules may affect how and when air ambulances are activated for service.

Historically the FAA has been responsible for regulating the aviation aspect of air medical operations (aircraft flight worthiness and maintenance schedules, pilot education, weather minimums, etc.) and has relied on state EMS offices to regulate the medical aspect (equipment to be carried, medical flight crew requirements, etc.).Many of these changes are related to safety and are designed to address the causes of 62 air medical incidents occurring between 1991 and 2010 that resulted in 125 fatalities. These incidents were broken down into four common factors:

1. Flights where instrumentation had to be used to fly in poor weather;
2. Loss of control of aircraft;
3. Controlled flight into terrain;
4. Night conditions.

The FAA did state that air medical operations are unique due to time sensitivity of missions, the need to fly at low altitudes and in varied weather conditions, and landing at non-traditional landing sites that may have unforeseen hazards such as trees, wires, towers and/or buildings.

The FAA made seven recommended changes to the rules for air medical operations:

1. Recommendation that all air medical services operators comply with certain specifications during flights with medical personnel on board. This is directed for services such as public safety agencies (police agencies, etc.) that do both air medical activities and law enforcement activities. Those agencies historically have had to comply with less stringent specifications.
2. Recommendation for all air medical services operators to develop and implement flight risk evaluation programs, which includes training and flight risk evaluation procedures. Many operators already have similar programs in place giving flight crews more education of the evaluation of flight risk to make better determinations of when or when not to fly.
3. Recommendation for all air medical operators to use formal dispatch and in-flight procedures that include up-to-date flight information and assistance in assessing flight risk mid-flight. This is to address situations of rapidly deteriorating weather conditions, as well as weather conditions that may exist in one area, but not in another.
4. Recommendation for air medical operators to install terrain awareness and warning systems on aircraft and provide training so all flight crew members can use those systems.
5. Recommendation that the FAA develop criteria for scenario-based training for air medical services pilots that includes training related to inclement weather and hazards that are unique to air medical services.
6. Recommendation for all air medical operators to implement safety management systems that include sound risk management practices including the use of flight data monitoring systems.
7. Recommendation for all air medical operators to install flight data recording devices and a program to monitor all available flight data.

Some of the main reasons for the delay in implementation of these rules, as well as some of the things that have a significant impact to air medical services overall, are cost, as well as time to develop recommended training programs and operations procedures. Much of the equipment that is being asked to be installed on aircraft comes at a cost that the operator may not be able to shoulder in a short amount of time, if at all.

Additionally, these pieces of equipment add weight to the aircraft. Operators need to determine how to install the new equipment while still staying within weight limits for the aircraft. Finally, personnel need to be oriented and trained how to use new equipment.

What this means to the EMS community as a whole is simple: there are occasions where an air medical service may have responded to a call for service that they may not respond to after the rules are actually in effect, especially in situations where service is requested in poor weather, or any other time flight crew safety may be called into question.

Providers need to understand that these rules were put in place in the spirit of flight crew safety, aimed at reducing incidents involving air medical services. Also it should be remembered that conditions where air medical services respond are dynamic and evaluated on an individual basis by the flight crew at the time of the request. Just because there are clear skies on scene, doesn’t mean that the weather is the same at the location that the aircraft is launching from.

For more information on the FAA rule changes, go to:

Announcement of the changes: https://www.faa.gov/news/press_releases/news_story.cfm?newsId=15795

The FAA Final Rule document: https://www.gpo.gov/fdsys/pkg/FR-2014-02-21/pdf/2014-03689.pdf

Announcement of the delay: https://www.gpo.gov/fdsys/pkg/FR-2014-04-21/pdf/2014-09034.pdf?utm_source=Update+FAA+New+Rule+Delayed&utm_campaign=news%3A+delayed+air+ambul+regs+changing&utm_medium=email