FAA tests waters for helicopter emergency medical services recording with mixed response

Part one of a two-part story by Charlotte AdamsWASHINGTON, 2 Dec. 2010. The Federal Aviation Administration (FAA) recently announced that it may require flight data recording and monitoring for the helicopter air ambulance industry. This segment of the agency's Oct. 12, 2010, notice has encountered mixed reviews from operators and manufacturers. Some raise the specter of a complex and expensive requirement down the road, while others speculate that imposing minimal hardware requirements for the sake of accident investigations will not advance flight data monitoring (FDM). Still others say that mandatory FDM would conflict with the FAA's protected flight data sharing program, which is strictly voluntary. The FAA's announcement also calls attention to the ongoing, but different, work of two international bodies that are developing guidelines and standards for emerging lightweight aircraft recording systems (LARS). The FAA's notice of proposed rulemaking (NPRM) mentions the possibility of a LARS and helicopter FDM (HFDM) requirement, but does not define what a LARS is. Nor has the agency initiated an RTCA activity to develop a minimum operational performance standard (MOPS) on LARS or FDM, says Larry Buehler, an aviation safety inspector with the Air Transportation Division of the Flight Standards Service. "So you might want to take that as an indicator" of the imminence of regulatory action, he says. The rationale for the potential requirement appears to be accident investigation, and the NPRM points out that only 11 percent of helicopter emergency medical services (HEMS) operators currently use flight data recorders (FDRs).A tiny minority of today's U.S. helicopter fleet is required to have big, expensive flight data recording equipment, which means that investigators are often hard-pressed to understand exactly why an accident occurred. The ships required to have FDRs are the large ones with seating for 10 or more passengers. And, even so, there are multiple loopholes. Although the National Transportation Safety Board has recommended that all transport-category helicopters operating under either Part 135 or Part 91 be equipped with cockpit voice recorders (CVRs) and FDRs, FAA is thinking of a smaller, more easily installed, more affordable package for HEMS operators. However, the agency cites a $6,450 price for hardware, which some observers consider an unrealistically low estimate.The current, FAA-approved flight data monitoring program -- known as Flight Operations Quality Assurance (FOQA) -- is voluntary. Under FOQA, operators share "de-identified" data with the agency in return for limited protections from enforcement actions against them or their employees. FAA then uses the aggregated data to better understand safety issues in U.S. airspace. If FDM became mandatory for HEMS operators, would operators make data available to the agency? Would the data be protected? Thus the NPRM asks whether operators, if required to equip only with LARS, "would be more likely to participate in" a FOQA program. It is not clear whether all operators required to equip with LARS would jump on board FOQA since there are also loopholes in the government's protections and concerns that even de-identified data could somehow be associated with an operator, given the initially small pool of participants. The FAA is sensitive to the issue of voluntariness. "That is the crux of the question," Buehler says. In writing the NPRM, "we did not want to damage the current voluntary FOQA program." So FAA "would love to hear comments on how [the issue of data sharing] could be addressed." BJ Raysor, director of aviation for Arkansas Children's Hospital (ACH), the first HEMS operator to launch a FOQA program, observes that FAA could require LARS but not FDM. Operators might see FOQA or FDM as a logical next step because either would allow them to improve operations, training, and maintenance practices based on real flight data. But, he predicts, if a flight data management program is required, a lot of people would choose FOQA. Metro AviationMetro Aviation, meanwhile, has jumped into the FOQA arena with both feet. It hopes be the first major HEMS operator to be FOQA-approved and has taken a majority interest in a new company, North Flight Data Systems, LLC (North FDS), which has purchased the flight data, voice and video recording product line of satellite tracking company, OuterLink. North FDS also is working on a next-generation FDM product with Metro and plans ultimately to offer FOQA analysis services to the industry. Most of Metro's fleet is equipped with the former OuterLink's O.V.V.R. audio and video recorders, says Mike Stanberry, Metro’s owner. Metro has also equipped some ships with North FDS's quick access recorders (QARs) and multifunction data acquisition units (MFDAUs). Metro currently operates several EC145s equipped with full, crashworthy voice and data capability for Cleveland Metro Hospital. The operator is working with the hospital and FlightScape, which provides FOQA analysis software, to analyze this set of flight data and help put Metro's FOQA program together.

Other HEMS operators are also making strides. Air Methods, for example, will evaluate FOQA in a project with the Flight Safety Foundation and L-3. The oil-and-gas support operators have also stepped out smartly. Era Helicopters has a FOQA program and PHI has a non-FAA, internal FDM program. Other suppliers include L-3, which has introduced two different light aircraft recorders; Honeywell, Appareo, which has a line of self-contained recorders for small operators and legacy aircraft; Wi-Flight, which has a smart phone-based product; and Sagem Avionics.ACH experienceArkansas Children's Hospital (ACH) has had more than a year of experience as a FOQA-approved operator, using the Appareo GAU 2000. Raysor cites measurable benefits, such as the management of a noise complaint from a resident in ACH's operating area. The resident had even gone to the FAA about it. But ACH was able to do a noise complaint study based on FOQA data. "We realized how many times a month we were flying [near] this guy’' location,” he recalls. "We were able to measure the altitude, the time of day and [the frequency]."The data also told ACH that "99 percent" of the infractions were when pilots were relocating aircraft from the hospital heliport to the airport without a patient, the operator's most flexible time. As a result of the study, ACH was able to restructure its routing to the airport and reduce noise infractions "by about 95 percent," Raysor says.Big pictureWhile the FAA talks about possibly requiring LARS and FDM, ongoing international initiatives by two interrelated groups are trying to move helicopter operators, manufacturers, and suppliers toward a consensus on FDM parameters and practices that could guide the evolution of regulation in this area. First was the International Helicopter Safety Team (IHST), which was launched in 2005 with the goal of reducing the helicopter accident rate by 80 percent by 2016, recalls Rhett Flater, executive director of the American Helicopter Society, who, with FAA and the Helicopter Association International (HAI), helped to spearhead the movement. Statistics show there has really been some improvement. The U.S. fleet accident rate has declined from an estimated 9.1 per 100,000 hours in 2005 to 4.9/100,000 hours through October 2010, according to FAA, bettering, so far, the 2010 target of 5.8. Internationally, the accident rate has also declined -- from 9.4/100,000 hours in 2005 to 6-6.1 through October of 2010, according to Fred Brisbois of Sikorsky, who co-chairs the U.S. side of the IHST's Joint Helicopter Safety Implementation Team.Brisbois points out that the No. 1 recommendation of IHST's analysis team in its 2006 report was for the development and installation of aircraft FDM equipment. Alluding to FDM/FOQA's widespread and successful use in the airlines, he called FDM "probably the most significant cultural change," he's seen in his 40 years in the aviation business. The implementation team has taken all the recommendations from the analysis team and "tried to pin them down into actions that are executable," he says. The IHST's HFDM group -- led by Kipp Lau of FDM analysis services provider, CAPACG -- has been developing a list of parameters for helicopter recorders. An operator, for example, could record parameters such as a certain degree of roll left/right for a certain duration in order to identify an excessive bank angle event. The IHST FDM group is also developing a common set of events that new operators can build on, Lau says. Because of the multiplicity of helicopter missions, he’s added another column, so to speak, indicating which types of operations each event would be appropriate for.Just last year saw the launch of a second group, known as the Global HFDM Community. The global HFDM group, which includes the larger operators, is also developing lists of light recorder "standards" in the form of parameters for categories of aircraft, such as light single piston, light single turbine, medium twin turbine, and heavy twin, explains Capt. Mike Pilgrim of CHC, who co-chairs the global HFDM organization's steering group. The group also focuses on data sharing among operators.Pilgrim distinguishes the global group's approach from the regulatory approach. The FAA is "looking for minimum standards for flight recorders to assist in accident investigations, and we are looking at recommending minimum standards for HFDM." The difference, he says, is that "for an effective HFDM program we would require a much larger data set than any legislator would ... mandate for accident investigation." In his view "it is pointless recommending a small minimum number of 'mandatory' parameters, but this is what regulators have consistently done with ... FDR systems." Editor's Note: This is the first part of a two-part series on recording and flight data monitoring requirements and options for helicopters. The second part will describe in greater detail some of the products currently available to this sector.

FAA tests waters for helicopter emergency medical services recording with mixed response

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