EASA proposes wide-ranging new HEMS regulatory requirements
By Aaron Karp | November 24, 2022
Estimated reading time 10 minutes, 42 seconds.
European Union (EU) member states are preparing to vote in the first half of 2023 on proposed regulations that would revamp rules for operating helicopter emergency medical service (HEMS) flights in Europe.
The European Union Aviation Safety Agency (EASA) has issued a finalproposal covering a number of types of HEMS operations, saying the regulatory upgrades are needed to address risky flying that is now allowed. E.U. states will vote on the proposal and, if passed, HEMS regulations in Europe will be tightened with effect in the second half of 2024, though operators will be allowed three to five years to implement certain provisions. All of the new regulations are expected to be fully in place by 2028.
According to EASA, the proposed regulations are aimed at HEMS flights serving hospitals with older infrastructure; high altitude and mountain flying; rescue operations; and flights to sites where visibility can be low.
“In general, HEMS flights can [currently] take place in difficult weather conditions, with limited or no flight preparation time, to non-aerodrome destinations,” EASA air operations regulations officer Eric Bennett told Vertical via email.
He noted that helicopters are currently able to fly “to a legacy hospital that is not compliant with heliport requirements and does not permit operators to comply with performance requirements, but where deviations are accepted in the public interest.”
The proposed new rules for operating flights to older hospitals require the facilities to ensure there is “no excessive worsening of the obstacle environment.”
Helicopters flying to legacy hospitals will be mandated to be equipped with a night vision imaging system (NVIS) “for increased situational awareness at night,” Bennett said. “For operators already implementing NVIS, provisions will help upgrade their night vision goggles.”
According to EASA Opinion Number 08/2022, a 33-page document that outlines the proposed regulations, “NVISs, when properly used by appropriately trained crew … [are] considered to greatly assist in maintaining situational awareness and in managing risks during night operations. HEMS without NVISs should be restricted to pre-surveyed operating sites and to well-lit urban areas.”
Other proposed new requirements for helicopters operating to legacy hospitals include moving maps to enhance terrain and obstacle awareness; aircraft tracking coordinated with ground crew; more thorough pre-flight risk assessments; and enhanced pilot training for night operations.
Single-pilot HEMS flights to legacy hospitals will be subject to additional rules, including a requirement to be equipped with an autopilot system for night flights.
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Also, there are new crew configuration requirements mandating that a technical crew member be seated up front with the pilot if a stretcher is being loaded onto the helicopter. “If the installation of a stretcher precludes the technical crew member from occupying the front seat, HEMS will no longer be possible,” the opinion states. “This possibility had been used to maintain legacy helicopters in service, but this is no longer considered compatible with the desired safety standards.”
Single-engine helicopters will remain closely regulated, as is already the case in the E.U. “Such helicopters can only fly by day and will not be allowed at hospitals, which are located in urban areas,” according to Bennett.
EASA noted newer hospital landing sites that opened after Oct. 28, 2014, already have sturdy rotorcraft infrastructure in place and are not covered by the upgraded rules.
Another area of HEMS flying targeted by the regulatory upgrades are high-altitude and mountain operations. “HEMS performance and oxygen regulations [for example] currently don’t work at high altitudes and need to be fixed,” Bennett explained. “The current HEMS fleet cannot comply with the current performance regulations at high altitudes.”
According to the EASA proposal, “mountain operations are currently not adequately covered” by E.U. safety rules.
“An example is HEMS operations with a cargo sling,” the opinion stated. “When the EASA framework for HEMS was initially developed, it was not foreseen that sling load operations would be used in HEMS.… Since the requirements were initially not developed with these operations in mind, they did not fully cover all relevant aspects.”
Four E.U. member states have used “alternative means of compliance” with EASA regulations for cargo sling operations. But an EASA review of these means of compliance “supported the conclusion that some elements of the implementing rules applicable to HEMS needed to be amended to adequately cover some aspects of mountain HEMS operations.”
Bennett explained: “For HEMS operations with the use of the hoist, operational flexibility should be introduced.… HEMS operations with the use of the cargo sling will become possible and will be regulated.”
In these circumstances, a technical crew member will not always be required to sit up front with the pilot. “For HEMS operations with the use of the cargo hook and sling, the technical crew member is no longer needed in the front seat after the in-flight reconnaissance of the HEMS operating site and landing at a nearby intermediate landing site,” the opinion states. “However, help is needed to deal with the sling and supervise the operation from inside or under the helicopter.”
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Additionally, new requirements covering high altitude flying will “make it easier for HEMS operators to have oxygen on board,” Bennett said. “It also proposes new rules to safely fly without oxygen at high altitudes for very short periods of time, in the context of HEMS.”
EASA will allow single-engine helicopters to support twin-engine rotorcraft conducting emergency services at high altitudes during the day. “Single-engine helicopters are currently involved in HEMS-similar medical emergency services at high altitudes under national regulations, to complement the service provided by twin-engines,” Bennett explained. “This concept is retained at high altitudes [in the EASA proposal] to address peak demand with large, modern, lightly equipped single engines, if the member state of the accident site permits.”
The new rules will extend HEMS regulations to non-medical emergency rescue mountain operations (irrespective of altitude) that are currently exempt from HEMS rules. “The risk profile of medical and non-medical emergency flights is the same,” Bennett said. “In the case of mountain rescue, it can be unclear at the time of dispatch whether medical assistance is needed or not. It makes sense that the same rules apply in both cases.”
Enhancing night vision
Regarding poor visibility, particularly when flying to unsurveyed locations, EASA is proposing rules to “mitigate the risk of a loss of a visual reference during the flight, considering that most HEMS operations are expected to remain under visual flight rules (VFR).” The opinion notes that “the loss of a visual reference during a VFR flight remains one of the major contributors to fatal accidents in HEMS.”
The new requirements would mandate that all helicopters operating HEMS night flights be equipped with a basic stability augmentation system or an autopilot system for single-pilot operations. “Higher standards of automation for single-pilot operations at night are desirable but may not be achievable at reasonable costs, whereas the proposal would be sufficiently helpful to the single pilot without excessive disruption to the current HEMS fleets,” the opinion states. “It is nonetheless expected that some operators will have to either retrofit their helicopters or undertake a fleet change.”
Because of this, EASA is proposing HEMS operators be given five years to implement this requirement.
Additionally, more sophisticated autopilot systems with altitude and heading hold capability will be mandated for HEMS rotorcraft manufactured starting one year after the new rules go into effect. “All helicopters manufactured for the HEMS market have such autopilots available, at least as an option,” the EASA opinion notes.