VOLUME 3 GENERAL TECHNICAL ADMINISTRATION
CHAPTER 19 TRAINING PROGRAMS AND AIRMAN QUALIFICATIONS
Section 15 Safety Assurance System: Air Ambulance Specific Flight Crewmember Training Programs
3-19-15-1 GENERAL. This
section contains guidance to be used by inspectors when evaluating
a Title 14 of the Code of Federal Regulations (14 CFR) part
ambulance operator training programs for flightcrew
members. This section should be used in conjunction with
Volume 3, Chapter 19, Sections 1 through 11,
as it does not contain comprehensive guidance for an
entire part 135 training program. Air ambulance operators are not exempted,
by virtue of the urgent medical response implications of this industry, from
any other training requirements imposed upon all part
This section addresses only the additional subject matter required for air ambulance (helicopter
or airplane) training programs. This section is related to Safety Assurance
System (SAS) Element 2.1.1 (OP), Training of Flight Crewmembers, and Element
2.1.4 (OP), Outsource Crewmember Training.
3-19-15-3 AIRPLANE TRAINING PROGRAMS. Inspectors must consider the following
elements when evaluating an operator’s airplane flight training program and airplane ground training program:
A. Airplane Ground Training Program. Inspectors must evaluate
the following ambulance-specific areas in the operator’s ground training curriculum:
· Aircraft medical systems variations;
· Passenger restraining methods in flight;
· Flightcrew functions and responsibilities,
including Crew Resource Management (CRM) as it pertains to interface between medical personnel and flightcrew members;
· Aircraft systems variations, such as
special electrical systems, navigational radios, and instrumentation and their performance characteristics;
· Handling of special medical equipment to
include loading/unloading of stretchers, isolettes, balloon pumps, and ventilators;
· Appropriate restraint of infants,
pediatric patients, and problem passengers to include prisoners;
· International operations (if appropriate); and
· Blood-borne pathogens and biohazard and infection
control, including prevention and control of infectious diseases.
B. Airplane Flight Training Program. There are no airplane flight
training maneuvers that are unique to air ambulance services.
3-19-15-5 HELICOPTER TRAINING PROGRAMS. Inspectors must carefully consider the
following elements when evaluating a helicopter air ambulance (HAA) operator’s training program:
A. Pilot Ground Training. Inspectors must evaluate the operator’s
ground training curriculum. The operator must ensure that the following topics are included:
1) Risk analysis procedure required by part
as described in Appendix A of the current edition of AC
135-14, Helicopter Air Ambulance Operations.
2) Local flying area (LFA) familiarity. Pilots must receive training
and must demonstrate their familiarity with each LFA they are authorized to
use by passing an examination given by the certificate holder within the previous
12 calendar-months prior to taking advantage of LFA weather minimums. In other
words, pilots who have not demonstrated their familiarity by examination within
the past 12 calendar-months may not operate to lower Class G minimums listed in the table within §
examination may be conducted in conjunction with a §
or may be made via flight check by a computer-based training
and checking system, or by written or oral examination administered by a company-designated
individual who is familiar with the LFA involved. Subject matter that should
be included in the training and examination are as follows:
a) LFA borders;
b) Locations of terrain features and obstructions that may pose a hazard to HAA flight operations;
c) Available (emergency) and operator-approved airports, heliports, and
off-airport landing sites/areas along with appropriate ingress/egress routes and limitations or guidance;
d) Preferred low-altitude flyways and minimum cruising altitudes throughout the LFA;
e) Air traffic control (ATC) frequencies, instrument approaches, and the
terms and conditions of any local Memorandums of Understanding (MOU) established between the ATC facilities and the operator;
f) Weather resources available within the LFA;
g) Local communications procedures between the aircraft and any communications
centers, specialists, or Operations Control Centers (OCC);
h) Specific local area adverse weather cues; and
i) Additional local concerns as appropriate (refer to §
3) Flight planning and weather minimums (refer to §
4) Flightcrew functions and responsibilities, including CRM as
it pertains to interface between medical personnel and flightcrew members.
5) Obstacle recognition and avoidance.
6) Handling, loading, and unloading of special medical equipment
such as stretchers, isolettes, balloon pumps, and ventilators.
7) Appropriate restraint of infants, pediatric patients, and
passengers who may pose a threat to the safety of the aircraft and crew, to
include patients who are hysterical or combative.
8) Hospital heliport operations and procedures.
9) Day and night unimproved landing area (scene) operations.
10) International operations (if appropriate).
11) Blood-borne pathogens, biohazard, and infection control, including
prevention and control of infectious diseases.
12) Refueling procedures and methods to ensure fuel quality.
B. Helicopter Pilot Flight Training with Flight Simulation Training Devices (FSTD).
1) Helicopter FSTDs are rapidly becoming more advanced. Some
are now capable of full motion with realistic visual cockpit displays. A growing
number of helicopter FSTDs are approved by the Federal Aviation Administration (FAA).
2) Training in inadvertent instrument meteorological conditions
(IIMC), flat light, and other special conditions can be enhanced through the
use of FSTDs, which have the capability to suddenly decrease visibility and
simulate a variety of situations not realistically possible in flight. FSTDs
can provide realistic training to hone appropriate pilot responses to all types
of sudden onset emergencies. Inspectors must become thoroughly familiar with
the types of FSTD and simulator practices that the operator intends to use and
the FSTD capabilities prior to authorizing the use of these FSTDs.
C. Flight Training Curriculum. Inspectors should verify that
the following recommended topics are included in the operator’s flight training
curriculum as appropriate to the operations conducted:
1) LFA orientation (day/night) to familiarize pilots with and to reinforce
LFA features, hazards, special procedures, and concerns, presented in subparagraph 3-19-15-5A2);
2) Hospital heliport operations and procedures (day/night and multi-aircraft);
3) Unimproved landing zone (LZ) operations (off-airport, day/night, and multi-aircraft);
4) Day and night cross-country flights, including cockpit and
exterior lighting and forced landing considerations (including use of a searchlight if installed); and
5) Communications, including air-to-ground and flight crew/medical personnel procedures.
D. IIMC Avoidance and Recovery Procedures. This is a topic that applies to all part
operations and as such is checked in all §
checks. It is emphasized here because of the high proportion of helicopter accidents
that were at least partially attributed to continued visual flight rules (VFR)
flights into instrument meteorological conditions (IMC).
1) Inspectors should evaluate the certificate holder’s training
and checking procedures, particularly the identification and recognition of
circumstances likely to lead to IIMC encounters and that serve to prompt the
pilot to abandon continued VFR flights into deteriorating conditions.
2) The inspector must also evaluate the training program treatment
of IIMC recovery techniques and procedures, including the appropriate declaration
of an emergency due to an IIMC encounter and the obtaining of an instrument
flight rules (IFR) clearance at the first opportunity. Inspectors are cautioned
to avoid pursuit of enforcement action under these circumstances providing adequate
pre-flight planning and risk analysis was performed.
3) IIMC may effectively occur when visual meteorological conditions
(ceiling and visibility) may exist but conditions do not allow for the determination
of a usable horizon. Such conditions include flat light conditions (discussed
in paragraph 3-9 of the current edition of AC
may occur during night operations over unlit surfaces in
low-lighting conditions. These conditions may result in a loss of horizontal
or surface reference by which the pilot typically controls a helicopter in VFR
flight. Without adequate training and checking, pilots may not be prepared to
contend with these conditions, leading to loss of control that may not be survivable.
4) An oral or written test covering procedures for aircraft handling
in flat-light, whiteout, and brownout conditions, including methods for recognizing
and avoiding those conditions, is required. Refer to
§ 135.293(a)(9) and see
Volume 3, Chapter 19, Section 7,
Flightcrew Qualification Curriculum Segments, for further details.
E. Night Training.
1) A disproportionate number of HAA-associated accidents occur
at night. Inspectors must evaluate an HAA certificate holder’s night training
and checking to verify that flight, ground, and simulator training emphasize
night operations, both aided (night vision goggles (NVG)) and unaided. Pilot
night proficiency is essential for 24-hour HAA operations. Night training must
be tailored to the certificate holder’s specific requirements and capabilities,
taking into account the experience level of their pilots, the area of operations,
type of aircraft, and the installed equipment. If applicable, night flight training
should include the effective use of Night Vision Imaging Systems (NVIS), Helicopter
Terrain Awareness and Warning System (HTAWS), and radar altimeters.
2) Night competency checks. HAA operators with operations specification
(OpSpec) A050 NVIS/NVG authorization are increasingly likely to perform all §
checks during darkness. If this is the case, the inspector
must annually evaluate or observe competency checks performed by check airmen
to verify maneuvers are performed with and without the aid of NVIS.
NOTE: All HAAs must be equipped with HTAWS by April 24, 2017, in accordance with
NOTE: Effective April 24, 2017, all HAA pilots must hold a valid helicopter instrument
rating or an Airline Transport Pilot Certificate (ATPC) with a category and class rating not limited to VFR. (Refer to §
3-19-15-7 CREW RESOURCE MANAGEMENT (CRM) TRAINING. Inspectors should evaluate
how air ambulance operators provide CRM training that integrates medical personnel
during routine flight operations and how medical personnel on board and, as
appropriate, communications specialists (CS) or Operations Control Specialists
(OCS) may be integrated to supplement the flightcrew, as appropriate, during
operations including IIMC recovery, NVG operations, and operations involving
unimproved LZs, etc. Refer to the current editions of AC
Crew Resource Management Training, for general CRM concerns and
Air Medical Resource Management, to identify certain HAA CRM training
issues. The inspector must bear the following overarching aeronautical decision-making
(ADM) concepts in mind when reviewing certificate holder CRM training programs.
A. Crewmember Judgment. Crewmember judgment is the mental process
by which the crewmember recognizes, analyzes, and evaluates information about
himself or herself, the helicopter, and the external environment. Judgment and
decisionmaking can be developed and improved with training. Pamphlet DOT/FAA/PM-86/45,
Aeronautical Decision Making for Helicopter Pilots, is recommended as a tool to improve ADM and CRM.
B. Decisionmaking. Decisionmaking training should include topics
such as LFA, refueling locations, terrain, local weather patterns, aircraft
characteristics and capabilities, and medical equipment. Emphasis in training
should be placed on identifying and addressing the types of decisions likely
to be required by the specific needs of HAA operations.
C. Risk Analysis. Risk analysis is an integral component of the
decisionmaking process. It must be trained for, understood, and practiced by
HAA crewmembers before and during all flight operations.
D. Medical Condition of the Patient. Industry best practices
indicate that the medical condition of the patient should not be a factor in
any pilot-in-command (PIC) decisionmaking processes to accept, decline, or divert
a flight and should not be briefed to the PIC in advance of the decisionmaking
process. This should be emphasized in training.
3-19-15-9 AIR MEDICAL RESOURCE MANAGEMENT (AMRM) TRAINING.
A. AMRM training is optional but strongly recommended. If the
operator engages in AMRM, inspectors should evaluate the operator’s AMRM. Verify
that both the certificate holder and medical management personnel have received
initial and recurrent training in clearly defining and consistently applying
safe operating philosophies, policies, safety culture, best practices, and procedures
throughout their respective organizations. Ideally, AMRM training should not
be limited to the classroom but should include engagement with high-level decisionmakers,
including medical or hospital management. Refer to
AC 00-64 to
identify AMRM training issues.
B. If the inspector observes or is made aware of certificate
holder or customer management actions or practices that are potentially detrimental
to HAA safety, this may indicate that AMRM training was not effective. The inspector
should address the observed or reported actions or practices through the AMRM
program so the issue can be remediated, and he or she should review the AMRM
training program to identify deficiencies and encourage preventative corrections
to the training program so it is unlikely the same issue would recur.
3-19-15-11 MANAGEMENT PERSONNEL TRAINING. Management personnel should
participate in the certificate holder’s training program. Management personnel should be familiar with
the ADM process. Knowledge of appropriate FAA regulations and guidelines related to safe operations is essential.
3-19-15-13 through 3-19-15-27 RESERVED.