200 likes | 393 Views
HEMS Performance JAR-OPS 3.005(d). HSST WP-07/3.4 HSST EASA Form 07/001. Draft NPA-OPS.
E N D
HEMS PerformanceJAR-OPS 3.005(d) HSST WP-07/3.4 HSST EASA Form 07/001
Draft NPA-OPS The proposed changes to the regulations in Appendix 1 to JAR-OPS 3.005(d) will allow more realistic and achievable performance criteria to be set for HEMS operations whilst retaining the level of safety necessary for such operations by the appropriate assessment and management of risk.
Background Appendix 1 to JAR-OPS 3.005(d) Helicopters conducting operations to/from a HEMS operating site located in a hostile environment shall as far as possible be operated in accordance with Subpart G (Performance Class 1). The commander shall make every reasonable effort to minimise the period during which there would be danger to helicopter occupants and persons on the surface in the event of failure of a power unit.
Background • HEMS operating site: A site selected by the commander during a HEMS flight for HHO, landing and take-off. • Because this is the primary pick up site related to an incident or accident, its use can never be pre-planned and therefore attracts alleviations from operating procedures and performance rules - when appropriate
Background Performance Class 1 (PC1) • The requirements of PC1 are: • a rejected take-off area with a suitable surface (in terms of size and surface condition) where a helicopter can be (re)landed OEI without damage • provision of specified obstacle clearance in the approach and take-off segments • these requirements have to be substantiated (calculated using graphs in the RFM) before PC1 operations can be commenced at any site • This is clearly not achievable with unplanned and un-surveyed sites.
Background • The HEMS philosophy attributes the appropriate levels of risk for each operational site; this is derived from practical considerations and probability of use. • The risk is expected to be inversely proportional to the amount of use of the site.
Proposal Helicopters conducting operations to/from a HEMS operating site located in a hostile environment shall as far as possible be operated in Performance Class 2. accordance with Subpart G (Performance Class 1). The commander shall make every reasonable effort to minimise the period during which there would be danger to helicopter occupants and persons on the surface in the event of failure of a power unit
Harmonisation • The proposal will harmonise current interpretation of the rule amongst JAR-OPS 3 operators
Options • Option 1. – To do nothing • would rely upon interpretation of the HEMS appendix; this has already been shown to be unsatisfactory as the regulation is interpreted in quite different ways by individual States • would leave helicopters in excess of 5,700kg at a substantial disadvantage (no appropriate regulation) • would also be unfortunate in not providing a clear regulation which can be transitioned to EASA without further discussion or amendment
Options • Option 2. - Adopting the proposed JAR-OPS 3.313 will : • provide a regulation that does not need interpretation and which could be applied universally • permit operations to a hostile environment by taking advantage of ground level exposure (as permitted in Subpart H post NPA-38). • permit the introduction of larger helicopters with increased flexibility, payload and performance so that more sophisticated equipment and more specialist personnel could be carried • lead to further choices of if and how compliance with Appendix 1 to JAR-OPS 3.517(a) needs to be shown (operations without an assured safe forced landing capability) • Compliance choices offered for consultation
Impacts • The Authorities; positive impact as it will reduce the need to interpret the regulation. There are no costs associated with the proposed changes apart from revision of the text. The code will also be submitted to EASA without the necessity for further amendment • Manufacturers; will not be affected by this proposal • Operators; positive impact for HEMS operators with clarification of the rule meaning. There could be additional cost if it is decided that a change in rule will require the fitting of UMS where not currently required
Consultation • The consultation process has been conducted within the HSST and in the HEMS organisations (EHA/EHAC) • they are in support of the intent of this policy • The primary consultation prior to the adoption will be through the appropriate public consultation process
Summary and Final Assessment The proposed change provides a substantial simplification to the rules. It removes the current text with its uncertainties and potential for dispute and replaces it with text that permits universal compliance with no impact on safety. The proposal also removes the unnecessary division between rules for helicopters with a MTOM greater than 5,700kg and the others – thus permitting larger and more capable helicopters into HEMS operations without artificial constraints.