SPA.HEMS.130 Crew requirements

FLIGHT CREW AND TECHNICAL CREW — VALIDITY OF RECURRENT TRAINING AND CHECKING In the context of HEMS, the validity period of recurrent training and checking of all crew members should be as specified in AMC1 ORO.FC.145(g).

HEMS COMMANDER MINIMUM EXPERIENCE The minimum experience level for the commander who conducts HEMS flights should not be less than:

(a)either:

(1)1 000 hours as a pilot-in-command/commander of aircraft, of which 500 hours are as a pilot-in-command/commander on helicopters; or

(2)1 000 hours as a co-pilot in HEMS operations of which at least 500 hours are as a pilotincommand under supervision, and 100 hours as a pilot-in-command/commander on helicopters;

(b)500 hours’ operating experience in helicopters, gained in an operational environment similar to that of the intended operation;

(c)for pilots engaged in restricted night operations that do not include landing at night at HEMS operating sites, 20 hours of VMC at night as a pilot-in-command/commander; and

(d)for pilots engaged in unrestricted night operations:

(1)30 hours of VMC at night, to which 3 hours may be credited for every hour flown as part of a structured night HEMS training programme on a suitable FSTD. The structured training programme may be part of the operator conversion course or command course of the HEMS operator. This experience comes in addition to point (c);

(2)10 approaches, landings and take-offs by night at operating sites in an operational environment similar to that of the intended operation in the helicopter or in a FFS level D.

FLIGHT TRAINING WITH SOLE REFERENCE TO INSTRUMENTS

(a)The flight training should include training as pilot flying with sole reference to instruments.

(b)The training duration should be at least 45 minutes.

(c)The training should be conducted by a(n) FI/TRI/SFI and should be sufficient for the pilot to demonstrate competence in recovery from inadvertent entry into IMC conditions including the following manoeuvres:

(1)transition to instrument flight during climb-out;

(2)climbing and descending turns on to specified headings;

(3)level flight, control of heading, altitude and speed;

(4)level turns with 30 degrees bank, 180 to 360 degrees left and right;

(5)recovering from unusual attitudes;

(6)emergency let-down procedures;

(7)with a validity period of 12 calendar months, use of the autopilot including upper modes, if fitted.

(e)The instrument flight training should take place in a helicopter FSTD that is suitable for the training, or if no suitable FSTD is available, in a helicopter using vision-limiting devices such as goggles or screens. The helicopter used for the training should be a helicopter type used in the HEMS operation. The helicopter is not required to be certified for IFR operations.

HEMS TECHNICAL CREW MEMBER

(a)When the crew is composed of one pilot and one HEMS technical crew member, the latter should be seated in the forward-facing front seat (co-pilot seat) during the flight. However, by day the HEMS technical crew member may be seated in the cabin at the discretion of the commander if all of the following conditions are met:

(1)the HEMS technical crew member is likely to be tasked with HEMS HEC duties from the cabin during the HEMS mission;

(2)the flight is conducted to or from a HEMS operating site;

(3)the operator’s risk assessment determines that the technical crew member can carry out their primary tasks from the cabin; this risk assessment may determine that the rear door(s) needs (need) to remain open for better visibility. In addition, both by day and by night, the HEMS technical crew member may also re-position from the front seat to the cabin and back in the hover phase at the HEMS operating site used for HEMS HEC, if conditions (a)(1) to (a)(3) and all the following additional conditions are met:

(4)the risk assessment determines that the technical crew member can safely move from one position to the other;

(5)the helicopter is so equipped that the repositioning does not result in inadvertent interference with flight controls or aircraft systems;

(6)the operator defines SOPs for the transitioning to unaided visual references prior to entering the hover phase and for the re-positioning of the crew member;

(7)the operator defines initial and recurrent training towards these SOPs as well as recency requirements for technical crew members involved; and for night operations the training takes place by night;

(8)for night operations, the operator defines criteria to determine whether the HEC operation takes place with sufficient visual references at pre-flight stage and on-site. Sufficient visual references should be considered not to be met in the context of offshore operations;

(9)by night, the commander determines whether the pre-flight criteria defined in (8) are likely to be met without the use of NVG, and on-site, whether the criteria are met without the use of NVG. The commander should only use the procedure if the criteria are met.

(b)The primary tasks of the HEMS technical crew members are to assist the commander in:

(1)collision avoidance;

(2)the selection of the landing site;

(3)the detection of obstacles during approach and take-off phases; and

(4)the reading of checklists when seated in the front seat.

(c)The commander may delegate other aviation tasks to the HEMS technical crew member, as necessary:

(1)assistance in navigation;

(2)assistance in radio communication/radio navigation means selection;

(3)if properly qualified and licensed, radio communications;

(4)reading of checklists from the cabin; and

(5)monitoring of parameters.

(d)The commander may also delegate to the HEMS technical crew member tasks on the ground, as necessary:

(1)assistance in preparing the helicopter and dedicated medical specialist equipment for subsequent HEMS departure;

(2)assistance in the application of safety measures during ground operations with rotors turning (including: crowd control, embarking and disembarking of passengers, refuelling etc.).

(e)There may be exceptional circumstances when it is not possible for the HEMS technical crew member to carry out their primary task as defined under (b). This is to be regarded as exceptional and is only to be conducted at the discretion of the commander, taking into account the dimensions and environment of the HEMS operating site.

(f)When two pilots are carried, there is no requirement for a HEMS technical crew member, provided that the pilot monitoring performs the aviation tasks of a technical crew member.

(g)When selecting flight crew in accordance with SPA.HEMS.130(a), for single-pilot operations the operator should consider the experience of both the pilot and the technical crew member.

(1)The operator should consider that a HEMS technical crew member is inexperienced until he or she has completed 50 HEMS missions. The operator may include HEMS missions flown during line flying under supervision.

(2)When an inexperienced HEMS technical crew member is part of the crew, the following should apply:

(i)the pilot has achieved 50 flight hours on the type within a period of 60 days since the completion of the operator’s conversion course on the type; or

(ii)the pilot has achieved 100 flight hours on the type since the completion of the operator’s conversion course on the type.

(3)A smaller number of flight hours or missions than those defined in (1) or (2) above, and subject to any other conditions which the competent authority may impose, may be acceptable to the competent authority when one of the following applies:

(i)a new operator commences operations;

(ii)an operator introduces a new helicopter type;

(iii)the pilot has previously completed a type conversion course with the same operator (reconversion);

(iv)credits are defined in the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012.

REDUCTION OF THE CREW COMPOSITION — SINGLE-PILOT OPERATIONS WITH NO TECHNICAL CREW MEMBER

(a)The commander should decide whether he or she needs the assistance of a technical crew member, or if the technical crew member can be relieved from flight duties to provide medical assistance from the cabin or on site.

(b)When relieved from flight duties at a HEMS operating site, the technical crew member should take part in the departure briefing that summarises the relevant obstacles and threats.

CONTINUITY OF THE CREW CONCEPT The crew concept includes the operator’s normal crew composition and variations to it that the operator accepts that will occur during the HEMS mission. The operator ensures the continuity of the crew concept by managing these variations.

FLIGHT CREW TRAINING AND CHECKING SYLLABUS

(a)The flight crew initial and recurrent training syllabus should include the following items:

(1)meteorological training focusing on the understanding and interpretation of available weather information;

(2)preparing the helicopter and specialist medical equipment for subsequent HEMS departure;

(3)practice of HEMS departures;

(4)the assessment from the air of the suitability of HEMS operating sites; and

(5)the medical effects air transport may have on the patient.

(b)Single-pilot operations

(1)The flight crew training syllabus should include initial and annual recurrent helicopter/FSTD training focusing on crew cooperation with the technical crew member.

(2)The initial training should include at least 4 hours flight instruction dedicated to crew cooperation unless:

(i)the pilot holds a certificate of satisfactory completion of a multi-crew cooperation course in accordance with Commission Regulation (EU) No 1178/2011; or

(ii)the pilot has at least 500 hours in either multi-pilot operations or single-pilot operations with a HEMS or equivalent technical crew member, or a combination of these.

(3)The training described in (1) and (2) above should be organised with a crew composition of one pilot and one technical crew member.

(4)The training described in (1) and (2) should be conducted by a suitably qualified commander with a minimum experience of 350 hours in either multi-pilot operations or single-pilot operations with a HEMS technical crew member, or a combination of these.

(c)The flight crew checking syllabus should include:

(1)proficiency checks, which should include landing and take-off profiles likely to be used at HEMS operating sites; and

(2)line checks, with special emphasis on all of the following:

(i)local area meteorology;

(ii)HEMS flight planning;

(iii)HEMS departures;

(iv)the selection from the air of HEMS operating sites;

(v)low-level flight in poor weather;

(vi)familiarity with established HEMS operating sites in the operator’s local area register;

(vii)crew cooperation.

HEMS TECHNICAL CREW MEMBER TRAINING AND CHECKING SYLLABUS

INITIAL AND RECURRENT TRAINING COVERING PRIMARY TASKS

(a)The HEMS technical crew member initial and recurrent training and checking syllabus required by SPA.HEMS.130(f)(1) and covering primary tasks as defined in point (b) of AMC1 SPA.HEMS.130(e), and tasks required by the operator’s refuelling procedure in compliance with SPA.HEMS.155, and meeting the objectives of points (e)(3) and (f)(2) of SPA.HEMS.130 should include the following items:

(1)Applicable laws and regulations;

(2)Helicopter general knowledge:

(i)stowage, cabin safety and use of on-board medical equipment;

(ii)general knowledge of helicopter operations;

(3)Meteorology;

(4)Operational procedures:

(i)company procedures;

(ii)duties in the HEMS role;

(ii)response to HEMS dispatch;

(iii)HEMS operating site selection and use;

(iv)patients;

(v)portable electronic devices and electronic flight bags, as applicable;

(5)Crew coordination including checklists;

(6)Human performance and limitations, CRM;

(7)Flight safety:

(i)general flight safety in helicopter operations;

(ii)obstacle and traffic clearance;

(iii)handling of abnormal and emergency situations including checklists;

(iv)dangerous goods (DGs), as relevant for HEMS operation;

(8)Security.

NAVIGATION TRAINING

(b)If the HEMS technical crew member is tasked to provide assistance in navigation, as defined in AMC1 SPA.HEMS.130(e), points (c)(1) and (c)(2), the initial and recurrent training and checking syllabus should also include the following items:

(1)applicable parts of SERA, as relevant to the navigation tasks of the HEMS crew member;

(2)basic navigation training;

(3)navigation aid principles and use;

(4)airspace, restricted areas, and noise-abatement procedures;

(5)crew coordination.

COMMUNICATION TRAINING

(c)If the HEMS technical crew member is tasked to provide assistance in radio communications as defined in AMC1 SPA.HEMS.130(e), points (c)(2) and (c)(3), the initial and recurrent training and checking syllabus should also include the following items:

(1)operation of relevant radio equipment;

(2)crew coordination.

MONITORING TRAINING

(d)If the HEMS technical crew member is tasked to provide assistance in monitoring the flight path and instruments as defined in AMC1 SPA.HEMS.130(e), point (c)(5), the initial and recurrent training and checking syllabus should also include the following items:

(1)general knowledge of helicopter operations;

(2)monitoring function;

(3)crew coordination;

(4)handling of abnormal and emergency situations, as applicable.

GROUND CREW TRAINING

(e)If the HEMS technical crew member is tasked to provide assistance to the helicopter on the ground as defined in AMC1 SPA.HEMS.130(e), point (d), the initial and recurrent training and checking syllabus should also include the following items as applicable to their tasks:

(1)safety and security at the HEMS operating site;

(2)the dangers to self and others of rotor running helicopters, including loading of patients;

(3)preparing the helicopter and specialist medical equipment for subsequent HEMS departure;

(4)conducting refuelling, and conducting refuelling with rotors turning;

(5)marshalling signals;

(6)safety on the aerodrome/operating site, including fire prevention and ramp safety areas;

(7)towing of helicopter/trolley. ADDITIONAL TRAINING (as appropriate)

(f)The initial and recurrent training and checking syllabus should also include the following items as relevant to the operations:

(1)HEMS HEC cargo sling operations, as defined in AMC1 SPA.HEMS.105(b);

(2)hoist operations, as defined in SPA.HHO;

(3)NVIS, as defined in SPA.NVIS;

(4)IFR/PBN. CONVERSION COURSE GROUND TRAINING AND CHECKING WHEN CHANGING HELICOPTER TYPES OR CHANGING OPERATORS

(g)The conversion course ground training and checking when changing helicopter types should include the elements of (a) to (f) above that are relevant to the new helicopter type.

(h)The conversion course ground training and checking when changing operators should include the elements of (a) to (f) above that are relevant in the context of changing operators.

INITIAL AIRCRAFT/FSTD TRAINING

(i)The technical crew member training syllabus should include helicopter/FSTD training focusing on crew cooperation with the pilot.

(1)The initial training should include at least 4 hours instruction dedicated to crew cooperation unless:

(i)the HEMS crew member has undergone this training under another operator; or

(ii)the HEMS crew member has performed at least 50 missions in HEMS or equivalent role as a technical crew member.

(2)The training described in (1) above should be organised with a crew composition of one pilot and one technical crew member.

(3)The training may be combined with the line flying under supervision.

LINE FLYING UNDER SUPERVISION

(j)Line flying under supervision

(1)Line flying under supervision should take place during the operator’s conversion course.

(2)Line flights under supervision provide the opportunity for a HEMS technical crew member to practise the procedures and techniques he or she should be familiar with, regarding ground and flight operations, including any elements that are specific to a particular helicopter type. Upon completion of the line flying under supervision, the HEMS technical crew member should be able to safely conduct the flight operational duties assigned to him or her according to the procedures laid down in the operator’s operations manual.

(4)For the conversion course that takes place when joining the operator, line flying under supervision should include a minimum of five sectors. These sectors should include a minimum of one low-height en-route transit and a minimum of three HEMS operating sites that the technical crew member is not familiar with.

RECURRENT AIRCRAFT/FSTD TRAINING

(k)Recurrent helicopter/FSTD training

(1)The recurrent training should focus on crew cooperation and include a minimum of 2 hours of flight.

(2)The training described in (1) above should take place in the same conditions as the initial training in (i) above.

(3)The validity period of the aircraft/FSTD training should be 12 calendar months.

LINE CHECKS

(l)Line checks

(1)The line check should be performed during a HEMS mission. If practically necessary, because of the difficulty to anticipate an actual HEMS activity or a cabin layout or helicopter performance making it difficult to carry an extra person, a helicopter flight representative of a HEMS mission may be carried out for the purpose of the line check.

(2)The operator’s conversion course should include a line check. The line check should take place after the completion of the line flying under supervision.

(3)Any task-specific items may be checked by a suitably qualified HEMS technical crew member nominated by the operator and trained in CRM concepts and the assessment of non-technical skills.

OPERATOR PROFICIENCY CHECKS

(m)Operator proficiency checks

(1)The HEMS technical crew member should complete an operator proficiency check to demonstrate his or her competence in carrying out normal, abnormal and emergency procedures, covering the relevant aspects associated with the flight operational tasks described in the operations manual and not already covered in the line check.

(2)The conversion course should include an operator proficiency check.

(3)The operator proficiency check should be valid for a given helicopter type. In order to consider an operator proficiency check to be valid for several helicopter types, the operator should demonstrate that the types are sufficiently similar from the technical crew member’s perspective.

PROVISION OF TRAINING AND CHECKING

(n)Use of FSTDs

(1)The line check and line flying under supervision should be performed in the helicopter.

(2)Notwithstanding (1), the operator may perform the line check in two parts, in a suitable FSTD and on ground, if all of the following conditions are met:

(i)The FSTD part of the line check takes place in a line-oriented evaluation;

(ii)The ground part of the line check takes place at the HEMS operating base and includes all normal operating procedures not checked in the FSTD;

(iii)Both parts of the line check are conducted within 3 months of each other;

(iv)For the purpose of AMC1 SPA.HEMS.130, the line check is considered to be performed on the day when the last part of the line check is completed;

(v)For the purpose of (ii), the operator should arrange to replicate realistic conditions as much as practicable, so that normal operating procedures that take place on ground at the HEMS operating site are also checked.

(3)Operator proficiency checks and aircraft/FSTD training should be performed in an suitable FSTD or, if it is not reasonably practicable to gain access to such devices, in an aircraft of the same type.

(o)Emergency and safety equipment training should be performed in a representative training device or in an aircraft of the same type.

(p)The type of equipment used for training and checking should be representative of the instrumentation, equipment and layout of the aircraft type operated by the crew member.

(q)Training and checking in the aircraft/FSTD should take place as part of the normal crew complement.

(r)The person conducting the training and checking should be a suitably qualified commander nominated by the operator. In the case of the training described in (i)(1) and (k)(1) above, the person conducting the training should have a minimum experience of 350 hours in either multipilot operations or single-pilot operations with a HEMS technical crew member or a combination of these. The person conducting a CRM assessment should be trained in CRM concepts and the assessment of CRM skills.

(s)Notwithstanding (r), the person conducting the training and checking of tasks conducted in the cabin where crew cooperation is not essential may be a suitably qualified technical crew member nominated by the operator.

CRM ASSESSMENT OF THE HEMS TECHNICAL CREW MEMBER

(t)A CRM assessment should take place during the line check or should take place annually in a line-oriented flight scenario (LOFT or line-oriented section of the OPC) of an FSTD session in a suitable FSTD. The CRM assessment in the helicopter should take place as described for pilots in AMC1 ORO.FC.230 point (b)(3)(vi) or (b)(3)(vii).

HEMS TECHNICAL CREW MEMBER THEORETICAL TRAINING

(a)The HEMS technical crew member training and checking syllabus required by SPA.HEMS.130(f)(1) may be adapted to the knowledge of the technical crew member and structured as shown in Table 1. Table 1 — HEMS technical crew member training

* applicable to trainees that have passed the theoretical knowledge examination for at least PPL(H) or that hold at least a PPL(H). ** applicable to trainees that have passed the theoretical knowledge examination for at least PPL(A) or that hold at least a PPL(A).

(b)The operator may consider that trainees that have passed the theoretical knowledge examination for at least PPL(A) or PPL(H) or that hold at least a PPL(A) or PPL(H) do not require additional navigation training. In all other cases, if the HEMS technical crew member is tasked to provide assistance in navigation, the navigation training may be structured as follows:

(1)Applicable parts of SERA, as relevant to the navigation tasks of the HEMS crew member;

(2)Basic navigation training:

(i)charts (convergence, scale, projections, symbology, plotting);

(ii)measuring distances and courses;

(iii)ability to keep track with helicopter position on map;

(iv)moving map if applicable;

(v)identification of obstacles and conflicting terrain;

(vi)time (local/UTC, sunrise/sunset) and speed;

(vii)units and unit conversion;

(3)Principles and use of navigation aids:

(i)navigation equipment and AFCS operations as applicable;

(ii)transponder;

(iii)ACAS, HTAWS, weather radar, moving map as applicable;

(iv)inadvertent IMC;

(4)Airspace, restricted areas, and noise-abatement procedures:

(i)air traffic services;

(ii)aerodrome procedures;

(iii)AIP;

(iv)NOTAMS;

(5)Crew coordination: assignment of navigation tasks.

(c)The operator may consider that trainees that have passed the theoretical knowledge examination for at least PPL(A) or PPL(H) or that hold at least a PPL(A) or PPL(H) licence do not require additional navigation training. In all other cases, if the HEMS technical crew member is tasked to provide assistance in radio communications, the radio communications training may be structured as follows:

(1)Operation of relevant radio equipment: radio licence as applicable to the frequencies used by the technical crew member

(2)Crew coordination: effective use of radio communication system

(d)If the HEMS technical crew member is tasked to provide assistance in monitoring, the training towards monitoring may be adapted to the knowledge of the technical crew member and structured as shown in Table 2. Table 2 — HEMS technical crew member monitoring training

* applicable to trainees that have passed the theoretical knowledge examination for at least PPL(H) or that hold at least a PPL(H). ** applicable to trainees that have passed the theoretical knowledge examination for at least PPL(A) or that hold at least a PPL(A).

(e)If the HEMS technical crew member is involved in flights under IFR, the additional training towards flights under IFR may be structured as follows:

(1)introduction to IFR operations covering IFR parts of the operations manual, including MEL

(2)applicable parts of SERA

(3)human performance and limitations

(4)navigation sources, charts, and procedures

(5)navigation equipment and AFCS operations as applicable

(6)flight instrument systems

(7)ACAS, HTAWS, weather radar, moving map as applicable

(8)air traffic control

(9)meteorology as relevant to the operating area

(10)flight planning

(f)If the HEMS technical crew member is tasked to provide assistance on the ground or is involved in operations under a specific approval, the training towards these tasks may be structured as in AMC2 SPA.HEMS.130(f)(1).

HEMS TECHNICAL CREW MEMBER OBSERVATION FLIGHTS If the candidate HEMS crew member has no flight experience as technical crew member, flight crew member or student pilot in day VMC, night VMC or IMC, the operator may provide observation flights on HEMS missions in day/night VMC and IMC as relevant, prior to the helicopter/FSTD training, once the ground training and checking of the conversion course has been completed, as part of the detailed training syllabus defined in SPA.HEMS.130(f)(1).

USE OF HEMS OPERATING SITES FOR TRAINING AND CHECKING In order to ensure that the training and checking is relevant to the duties of the crew members and ground personnel as required by ORO.GEN.110(e), the operator may define HEMS operating sites for the purpose of the HEMS training and checking required in SPA.HEMS.130, including training for HEMS HEC operations, except for the initial part of the training. The training and checking may involve all personnel necessary to the HEMS mission.

LINE CHECKS Where due to the size, the configuration, or the performance of the helicopter, the line check cannot be conducted on an operational flight, it may be conducted on a specially arranged representative flight. This flight may be immediately adjacent to, but not simultaneous with, one of the biannual proficiency checks.

Operators should identify, as part of their safety risk assessment process, additional risks for flight crew members who have attained the age of 60 years and who perform single-pilot HEMS operations in accordance with point FCL.065(a) of Annex I (Part-FCL) to Regulation (EU) No 1178/2011, including the negative effects of fatigue as a cardiovascular and cerebrovascular risk factor, and take appropriate action to effectively mitigate those risks.

BEST PRACTICES FOR FLIGHT CREW MEMBERS ABOVE THE AGE OF 60 PERFORMING SINGLE-PILOT HEMS OPERATIONS Several studies have found that, in general, the frequent exposure of working population to long working hours (≥55 hours per week), frequent overtime work (34 hours overtime) or shift work is associated with increased risk of cardiovascular disease (CVD) — including of fatal and non-fatal coronary heart disease (CHD) and atrial fibrillation — and cerebrovascular disease such as stroke. In the context of the association of long work hours, overtime work and shift work with an increased CVD risk, some authors recommend for general population countermeasures such as a limit of operation time to 40 hrs/week and working time up to 10 hours within 24 hours (Virtanen et al., 2018). Although such operational limitations might be considered to apply for pilots from the age of 60 onwards, it is not clear, due to lack of dedicated studies, how that will affect the cumulative CVD risk after numerous years of exposure to long and irregular working hours before their 60th birthday. However, by limiting the working hours the risk for CVD and cerebrovascular disease will not be further increased due to fatigue and, with time passing, this risk is expected to gradually reduce. A working hour limitation could also lead to a reduction in fatigue and an increase in the recovery of older pilots. With regard to the above-mentioned considerations, it should be emphasised that sufficient sleep of good quality is the key factor in preventing fatigue and maintaining optimal performance and good health. Ideally, a pilot should have a continuous 8-hour sleep opportunity per 24 hours. Sleep should be facilitated in a dark and quiet environment allowing horizontal rest. Where the ideal 8hour continuous rest is not possible due to operational constrains, the operator could consider additional mitigating measures within their FRMS/SMS. The operators should also give proper consideration to the period of the day when this rest period is scheduled in relation to the circadian rhythm of the flight crew members. Operators could consider implementing an FRMS tailored to the specific operational demands of the company. Pilots and managers should be educated to stimulate awareness of the safety implications of fatigue, recognise the signs of fatigue, and how to prevent fatigue by sufficient sleep and strategic naps. Basic principles to consider for HEMS operators:

(a)Form a fatigue safety action group including manager/head of flight operations, planner, pilot(s)

(b)Identify potential fatigue hazards, including accumulation of fatigue

(c)Assess fatiguing rosters (e.g. this can simply be done using the Karolinska Sleepiness Scale or the Samn-Perelli Fatigue Scale in conjunction with an assessment of the sleep duration and quality using a simple scale)

(d)Estimate risk associated with an identifiable hazard

(e)Redesign rosters/rotations in coordination with stakeholders

(f)Monitor reduction of risk (e.g. using the Karolinska Sleepiness Scale or the Samn-Perelli Fatigue Scale in conjunction with an assessment of the sleep duration and quality using a simple scale)

(g)Provide procedures and training (if necessary, this might be done by (an) external expert(s) and online)

(h)Make use of the continuous improvement plan-do-check-act principle of the SMS

TRAINING AND CHECKING OF PILOTS ABOVE THE AGE OF 60 PERFORMING SINGLE-PILOT HEMS OPERATIONS

(a)Initial training for the personnel providing the training and checking for pilots above the age of 60 performing single-pilot HEMS operations should aim to raise their awareness regarding the signs and operational impact of mild cognitive decline, as well as the reporting process to the medical assessor of the licensing authority, and the confidentiality principles to be considered. In developing such training, proper consideration should be given to the information provided in GM1 SPA.HEMS.130(g)(2) and GM2 SPA.HEMS.130(g)(2). The duration of the training should not exceed 6 hours. Recurrent training may be considered based on the operator’s assessment.

(b)The training should ensure that personnel providing training and checking for this category of pilots are able to perform the following tasks: detect and document, to the best of their abilities, any signs of cognitive decline; consider essential cognitive factors contributing to flight performance when conducting regular mandatory operator proficiency checks (OPCs). In order to do this, attention should be focused in particular on the ability to function under highly stressful demands, such as, but not limited to, abnormal and emergency procedures under high time pressure; discuss their concerns with the pilot in question encouraging them to self-report the problems to their AME/AeMC or to a peer support programme, and when any signs of cognitive decline have been identified or are suspected, share, without undue delay, the report with the medical assessor of the licensing authority, as defined in Part-MED, for further assessment, in accordance with principles of medical confidentiality.

(a)Information for examiners about operational signs of cognitive performance deficits Cognition encompasses many aspects of intellectual functions and processes such as perception, attention, thought, the formation of knowledge, memory and working memory, judgement and evaluation, reasoning and computation, problem-solving and decision-making, comprehension and production of language. Cognitive processes use existing knowledge and discover new knowledge. Cognitive decline is considered to begin from 40 years of age. There is large variation in the extent and functional effects of age-related impairment between people of the same age. The most important changes in cognition with normal ageing are declines in performance of cognitive tasks that require one to quickly process or transform information to make a decision, including measures of speed of processing, working memory and executive cognitive function.

(b)Cognitive functions and aviation The cognitive functions that are generally assumed to impair with increasing age and considered important for the proper performance of all flying tasks are:

(1)problem-solving and decision-making (e.g. diagnosis of faults and defects and taking action);

(2)information processing within a required time frame (e.g. process the information of flight, navigation and engine instruments, primary flight displays, radar, TCAS, radio voice communications, data-link, direct vision, crew member communication, vibrations, noises and smells). With tasks involving both speed and accuracy, older people tend to attach greater importance to accuracy, thereby slowing their speed of response;

(3)perception (e.g. instrument monitoring);

(4)memory (e.g. recall information given by air traffic control);

(5)psychomotor coordination (e.g. flight control). Signs of cognitive impairment can relate to any or all of the five functions listed above. It is generally accepted that experience can counter cognitive decline in active pilots up to a certain level. When assessing cognitive function in relation to flight performance during the regular OPCs, the examiner may consider the List of competency elements and performance criteria described in points (g) through (o) of GM1 to Appendix 5 to Annex I (Part-FCL) to Regulation (EU) 1178/2011 with particular focus on the following points: attitudes and behaviours appropriate to the safe conduct of flight, including recognising and managing potential threats and errors; management of abnormal and emergency situations; communication with ATC, ground personnel and crew, and HEMS crew. Particular attention on the ability to function under highly stressful demands, such as high time pressure, is expected to allow the examiner to detect deficits and refer the respective case to the medical assessor of the licensing authority.

(a)Considerations concerning confidentiality when reporting possible signs of cognitive performance deficits of a pilot to the licensing authority EU and national personal data protection regulations should be observed in all cases involving processing of personal data, including transferring of personal data to competent authorities and medical professionals. Medical confidentiality related to the aero-medical assessments is strictly protected by point MED.A.015 of Annex IV (Part-MED) to Regulation (EU) No 1178/2011. Regardless of the fact that the assessment of cognitive performance is not a medical examination and hence not covered by the provisions of point MED.A.015, the principles of confidentiality should be observed at all times. Confidentiality of medical records is an important ethical and legal duty of all parties involved and can only be superseded by the requirement to address imminent and high risks of harm to involved or third parties. In the context of the application of point SPA.HEMS.130(g)(2), this means that, when processing information containing health-related data, examiners involved are subject to the requirements of EU and national personal data protection regulations. As a consequence, the information, that the examiner will report to medical assessor of the licensing authority of the pilot concerned, should be clearly described in a privacy notice provided to pilots prior to the proficiency check specified in point (b) of AMC1 SPA.HEM.130(g)(2). When examiners detect a cognitive performance deficit of pilots, the personal data of these pilots should be shared only with the medical assessor of the licensing authority of the pilot concerned. When such sharing of personal data is needed, the examiner should inform the pilot concerned.

(b)Additional considerations and examples It is anticipated that in the context of recurrent checking tests examiners may not come in a position where they have to breach confidentiality related to observed signs of neurocognitive performance deficits. Nevertheless, such situations may take place occasionally. Below we present several best practices to consider in various scenarios:

(1)If neurocognitive performance deficits (see the report ‘Extending age limits of HEMS pilots to 65 years – mental health and cognitive screening’) cause failure or partial failure of the proficiency check, the result of the check will be reported to the authority and the pilot will not be allowed to exercise the privileges of their licence/rating pending the results of a new evaluation. While the pilot is grounded, flight safety will not be imminently endangered; nevertheless, the examiner should report the situation to the medical assessor of the licensing authority of the pilot allowing for additional medical investigations. In such a case, the examiner should provide a report based on identifiable factual items explaining why the pilot’s performance did not meet the required standards. In case there are signs of a cognitive performance deficit, the medical assessor of the licensing authority may demand a neurophysiological assessment before a re-examination check is to be performed.

(2)If a result of a check is sufficient only by the narrowest margin and the examiner has found one or more possible sign(s) of cognitive performance deficit, the examiner should explain their concerns to the pilot and seek the consent of the pilot to share the concerns with the medical assessor of the licensing authority in order to discuss monitoring of possible cognitive decline by shortening the interval between the last and the next check and/or a neurophysiological assessment. In such cases, the examiner should describe their concerns in operational terms based on identifiable factual items explaining why the pilot’s performance is borderline to meet the required standards such as ‘situational assessment and decision-making on engine failures took longer time than commonly needed’ (which relates to the cognitive function of problemsolving and decision making). Where the pilot refuses to give consent regarding the notification to the licensing authority, the examiner performing the proficiency check should consider taking appropriate measures to remove the respective pilot from flying duties in the interest of flight safety, while at the same time reporting the situation to the medical assessor of the licensing authority of the pilot. In that case, the examiner could consider paying special attention to signs of cognitive performance deficit(s) during a next check.

(3)In the case that a pilot has successfully passed the check, demonstrating that their performance is sufficient to exercise the privileges of the licence/rating, it can be considered that there is no evidence of any cognitive decline that would negatively impact flight safety in the interval before the next check and, consequently, no further measures are needed.