EMERGENCY MEDICAL SERVICES WORKSHOP

Participants

Approximately 60 representatives from various EMS companies, government agencies, airlines and charter companies attended the workshop.

It included the Department of Health, Ambulance and Emergency Medical Services: KZNPA, S.A. Red Cross, SAA, SA Express, Comair, MRI, Europ Assistance, International SOS, Medair, Rossair, Medicair, Air Ambulance Africa, Charlan Air Charters, Court Helicopters, Zephyr Flo Aeronautics, FJC Aviation Consultants, South African Society for Aerospace and Environmental Medicine, Institute for Aviation Medicine, ALPA and various aviation consultants.

Opening and welcome

Mr. Trevor Abrahams, the Commissioner for Civil Aviation, welcomed the participants. He expressed his pleasure at the interest shown by the industry and assured participants that it was the CAA’s goal to promote aviation safety through partnerships with the industry. He also stated that regulations should be written to be in accordance with our ICAO obligations, consistent with international best practicepractical, attainable and ,enforceable and accessible to the aviation community in terms of language. The objective of the workshop was to discuss the uncertainties and problems experienced by the industry pertaining to Part 138 of the Regulations (Emergency Medical Service Operations) and to discuss possible solutions to rectify the situation.

Presentations and discussions

Dr. Ansa Jordaan, aviation medical officer of the CAA, presented a summary of uncertainties pertaining to the regulations, based on questions and complaints forwarded to the CAA. Mr. Colin Weir of Zephyr Flow Aeronautics and Mr Steve Anderson of Medair also presented their viewpoints on problems experienced with the current regulations. All the representatives participated in the discussions. The CAA also presented a summary of international practice relating to emergency medical service operations (EMS).

All participants agreed that the provision of a high standard of medical care, whilst maintaining aviation safety, must be the objectives of EMS in South Africa. The following problems were identified by the industry:

1. The industry had very little input when the initial regulations were compiled
2. The Department of Health was not consulted prior to writing the regulations
3. The requirements may be acceptable for operators of "dedicated air ambulances", but are too strict and costly for smaller charter operators (that only does a few emergency flights on an irregular basis), which precludes them from obtaining the G7 license required
4. Requirements as prescribed in part 138 is not clearly written
5. The issue of a G7 satellite base has not been addressed
6. No provision is made for true life-threatening situations where a Part 138 operator may not be available for transport of a patient
7. No provision is made for sea and mountain rescue operations (or for cases of national disasters)
8. Present regulations preclude the delivery of service in all geographical areas of South Africa
9. Requirements for pilots are too strict, especially for smaller charter operators
10. No specific requirements are included for helicopter operations
11. There is no national standard of training for air crew and medical personnel involved in EMS operations
12. Certain areas of community health has not been addressed e.g. notification of transportation of patients with communicable diseases, international health regulations, disinfecting of aircraft, etc.
13. No procedures are required for customs and immigration purposes while transporting ill passengers
14. Some of the regulations are not enforceable e.g. requirements for oxygen cylinders
15. Some of the regulations are unnecessary e.g. CAA approving stretchers again after it has already been approved by the FAA
16. Regulations in other parts of the CARs such as Part 121 regarding limitations on carriage of passengers with disability also needs to be reviewed
17. Operators may not be fully covered for liability e.g. insurance against aggravation of a patient’s condition
18. The absence of a national South African Air Ambulance Organisation in South Africa
19. The absence of communication and co-operation amongst EMS providers in South Africa

Suggested proposed model by the CAA

The CAA proposed that:

1. Provision should be made for the transport of patients under life-threatening conditions
2. The CAA must be responsible for oversight of the flight safety side of EMS operations
3. The Department of Health must ultimately be responsible for the oversight of level of patient care in EMS operations ( initially, however, the CAA will need to advise them – ideally the Department of Health and the CAA should be working side by side)
4. If a patient requires medical care and equipment, the operation must be conducted according to Part 138
5. Training for flight crew and medical personnel involved in EMS operations should be standardized and must be accredited by the CAA and the Department of Health
6. Operators must maintain a register of accredited flight crew and medical personnel
7. The CAA must establish an organized forum through which all professionals involved with air medical transport can participate and debate to solve problems
8. The industry should form a national air ambulance association to liaise with relevant organisations and to establish uniform operating protocols
9. The CAA, in collaboration with the Department of Health and the Air Ambulance Association, must establish a Commission for accreditation of operators and medical service providers

Decisions

a. Most of the proposals suggested by the CAA were accepted and a workgroup was identified to:

1. Investigate the viability of establishing an organisation to determine and monitor the standards for regulation of the air ambulance industry – including training standards
   
   
2. Identify a committee and render assistance in defining different levels of accreditation for EMS operations
   
   
3. Assist in the review and amendments in the Regulations of Part 138 and other relevant Parts

The CAA will chair the workgroup. Other organisations and persons forming part of the workgroup include: Department of Health, Institute for Aviation Medicine, Licensing Council, South African Society for Aerospace and Environmental medicine, ALPA, HASA, The Red Cross Society, Dr. K Boffard (Professor of Trauma Unit, Johannesburg General Hospital), Mr. Anderson (Medair), Ms Fouchee (FJC Aviation Consultants), Ms Ferguson (MRI), Mr Weir ( Zephyr Flo Aeronautics), Mr. Beek (Aviation Consultant) and Mr Olivier (Medijet)

The workgroup’s first meeting will take place on 2 March 2000 and they will report back to all participants on 17 March on progress made.

b. Part 138 will be reviewed to apply to dedicated air ambulance operations (or operators of which the core business is transport of patients), while existing regulations will be reviewed to provide for smaller air charters as well – possibly a requirement for a class II license (or a G7 license) . Different levels will be established for dedicated aircraft functioning as air ambulances and aircraft being converted to function as air ambulances

Interim measure

In the interim, EMS operations will function as described on the CAA web site: Operators of which the core business is EMS operations, must comply with Part 138. Other operators, for which the core business is not EMS operations, but does EMS operations on an infrequent basis, will have to comply with Parts 121, 127 and 135.

The CAA will address this in more detail in the next two weeks (e.g. defining core business) and will publish the result on the web site, to function as interim measure while Part 138 is in the process of review and amendment.