19 Mar 15

To: Federal Aviation Administration

 cc. Brian Foster, VP, Flight Operations

 Bert Levesque, Director of Operation, MTC

 Donald Savage, Chief Pilot, MTC

 

From: Michael H. LaMee, Chief of Training and Standardization, MTC

Subject: Request for Exemption to 14 CFR § 43.3(a)

Med-Trans Corporation is requesting an exemption to § 43.3(a) which states, in pertinent 

part, except as provided in this section and § 43.17, no person may maintain, rebuild, 

alter, or perform preventive maintenance on and aircraft, airframe, aircraft engine, 

propeller, appliance, or component part to which this part applies. The application of this 

exemption would be for properly trained medical personnel to perform the insertion and 

removal of litter systems, isolettes and secondary stretcher systems (all of which are 

addressed in each aircrafts EMS Rotorcraft Flight Manual Supplement) in the EC-135 

and EC-155 aircraft operated by Med-Trans Corporation.

Background:

The EC-135 and EC-155 aircraft operated by Med-Trans Corporation have the Metro 

Aviation, FAA approved EMS configuration which allows for more than one loading 

schedule. All of these loading schedules are described in the respective Rotorcraft Flight 

Manual Supplement. These supplements allow for the use of the standard patient litter, 

the isolette litter system and also the dual patient configuration. No tooling is required 

when switching between litter systems or when changing the loading schedule for dual 

patients. Medical personnel and pilots receive initial and recurrent training/qualification 

on these processes IAW the Med-Trans Training Manual. The successful completion of 

this training is documented on the Aircraft Orientation and Safety Training Form (also 

found in the Med-Trans Corporation Training Manual). The weight and balance program 

used by our organization provides for accurate adjustments to the actual aircraft weigh 

and center of gravity variances for these various loading schedules. This has not 

historically been viewed as a maintenance function by our Certificate Management Team 

(CMT) as no tooling is required and all of the various loading schedules are covered 

under the Rotorcraft Flight Manual EMS Configuration Supplement. Recently our CMT 

has changed their view on the interpretation of § 43.3(a) and state that this rule now 

applies to the above discussed variances to the loading schedule. 
The ingress/egress of the litter system and isolette system are identical. The release 

and locking mechanisms are the same and there is no changing of mounts or hardware 

required. The only difference is the part number for each component. For the 

installation of the secondary litter, again no tooling is required. The EC-135 EMS 

configuration includes a “third rider” seat that has latches/quick releases that allow for 

the flipping up and stowing of this seat to allow the insertion of the secondary litter which 

is normally stowed against the side bulkhead in the cabin. Again this process requires 

no tooling.

This exemption is also being requested as to not unduly delay patient care in their critical 

time of need. Without this exemption it would necessitate the pilot shutting down the 

aircraft (even on an accident scene if the secondary litter is needed) and then personally 

performing these changes to the loading schedule, which would add several minutes of 

unnecessary ground time.

This would also have a significant impact to neonate (newborn child) transports. Without 

this exemption the aircraft would need to be shut down, if already running, to switch 

between the primary litter and the isolette. The aircraft already running is not uncommon 

due to follow on flight requests or when the aircraft must be relocated to retrieve the 

specialty medical team and isollete system. A conservative estimate for this to take 

place would be at least 10 minutes due to the amount of time it takes to perform the 

aircraft shutdown and run-up with all required checks.

It is our organizations proposal, if this exemption is granted, that pilots and medical 

personnel be given initial and annual recurrent training on the stretcher, isolette and 

secondary litter systems operations. This training will be conducted in accordance with 

the Med-Trans Corporation Training Manual. Successful completion of training will be 

documented on the EC-135/155 Aircraft Orientation and Safety Training Form and this 

documentation will be verified and retained by our certificate. The aircraft weight and 

balance program will be appropriately adjusted each time the loading schedule is 

changed and accurately reflect the current status of the aircraft.

For reference, included with this request are the Rotorcraft Flight Manuals for the EMS 

Configurations discussed.

Respectfully,

Michael H. LaMee

Chief of Training & Standardization

Med-Trans Corporation

209 State Highway 121 Bypass

Lewisville, TX 75067

Office: 972-829-8459

Cell: 605-228-4756