19 Mar 15

To: Federal Aviation Administration cc. Brian Foster , VP, Flight O perations Bert Levesque, D irector of Operation , MTC Donald Savage , Chief Pilot , MT C
From: Michael H. LaMee, Chief of Training and Standardization, MTC Subject: Request for Exemption to 14 CFR § 43.3(a) Med
-Trans C orporation 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, propel ler, 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, isolette s 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 appro ved 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 li tter 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 o n these processes IAWthe 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 u sed 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 app lies 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 a nd 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. Wi thout 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 c hanges to the loading schedule, which would a dd several minutes of unnecessary ground time. This would also have a significant impact to neonate (newborn child) transports

. Wi thout this exemption the aircraft would need to be shut down , if already running , to switch between the primary litter and t he 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 Orien tation 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, i ncluded 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 Bypa ss Lewisville, TX 75067 Office: 972
- 829
- 8459 Cell: 605
- 228
-4756