As a member of the Medevac Committee, I participated in the development of the proposed regulations 3-4 years ago.  Given that time span and reviewing them in the present, I have two areas that appear to need more detail.  Thank you for your time and consideration.

12VAC5-31-880 Air Medical service personnel classifications

Section 4 a Prehospital Scene:

Reading this regulation, it would allow a medevac to have only one flight trained EMTP and the other "attendant" as defined in #1 could be a ground EMTP without flight training.  Given the specialized nature of air medicine and the focus on safety, both members in a medevac helicopter should be, at the minimum, EMTP with specialized air medical training (#1b, #3) . It is not acceptable to have only one member with specific flight training.  Safety is the primary concern and flight trained personnel have specific training to:  assist with communications in the cockpit, identify hazards (both air to air and LZ), crash or event actions, and general aviation and air medical safety culture training.  I request that consideration be made so that the minimum crew make up be two flight trained EMTP.  This should also extend to #1b, #1 which would require a physician (if he/she were the second crew member) to have air medical training. 

12VAC5-31-890 Equipment

#3 Should include language that clearly states that the design and dimensions of the interior cabin eliminate or address head strike areas.  Areas that could be a head strike concern, should be padded and other eliminated (if possible).  The proposed regulation begins to address the issue but misses the key point that these areas should not be in cabin. 

We have a duty to ensure that the design specifications clearly guard our air medical services not to have unsafe design.  Though helmets are worn, they to not fully protect the air medical team from significant injury due to poorly addressed or designed head strike areas.  Head strike areas are usually items such as:  additional equipment (that could be mounted in other areas), radio heads (padding), O2 regulators (flush mount regulators could reduce risk), etc. 

I, again, than you for your time and appreciate all of the hard work that the Regulation Division places in the development and maturing of our EMS regulations.