EMS helicopter pilot contends that his company's policy of operating under both far part 91 and part...

Narrative:

While on the part 91 leg (repositioning flight); I was the PIC of [company] EC135. This was the second 'mission' of the evening in which I had flown 6+ hours and did not have a rest period between. At this time [company] had no line pilots and I was the chief pilot. The director of operations had advised me that we were on a 24/7 on-call basis approved with our poi. I was instructed that if a call would be taken I had to have 10 hours rest before the next flight or I had to accomplish multiples of flights within 14 hours and then take a 10 hour required rest period under far part 135 rules; however a refueling or repositioning leg was to fall under far part 91 rules. While on my 'off' time I was required to train new-hire pilots from the hours of xa:00 am to xh:00 pm. On the day prior to the occurrence I was prepping new pilot records in preparation for their arrival. I was asked to do this on my time 'off' and not 'sign in' until a flight was activated. That evening we were activated for one flight that was accomplished and unremarkable; followed by a second flight that was accomplished under far part 135 with no issue. We were on the part 91 leg repositioning the aircraft back to base. This flight had clear VMC weather and no ceiling. The flight originated during the hours of the night and during the part 91 leg had become daylight. It was during this leg while the autopilot was engaged for a direct GPS route at approximately 800 ft AGL that I found myself fatigued during flight. I typically carry an energy drink in my flight suit; however I had taken it earlier during the first flight of that night. I noticed that I was fatigued and would open the pilot's side window and would vent air onto my face to remain alert.I realize that flying while fatigued is a safety risk. I should have landed the aircraft at the closest airport and taken a rest period before continuing to fly home. I believe that helicopter EMS should only be flown under part 135 rules every leg. I also feel that in order to prevent fatigue in the future no medevac operation should be allowed to operate with a single pilot on a 24/7 on-call basis. I also feel medical crewmembers should be essential in ensuring that a pilot is not fatigued. Asking questions; interacting; becoming a part of the crew versus sleeping themselves in the cockpit.

Original NASA ASRS Text

Title: EMS Helicopter pilot contends that his company's policy of operating under both FAR Part 91 and Part 135 subverts crew rest requirements and leads to crew fatigue.

Narrative: While on the Part 91 leg (repositioning flight); I was the PIC of [Company] EC135. This was the second 'mission' of the evening in which I had flown 6+ hours and did not have a rest period between. At this time [Company] had no line pilots and I was the Chief Pilot. The Director of Operations had advised me that we were on a 24/7 on-call basis approved with our POI. I was instructed that if a call would be taken I had to have 10 hours rest before the next flight or I had to accomplish multiples of flights within 14 hours and then take a 10 hour required rest period under FAR part 135 rules; however a refueling or repositioning leg was to fall under FAR part 91 rules. While on my 'off' time I was required to train new-hire pilots from the hours of XA:00 am to XH:00 pm. On the day prior to the occurrence I was prepping new pilot records in preparation for their arrival. I was asked to do this on my time 'off' and not 'sign in' until a flight was activated. That evening we were activated for one flight that was accomplished and unremarkable; followed by a second flight that was accomplished under FAR part 135 with no issue. We were on the Part 91 leg repositioning the aircraft back to base. This flight had clear VMC weather and no ceiling. The flight originated during the hours of the night and during the Part 91 leg had become daylight. It was during this leg while the autopilot was engaged for a direct GPS route at approximately 800 FT AGL that I found myself fatigued during flight. I typically carry an energy drink in my flight suit; however I had taken it earlier during the first flight of that night. I noticed that I was fatigued and would open the pilot's side window and would vent air onto my face to remain alert.I realize that flying while fatigued is a safety risk. I should have landed the aircraft at the closest airport and taken a rest period before continuing to fly home. I believe that helicopter EMS should only be flown under part 135 rules every leg. I also feel that in order to prevent fatigue in the future no MedEvac operation should be allowed to operate with a single pilot on a 24/7 on-call basis. I also feel Medical crewmembers should be essential in ensuring that a pilot is not fatigued. Asking questions; interacting; becoming a part of the crew versus sleeping themselves in the cockpit.

Data retrieved from NASA's ASRS site as of July 2013 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.

Attributes
ACN	1103644
Time
Date	201305
Local Time Of Day	0001-0600
Place
Locale Reference	ZZZ.Airport
State Reference	US
Environment
Flight Conditions	VMC
Light	Dusk
Aircraft 1
Make Model Name	EC 135
Operating Under FAR Part	Part 91
Flight Phase	Cruise
Route In Use	Direct
Flight Plan	None
Person 1
Function	Single Pilot Pilot Flying
Qualification	Flight Crew Flight Instructor Flight Crew Instrument Flight Crew Commercial
Experience	Flight Crew Last 90 Days 40 Flight Crew Total 3200 Flight Crew Type 326
Events
Anomaly	Other Fatigue

EMS helicopter pilot contends that his company's policy of operating under both far part 91 and part 135 subverts crew rest requirements and leads to crew fatigue.