Texas EMTs and Medics who work standby events, please read!

[Skip Goulet]

I have worked standby events in Texas for more than 30 years and have just gotten the slats pulled out from under me, and I would like to hear from other people in the state who do standby service.

For the past couple of years we have sat with our van ambulance at the local racetracks for standby only (no transporting), as we've been unable to certify the ambulance. We can't get medical direction, and the docs all say that since we're doing BLS only, we don't need medical control. TDH says differently. They are trying to shut us down because we have an "ambulance vehicle" with us at the standbys which is unlicensed. They say that just having the van present (although unmarked :no ambulance decals,etc) is illegally "advertising" ourselves as a licensed service when we're not. They've gone so far as to now give me a probated suspension of my EMT cert. for the past standbys we've done.

I would think that this is a bit out of line for them, and would like to see if anyone else has run into a similar situation and how you've worked it out, if at all. Under their their terms, it puts us totally out of operation. Let me hear from you guys and your opinions, experiences.

[Woody76559]

I have to go with TDSHS with this one. Sorry, but there are rules and regulations that must be followed. If they let one service go, then no one should have to license. Any ambulance in the State of Texas MUST be licensed. This is for your protection as well as the patient's. Sorry, but you were in the wrong.

[Richard B the EMT]

Check local protocols, please. Here in NY State, for any gathering over a specified number of expected people, at least one BLS team has to be assigned to the event, for each multiple of that number, with a plan for treatment if the event becomes an MCI ready to be implemented.

Thank the Woodstock Concert, in 1969, for that.

I admit not having any idea if the medical plan includes non transport BLS crews, as each event is probably going to be different, but, as far as I know, all ambulances in the state have to be registered and/or certified by the state DoH to the minimum standards.

As a mention, I attended a "Brooklyn Cyclones" game at "Keyspan Park" (Steeplechase Park, Coney Island, Brooklyn, NY, and they won, beating the New Jersey Cardinals). No ambulance there, but saw at least 6 uniformed EMTs from the Midwood Ambulance Service (Brooklyn, NY) working medical coverage, they told me if a transport is needed, either they call in a line ambulance from their agency, or call 911 for a FDNY EMS ambulance.

[Skip Goulet]

Woody: Ordinarily I would agree with you; but in this instance, you're a bit off base. While TDH requires all emergency ambulances to be licensed (EMS provider's license), the state has never (and still doesn't) require certification/licensure for non-emergency or non-transport ambulances (which is where we fit in). Via this board, I spoke to a gentleman who lives somewhere near Dallas and is with a group called "North Texas Paramedics". Like us, they provide standby service for local sporting events...mostly motocross from what I understand. They have a Type II van that they use at these events, but like our unit, it is unlicensed and is not used for transport. TDH doesn't bother these guys. Likewise, the people who own the dragstrip at Penwell (west of Odessa) have their own ambulance vehicle which, again, is unlicensed and not used for transport. They contract with Odessa Fire Dept paramedics for standby service (off-duty Medics, I should add). They use this vehicle in and around the racetrack environs and for on-track transport purposes, and to provide a sheltered area for patients. Obviously they stabilize as necessary and wait for a city truck to arrive for transport.

I managed a standby-only service in the Panhandle for more than 20 years. Our units were certified and we did provide transport. There's a big difference there. It's just my opinion, and not biased so, that we simply pissed someone off in the administrative chain one way or another and they're using us just to make an example. I only mentioned two examples of non-transport, unlicensed ambulances here but there are numerous others in Texas. Does TDH think they can shut all of us down? The guy who was ramrodding things yesterday had the opinion that simply because the ambulance van looks like an ambulance and still had a stretcher that it was illegally "advertising" itself as a TDH licensed entity. It doesn't, and we weren't. It's that simple. Unless the van is marked with "AMBULANCE" or "EMS" or "Paramedic" (you get my drift) wording or lettering, then it's not "advertising" anything.

Regardless, under most circumstances you would be right. I just tend to disagree on this matter. And here's another one that I really don't know how to describe. A certain Odessa-based ambulance co. is contracted to provide transport for patients to and from River Crest, a specialized facility for mental and detox patients in San Angelo. They use a "stretcher van" that is totally unmarked and has no emergency equipment. They have a roll-in cot and O2 for patients requiring it. While the co. is a licensed EMS provider (they have a large fleet covering Odessa and now Lubbock), this particular van is not certified. Seems like that is fine with TDH. I'm beginning to wonder where all this will eventually lead.

Richard, good to see you on here, too. I figured if you saw the post you would have comments, which are always welcome.

The downside of all of this is that it puts us out of business for the most part. We can still provide standby personnel for our events. We just can't take our van with us. Most of the events insist on having an ambulance vehicle present, even if just for looks to satisfy some of their safety requirements, so that knocks us out for the moment. As I said in my original post, the only reason the van isn't permitted is for lack of medical direction, which the doctors are all saying isn't necessary! It seems that at TDH no one can quite agree. As I said, it's costing us our business and is putting my EMT cert. on probated suspension for a while. That's totally unfair and uncalled for.

[ReD]

I work for a company and we do stand-by events. all of our ambulances are MICU capable and registered. we havent had any problems.

[Skip Goulet]

Thanks for your comments, Red. I understand fully that certified ambulances quite often work standby events,too. Superior Ambulance and MedTech in Odessa are two good examples, and both are fine ambulance services.

The point I was trying to make is that there are numerous standby organizations here in Texas that work sporting events with non-certified ambulances: knowing fully well, of course, that they can't and won't transport. All they do is provide care and stabilization until another ambulance gets there. For that matter, when Superior and MedTech work sporting events, the ambulance working the event does not leave with a patient. Again.....they care for the patient until another of their units gets there and the second unit transports. What I'm trying to say is, with so many organization working standbys utilizing non-certified vehicles, why are we being singled out when we have done nothing wrong. As I think I pointed out before, the ambulance service I ran for many years in the Panhandle utilized licensed ambulances, and we did transport from the events we worked. On occasion we had an ambulance at events that wasn't certified, but we were allowed by TDH at the time to transport with it. The only restriction was that we could not run "hot" with an uncertified ambulance. Texas did not attempt to regulate non-emergency ambulance at the time; and I've been told that the state has yet to draft legislation requiring non-emergency transports to be done with certified-only vehicles. I also pointed out the fact that there are numerous "stretcher van" ambulances in Texas that make inter-facility transfers with patients. These vans have the bare minimum: a cot and O2 equipment. Again....these are unlicensed as ambulances and are not regulated by TDH. With this in mind: again, why are we being singled out. Pure politics with a power play mixed in. Thanks again for your comments.

[flight-lp]

Texas Administrative Code 157.5 and 157.11 clearly outline the state's licensing requirements for any EMS personnel providing any level of pre-hospital care. While I do agree that there are many more in violation, your organization is in the wrong sorry to say..................

[Dustdevil]

Skip, as a medic in Texas since 1973, I'm afraid I have to fully agree with you. If it ain't an ambulance, it ain't an ambulance. Period. What you describe is no more an ambulance than a fire truck is. It's simply a first aid station. Nothing but a big first aid kit on wheels. And if no attempt is made to represent it as an ambulance, then TDH is just being a dick. An admin law attorney could probably set them straight if you have the money for such.

Sounds to me like what happened is a competitor ratted you out in an attempt to steal your business.

A similar situation happened to me in the early 80's. A competitor complained to the city of Fort Worth that the standby company I was supervising for was operating unlicensed in their city. One afternoon, a FWPD unit drove into the racetrack grounds and up to my ambulance, where he asked for my ID and told me I was being cited for unlicensed operation of an ambulance in the city. I told him that we weren't even IN the city! He said, "Yes sir. The city limits extend all the way to the railroad tracks." My reply was, "Uhhh... don't you remember crossing the tracks when you drove in here?" He stopped, looked at me for a second, then said, "Oh yeah! Sorry about that. Have a nice day!' and drove away.

I heard the following week that the jerk who had tried to rat us out was screaming and yelling at city hall on Monday morning about us not being cited!

Anyhow, the point being, you CAN fight city hall. They aren't always right.

Good luck!

[flight-lp]

Aw now hold on a sec.......You are now talking about two distinct and separate animals.

1. License of the unit

2. License of the operating company

You can run 2 medics out of a Yugo, but if those two medics are offering any level of care above that of a regular citizen, you are then providing emergency care which is subject to licensing. You cannot offer bandaging, splinting, c-spine, or even vitals unless you are a licensed ambulance company. In addition you must have protocols and you must have medical direction. There are variances to this ruling, but I would make sure that you have specific authorization from the Department of Health so there are no questions. But based on what was originally stated and reviewing TDH policy, they were wrong..............

[Arff312]

Ok i work standbys for concerts and we dont have any ambulances. We just have wheel chairs and stretchers available. we have docs and nurses at our medical station. We call 911 for transports. I also work for Six flags and it is the same type of thing. No need for a ambulance if your not transporting.