Hearing Loss Medical EASA. Any experiences?
Hello (wannabe) pilots,
After working in another flied for some years, i wanted to chase my childhood dream and become airline pilot! I did an assesment for the KLM Flight Acadamy and passed it. The only formality was to pass my medical examination. It didn't turn out to be just a formality.... it appeared i have a hearing loss of about 45db on my right ear (on 1000hz). I never knew i had this, neither did i experience any negative effects because of this. My left hearing is perfect, and probably i have this hearing form birth and my left ear compensates for it.
The KLM doctor sent me to an ENT doctor (specialized in aviation) and to make it short: the conclusion is that my hearing is (according to her opinion) good enough for flying, i perform a speech discrimination test very good and a MRI scan showed that i don't have a active pathological process going on (so it's unlikely it will degrade further).
This rapport was sent back to the KLM doctor and he told me i don't comply with the requirements: not more than 35db loss on either ear seperately on 500,1000 and 2000hz. (In that he is right: on my right ear, i can't perform a audiometry on 1000hz that will show less then 35db loss. And i never will). He consultated the IL&T (the Dutch NAA), but they also stated that i don't comply with the requirements with the same argument, hence denial of type 1 certificate (hooray i can get a type 2 medical certificate, i can do everything as long as i don't need an IR. Not very convinient when i want a ATPL).
As i am diving in the EASA rules, it states indeed that initial applicants shall not have a hearing loss of more than 35db on the above specified frequencies (MED.B.080, (a, 1, ii)).
***Italic is copied from the EASA rules***
It also states that "A comprehensive ear, nose and throat examination shall be undertaken for the initial issue of a class 1 medical certificate and periodically thereafter when clinically indicated." (MED.B.080 (a, 2)).
Then it states (MED.B. 080, (b)): Applicants with any of the following medical conditions shall undergo further examination to establish that the medical condition does not interfere with the safe exercise of the privileges of the applicable licence(s): (1) hypoacusis (among onther, but i only write here what matters to my case).
Lastly the regulations state:
MED.B.080, (c), (1): Applicants for a class 1 medical certificate with any of the medical conditions specified in points (1 hypoacusis), (4) and (5) of point (b) shall be referred to the medical assessor of the licensing authority.
That are the regulations. The EASA requirements than go on with the General Means of Compliance:
AMC 1 MED.B.080, (2): Applicants with hypoacusis may be assessed as fit if a speech discrimination test or functional flight deck hearing test demonstrates satisfactory hearing ability. A vestibular function test may be appropriate. and (3) If the hearing requirements can only be met with the use of hearing aids, the hearing aids should provide optimal hearing function, be well tolerated and suitable for aviation purposes.
In my opinion, it doesn't state that it is not allowed to be assesed as fit on an initial test when you have hypoacusis. How i read it, you should then do a comprehensive investigation (i did just that at an ENT specialist), show appropriate hearing on a speech discrimination test (i also showed that) and show that it's no active pathology (the MRI shows that in my case). And although the ENT specialist said i don't need hearing aids, if I have to to chase my dream, i will use them ofcourse. But none of that was discussed, my medical simply will be denied because i don't meet this requirement of less then 35DB loss on 1000hz.
I just wonder: did anyone ever experienced something similar to this? How do you interpret these rules? Do you think the Dutch NAA (IL&T) made a proper decision considering the EASA rules or did maybe a NAA in another country made another decision in a case similar to this?
And lastly: does anybody have any idea why the CAA (United Kingdom) rules are similar to the EASA rules, but add much more guidance material which covers exactly this topic? I mean it's strange right: i live in the Netherlands and can't get a medical, but would i move 350km to the UK, i could get a medical. I would be able to work for a English airliner, fly to Amsterdam and land there with a medical license that the EASA would consider invalid. I think that's really arbitrary.
I hope somebody can give me some tips/advise/share his or her experiences because ofcourse i am gonna object to the decision and want to make my case as strong as possible.
Sorry for the long post and maybe the grammar mistakes.
Kind regards and thanks in advance,
Lex