Testimony of Robin Wilkening, MD, MPH
Regarding S. 65
Senate Subcommittee on Aviation
July 19, 2005
Senator Burns, Senator Rockefeller, and Distinguished Senators of the Aviation Subcommittee,
My name is Dr. Robin Wilkening. I am a Board certified Occupational Medicine physician with a Masters degree in Public Health. Occupational Medicine is the medical specialty that deals with all aspects of worker health and safety. Workplace safety, worker health, fitness for duty, health-related productivity, and workplace access are key elements of my training, expertise, and professional interest. My research paper on the Age 60 Rule was published in the journal Aviation, Space, and Environmental Medicine in March 2002. My conclusion, after an extensive review of the literature, was that requiring airline pilots to retire based solely on the age of 60 had no basis in medical fact, could not be supported by scientific literature, and was not consistent with flight safety data. The Age 60 Rule prohibits an entire class of workers from continuing gainful employment based on age alone, and as such constitutes age discrimination in the workplace.
I am not alone in my opinion that the Age 60 Rule cannot be justified. One year ago the Civil Aviation Subcommittee of the Aviation Safety Committee of the Aerospace Medical Association (ASMA) - recognized as the international leader for excellence in aerospace medicine - published its findings regarding the Age 60 Rule. Following an extensive and scholarly examination of the literature, this panel of aviation medicine and safety experts concluded, "there is insufficient medical evidence to support restriction of pilot certification based on age alone," and noted that "the decision to use 60 years of age as an upper limit for commercial air transport operations was arbitrary." In addition, the Civil Aviation Medical Association (CAMA), the pre-eminent professional body representing Aviation Medical Examiners, "...supports the concept that pilots operating under FAR Part 121 should not be forced to retire from piloting duties based solely upon attaining age 60." In February 2005, the International Civil Aviation Organization (ICAO) cited the results of its survey of member nations wherein 83% of the 112 respondents indicated that "an age limit above 60 years would be appropriate for airline pilots" (with 72 states favoring an upper age limit of 65 and six desiring no upper age limit at all). ICAO highlighted the opinion of their Flight Crew Licensing and Training Panel that, as the Aerospace Medical Association stated, "...there is insufficient medical evidence to support a restriction based on age alone." In proposing the current rule change to allow pilots up to age 65 to fly in multi-crew operations, ICAO specifically mentioned research performed in the United States by Baker and Li showing the safety of over-60 pilots, and cited a recent ICAO survey documenting more than 15,000 "older pilot years" of accident-free flying worldwide. The ICAO "Age 65 Rule" is expected to take effect on November 23, 2006.
Acknowledgment of the safety of over-60 pilots is not limited to the medical community. In the Letter of Understanding between ALPA and Air Canada Regional, Inc., ALPA President Duane Woerth endorsed Canadian ALPA member pilots flying up to the age of 65. And although the Letter stated "there are current Federal Aviation Administration restrictions for Captains over the age of 60 to fly into the United States of America," strikingly absent was any mention of the FAA's Age 60 Rule being a safety regulation. Likewise notably absent was any language suggesting even the slightest concern that these airline pilots up to age 65 – now represented by ALPA – constituted an undue safety risk.
It is by now well known and widely accepted that the Age 60 Rule was never meant to be a safety regulation. Far from being related in any way to safety, it was instead a bit of backroom economic favoritism designed to benefit the management of one particular airline and, by extension, the management of all airlines. In FAA Administrator Quesada's own words, written in April 1959 to the President of the University of Notre Dame, "there exists at present no sound scientific evidence that airline piloting or any other aeronautical activity becomes critically unsafe at any given age." When in August 1959 then-ALPA President Clarence Sayen, an ardent opponent of the Age 60 Rule, demanded that the FAA produce scientific evidence, Administrator Quesada did not - because he could not - offer any evidence that airline pilots over age 60 were less safe than their younger counterparts. Instead, the FAA offered up a bibliography of 41 publications dealing with aging, none of which addressed airline-piloting capabilities. Since that time there have been numerous studies dealing with the subject of aging both in general populations and in groups of pilots. In their recent exhaustive review, ASMA aviation research experts thoroughly analyzed a huge body of literature and reported three findings: 1) Performance on measures of most – but not all – cognitive functions decline with advancing age; 2) Performance of a group may not predict the performance of any specific individual; and 3) Observed “declines” in laboratory test performance are not necessarily predictive of cockpit performance. Based on their thorough study of the literature of aging as related to piloting, ASMA experts concluded: “On review of the existing evidence, the Aerospace Medical Association concludes there is insufficient medical evidence to support restriction of pilot certification based on age alone.”
Laboratory studies on effects of aging are worthy academic exercises that increase our general fund of knowledge. However, the results of these tests, as ASMA noted, are not necessarily predictive of cockpit performance. Flight safety is the true outcome of interest, and we are indeed fortunate to have a body of flight safety data detailing the performance of pilots in various age groups. When performed according to rigorous scientific standards and analyzed using proper statistical technique, flight safety studies show that pilots over age 60 are as safe as their younger colleagues. It is important to review these results.
1. 1994: Kay EJ, et al. Age 60 Study, Part III, Consolidated Database Experiments Final Report, DOT/FAA/AM-94/22, Office of Aviation Medicine, Washington DC 20591, October 1994.
The analysis provided no support for the hypothesis that the pilots of scheduled air carriers had increased accident rates as they neared the age of 60.
For pilots with Class II medical certificates, the accident rate for the age group 60-64 did not differ from that of the age group 55-59. For pilots with Class III medical certificates, the accident rate for the age group 60-64 did not differ from that of age group 55-59. Additionally, for Class III pilots with more than 500 total flight hours and more than 50 recent flight hours the accident rate for the age groups 60-64 and 65-69 did not differ from that of age group 55-59.
In a further arm of the study, accident rates were examined year-by-year, rather than in 5-year groups, for pilots aged 50-69. Between age 63 and age 69, there was an apparent, though not statistically significant, linear trend that was described by the author as "a hint, and a hint only, of an increase in accident rate for Class III pilots older than 63 years of age."
2. 1999: Rebok GW, Grabowski JG, and Baker SP, et al. Pilot age and performance as factors in aviation crashes. Presented before the American Psychological Association meeting, Boston, MA 1999.
Dr. George Rebok demonstrated that in general aviation crashes involving pilots aged 40-63, the percentage of accidents caused by pilot error was smallest in the age group 56-63.
4. 1999: The Chicago Tribune July 11.
Statistics compiled by the FAA for air carrier accidents/incidents involving air transport (airline) pilots from January 1, 1990 to June 11, 1999 were evaluated by Northwestern University professor Ian Savage. This cohort, including pilots age 20 to over 60, was notable for its inclusion of airline pilots working for commuter airlines who were over 60 years of age during this period. These pilots were exempt from the Age 60 Rule between 1995 and December 1999. The data showed no statistically significant difference in incident rate between any age group. The safety of this over-60 pilot group is all the more notable because these pilots - confined to commuter operations - were exposed to much greater flight risk than were their younger counterparts flying in safer, large jet operations.
5. 2000: Broach D, et al. OAM AAM-00-A-HRR-520. Civil Aeromedical Institute (CAMI), Human Resources Research Division, Federal Aviation Administration, Oklahoma City, OK 73125. A series of four reports.
Continued
Report One was a bibliography.
Report Two reanalyzed the Chicago Tribune data but specifically excluded those pilots aged 60 and older from analysis. CAMI reported no statistically significant differences in the accident/incident rates by age group. It is particularly notable that the proportion of 50-59 year old air transport pilots involved in accidents or incidents was significantly lower than the proportion for the 40-49 year old group.
Report Three evaluated pilots age 23-63 with an Air Transport rating and a Class I medical certificate (that is, pilots who were rated and medically certified to be airline captains) who flew between 1988 and 1997. This study was conducted at the request of the United States Senate to compare the flight safety of pilots age 60-63 with the flight safety of younger pilots. Study author Dana Broach: "No significant difference was found between accident rates for pilots in the 55-59 and 60-63 year old age groups." This finding is all the more noteworthy because, as in the Chicago Tribune cohort above, the over-60 pilots in this study group were flying in less-safe commuter operations only.
Report Four expanded the Report Three study cohort to include pilots with a Commercial rating and a Class II medical certificate, creating an impure study population composed of pilots who had an Air Transport rating and Class I medical certificates and pilots who did not. In this mixed group, there was a statistically significant increase in the accident rate for pilots age 60-63. The inappropriate combination of these two pilot groups into a single cohort was criticized in the aviation medical literature and casts serious doubt on the veracity of the findings.
6. 2001: Baker SP, Lamb MW, Grabowski G, Rebok G, Li G. Characteristics of general aviation crashes involving mature male and female pilots. Aviation, Space and Environmental Medicine 2001;72:447-52.
This research group at the Center for Injury Research and Policy, Johns Hopkins School of Public Health reported their analysis of the causes of general aviation crashes. Older pilots made fewer errors: among males age 55-63, 26% of crashes were without obvious pilot error whereas among males age 40-49 only 7% were without obvious pilot error.
7. 2002: Miura Y, Shoji M, Fukumoto M, Yasue K, Tsukui I, Hosoya T. A 10-year retrospective review of airline transport pilots aged 60-63 in Japan. Aviation, Space and Environmental Medicine 2002 May;73(5):485-7.
Investigators from the Japan Aeromedical Research Center in Tokyo reported the results of their experience with pilots over age 60. During the study period these pilots underwent standard medical examinations and were engaged first in non-scheduled flying (1991-1996) and then scheduled flying (1996-2000). These pilots were not involved in any of the 323 accidents reported by the Japan Aircraft Accident Investigation Commission. The investigators\' conclusions: "aged pilots who are deemed medically qualified by the official notice criteria are flying safety without mishap incidence." Japan has since raised its upper age limit to 65.
8. 2002: Li G, Baker SP, Lamb MW, Grabowski JG, Rebok GW. Human factors in aviation crashes involving older pilots. Aviation, Space and Environmental Medicine 2002 Feb;73(2):134-8.
In a study of human factors in aviation crashes involving older pilots, these researchers studied a cohort of 3306 pilots who were 45-54 years old in 1987 and flew commuter aircraft or air taxis. This group was followed longitudinally until 1997. Comparisons of crash circumstances and human factors were made between pilots age 40-49 and 50-63. Neither crash circumstances nor the prevalence and patterns of pilot errors changed significantly as age increased from the 40s to the early 60s.
9. 2003: Li G, Baker SP, Grabowski JG, Qiang Y, McCarthy ML, Rebok GW. Age, flight experience, and risk of crash involvement in a cohort of professional pilots. American Journal of Epidemiology. 2003 May 15;157(10)
74-80.
In a further study of the above cohort, the researchers determined that those pilots with 5,000-9,999 hours of total flight time at the beginning of the study period had a 57% lower risk of a crash than their less experienced counterparts. There was no association between pilot age and crash risk, which the researchers noted "may reflect a strong \'healthy worker effect\' stemming from the rigorous medical standards and periodic physical examinations required for professional pilots."
The Age 60 Rule was never designed to be a safety regulation, and was not promulgated in response to any demonstrated safety need for the restriction of pilots over age 60. An exhaustive review of the medical literature regarding aging has failed to show any evidence that would prudently bar airline pilots over age 60 from the cockpit. All published flight performance studies, when conducted according to the highest scientific standards and evaluated using appropriate analytical technique, and show that pilots flying until age 63 are as safe as their younger colleagues. The international experience with older pilots amply demonstrates the safety of pilots flying until age 65.
Requiring airline pilots to retire based solely on the age of 60 has no basis in medical fact, cannot be supported by scientific literature, and is not consistent with flight safety data. The Age 60 Rule prohibits an entire class of workers from continuing gainful employment based on age alone, and as such constitutes age discrimination in the workplace.
Robin Wilkening MD MPH
[email protected]