Flying Single pilot over 60.
I have been in correspondance with the SRG ref single pilot over 60. I attach a copy of my last letter that may be of interest. I believe that the points that I raise are self explanatory.
Dear Mr Bell,
Single pilot over 60.
Thank you for your SS107 dated the 1st of November. I am sorry not to have contacted you earlier, but being semi-retired can be time consuming hard work!
Despite the power of Google the only reference I can find to the Chicago Convention is the original document, I cannot find Annex 1.
I note that the review carried out by ECAC was, as you state, over 15 years ago. Since then there have been considerable advances in the ability of medical science to conduct non-invasive testing. This provides an extra element of safety available from aircrew medical examinations. In my own experience my SAM has had at least two updates to his electic cardiogram equipment in that time. There still remains scope for the depth of investigation at an aircrew medical to be increased by, for example, requiring a stress ECG. Until all reasonable non-invasive procedures have been exhausted it is unreasonable to restrict a pilot due to age.
I believe that the data used to evaluate the age limits imposed is based on a fixed wing case, where, in the event of a pilot suffering an in flight medical incapacity, flight has to be continued for a considerable time to a suitable place of landing and then the pilot has to carry out what is the most stressful phase of the flight, the landing itself.
In considering the combination of different types of flight, flight conditions and flying machines it would appear too difficult to not treat them as one for regulatory purposes. Of fixed wing/rotary wing, day/night, on shore/off, shore IMC/VMC only two categories exist with regard to crew incapacity. In the case of all of them except rotary wing, day, VFR, onshore flight has to be continued to a suitable place of landing. In the case of rotary wing, day, onshore, VFR a landing can be affected almost immediately should the pilot suffer the effect of incapacity? For a helicopter such a landing is a relatively non-stressful event. There clearly is a quantum difference in the risk associated with these two cases thus making it not unreasonable for helicopters day VFR onshore to be considered as a separate case.
Clearly any age discrimination legislation has to be overruled if there is an overriding safety issue. It is the responsibility of any regulatory authority that wishes to overrule age discrimination legislation to have the necessary documented safety analysis to show that this is the case.
Under the terms of the Freedom of Information Act can you please provide me with the documented risk analyses that you have conducted that shows that there is an overriding safety case for not allowing a pilot to fly single pilot day VFR onshore in a helicopter?
In considering the risk associated with an individual pilot all factors relating to that individual have to be considered together. Even if there is an increase in risk associated with a pilot over the age of 60, that pilot’s age reduces the risks associated with inexperience or lack of maturity. I am sure that you have the relevant statistics that allow a comparison between age and human factors accidents that would support this.
There is already a built in safeguard to reduce the overall risk to the public for pilots flying single pilot, in that there is a weight limit on the flying machine that can be flown single pilot. This in itself restricts the overall risk to a relatively very small number of flights thus the overall risk to the public would remain very small even if the age limit were raised.
Yours faithfully,