EASA medical: Closing date for comments

[SunnyDayInWiltshire]

I read that the LAA are clamouring for people to make formal comments on the draft LAPL medical regulations (LAPL may replace the NPPL on a European basis). Comments must be submitted by 23 August. Having read the comment response document (http://easa.europa.eu/ws_prod/r/doc/crd/CRD%20b.%202%20-%20Part-MED.pdf) on the EASA website, I don't entirely agree with the LAA assessment that this will make the system unworkable.

On page 25, the General Practitioner (ie your GP who has access to your medical records) must either have acquired knowledge about aviation medicine OR have held a pilot license at some point. No need for a full training course. For the purposes of the LAPL medical, the GP is an acting AME.

The new initial examination itself requires urine, vision and hearing tests.

I've had both the GP and AME examinations this year. The GP was a formality - I think probably the first one he'd ever done - and didn't require a urine/hearing tests (I did show my recent optician's report). It helped that this aligned with the DVLA requirements for commercial drivers. It would be fair to say he didn't have any aviation knowledge apart from reading the briefing document that goes with the NPPL medical declaration. He's been my doctor for over 20 years, so has a very good understanding of my medical history.

The AME didn't have access to my medical history so apart from a very thorough physical examination with lots of tests, it seemed to me I could have omitted salient facts.

Clearly, requiring all LAPL pilots to visit an AME isn't workable but that isn't my interpretation of the draft regulations. Do others agree with my interpretation or not? (If not, submit your comments direct to EASA quickly!)

[Miroku]

As I understand it if the LAPL does replace the NPPL then anyone who can't get a class 2 medical won't be able to fly!

I would guess that this includes the vast majority of NPPL holders (including myself) who took an NPPL licence precisely because they were unable to get a class 2 medical.

We have until tomorrow to comment on this point to EASA apparently.

See the LAA site for more details.

[peter272]

.. and please be sure not to copy another's comments as they will be ignored.

Look at the news page on Welcome to the British Gliding Association (http://www.gliding.co.uk) for the BGA's response and also how to use EASA's very complicated response tool

[BEagle]

Here are the €uro-proposals:

MED.B.090 Medical examination of applicants for LPL medical certificates

(a) An applicant for a LAPL medical certificate shall be assessed based on aeromedical best practice.

(b) Special attention shall be given to the applicant’s complete medical history.

(c) The aero-medical examination shall include at least the following:

(1) clinical examination;
(2) blood pressure;
(3) urine test;
(4) vision;
(5) hearing ability.

(d) Notwithstanding (c), after the first issue of a LAPL medical certificate the aeromedical examinations until the age of 50 can be reduced with due regard to the evaluation of the applicant’s medical history.

MED.D.001 Requirements for general medical practitioners

(a) GMPs shall act as AMEs for issuing LAPL medical certificates only if exercising their activity in a Member State where the GMP has appropriate access to the full medical records of pilots.

(b) In order to issue LAPL medical certificates, general medical practitioners (GMP) shall be fully qualified and licensed for the practice of medicine in accordance with applicable national rules, and

(1) have completed postgraduate training in general medical practice; and
(2) have acquired knowledge in aviation medicine; or
(3) hold, or have held a pilot’s licence for any kind of aircraft.

(c) GMPs acting as AMEs shall declare their activity to the competent authority.

You will note that, after age 50, every medical revalidation will include all 5 listed items including a 'clinical examination'. Your own GP may not meet the criteria of MED.D.001, so you would need either to change your GP or visit an AME....

The CAA doesn't agree with this as they consider the NPPL Medical Declaration to be entirely sufficient and they have considerable evidence to back this up. Various €uropean aero-quacks don't agree with the proposals as they wish to protect their comfy income stream....:ugh:

Best solution? Throw the unnecessary and pointless LAPL into the junk pile and devolve all sub-ICAO pilot licensing from EASA to national authorites.

[jez d]

If this equivalent of a JAA Class 2 medical requirement remains for LAPL holders then I agree with you Beagle - there is simply no point in having the licence in the first place.

The NPPL, on which the LAPL appears to be based, was created precisely to afford the opportunity for pilots who could not gain a Class 2 medical to continue flying. And history has proven that there has been no compromise to flight safety as a result of pilots flying under GP authorised medicals.

And it's not just NPPL holders who will be affected, but also the entire gliding community.

As renowned MD Peter Saundby wrote in the September edition of Today's Pilot, there is strong evidence that EASA's backing of the opinion of a few well placed AME's with vested interests (and which ignores some 30,000 objections raised by the flying community), is actually contrary to both EU treaty and the EU Commission's Basic Regulation 216/2008 which details EASA's responsibilities and demands appropriate and proportionate regulation.

EASA are treading on very thin ice here. There are some very influential and well placed individuals out there who would not be flying if it wasn't for the reduced medical requirements afforded under NPPL and UK glider pilot licences.

Regards, jez

[Whopity]

Interesting Quote in the latest EASA News (http://www.easa.europa.eu/communications/easa-news/EASA-Newsletter-issue-5.pdf)Page 3 Centre ColumnHowever, we should stress that our main goal is that pilots who have certain privileges today should keep it with the new licenceAre they so incompetent that they can't see this is untrue? IMC and NPPL are just 2 examples.

[BEagle]

In other words the only way to do this is to remove sub-ICAO pilot licensing from the grubby paws of the €urocrats and leave competence for national matters to national authorities.....:(

Too easy for the Colognic irritators, I guess.....:mad:

[David Roberts]

In all this debate one needs to distinguish clearly between medical standards to be 'achieved' for the different levels of proposed EU licences and the process(es) by which those standards are evaluated for a given applicant.

The ICAO compliant private pilot licences proposed by EASA will need ICAO compliant medical standards - thus ICAO Class 2, which I understand broadly is less onerous than the current JAR Class 2. The LAPL was developed specifically to meet the requirement from various stakeholders for sub ICAO licences. The sub ICAO element was driven primarily by the need for proportionate medical standards in order not to disenfranchise national licence holders, such as those with the UK NPPL (A) or NPPL (SLMG) who fly aeroplanes that fall within the scope of EASA. Also, of course, gliding and ballooning now fall within the scope of EASA (n.b. for gliders that are within the scope of EASA as opposed to Annex II ones). Forget NPPL (M) for microlights because microlight aircraft are in Annex II and therefore outside the scope of EASA. In the case of UK gliding it has long used the DVLA medical standards (groups 1 and 2) which are the NPPL medical standards and therefore it was vital that an equivalent licence level with associated medical thresholds was available under the EU system. Hence the LAPL (Sailplanes).Otherwise a considerable number of pilots would be disenfranchised on transfer to European licences. The SPL is the ICAO compliant gliding licence, which only differs from the LAPL (S) in respect of the medical standards and process (GP allowed to do LAPL medical but not SPL medical).

My understanding (I would need to look up and check advice from the UK medical 'guru' on this) is that the proposed medical standards for the LAPL are almost the same as the UK NPPL, and are based on the FAA Class 3 (but I stand to be corrected). Therefore, prima facie, the vast majority of NPPL holders should be able to meet the LAPL medical standards, assuming no change in medical condition. But I am not a doctor so don't hold me to that, please.

The key debate has been and still is (even more so with the latest CRD changes from the NPA) the proposed conditions that GPs would have to meet to enable them to issue certificates of fitness to fly (as opposed to the current NPPL bases of endorsing the pilot's declaration of absence of disqualifying conditions). The AME lobby has at this point convinced EASA that a GP would not only have to be qualified as a doctor (fine!) but would have to have, as yet undefined, 'aeromedical knowledge' (or hold or have held a pilot licence of any sort). It does not take much imagination to realise that most GPs will not meet these additional criteria and are unlikely to be motivated to obtain at least the 'aeromedical knowledge' for the small number of patients who require the aviation medical certification for the LAPL. And of course we all know that moving to a different GP (who happens to have the required additional qualifications) is far from easy or desirable.

So we can see that the AMEs are effectively trying to exclude the GP from what the Commission and Parliament intended - a GP route as an alternative to an AME. I wonder why? Answers on a postcard.

[Whopity]

The LAPL was developed specifically to meet the requirement from various stakeholders for sub ICAO licencesWho exactly are these stakeholders and what is the requirement? Experience tells us that it is not normally possible to train a pilot to a safe standard in less than 40 hours. Even the BMAAs statistics prove this. Why then is the ICAO standard unsuitable? If its simply a medical issue then seperate simple arrangements can be made based upon the medical alone. The proposed Helicopter LPL actually exceeeds the ICAO hours minima!

EASA's job is to regulate for safety; there is no safety case for the LPL at all; it should be dropped as its reinventing the wheel. If individual States want a non ICAO licence it should be left to them to decide. There are lot of NPPL holders who could not obtain a FAA Class 3.

[BEagle]

My understanding (I would need to look up and check advice from the UK medical 'guru' on this) is that the proposed medical standards for the LAPL are almost the same as the UK NPPL, and are based on the FAA Class 3 (but I stand to be corrected).

No, the standards proposed by EASA in part-MED are vastly different to those required for NPPL, Ballon and Airship, Gyroplane and ORS4 No.756 Medical Declarations.

On this point, the CAA Medical folk are very firmly in total agreement - the current Medical Decalaration system is entirely proportionate for such flying.

The LAPL is, as Whopity has stated, not backed up by any proven safety case. It simply isn't necessary.

All sub-ICAO pilot licensing should be devolved to national authorities. Those who wish to fly internationally should comply with current ICAO / JAA requirements; those who wish to fly within national airspace only should be permitted to do so under current national arrangements.

Fortunately EASA has been instructed that, if it re-invents the wheel, its proposals will not be accepted by the European Parliament. But they don't seem to have listened to this instruction.........

[peter272]

... but given there is little statistical evidence that the current Class2 medical is any use in identifying likely pilot incapacitation in advance, it would seem that access to your own medical notes by your own GP is better.

Sure, if there was a doubt, the GP should refer onwards, but for me, the £150 per year checkup - with the exception of the ECG - is no better than the £50 or so one-over by my GP, and that is not an annual one either.

In my view, unless there is a need for a higher standard of medical (ie for commercial flying, IR, instruction) then the self-certification route is the way to go for all of us.

Of course it won't happen. Too many vested interests

[Whopity]

The major medical cause of pilot incapacitation is "Diarrhea" I doubt if anyones medical notes will help diagnose it!

[Lister Noble]

I passed an AME class 2 Medical for PPL and three weeks later needed a pacemaker!
Now flying NPPL,I could fly PPL if I wished to pay around £800 for annual medical exam(echocardio,stress test and 24 hr ECG halter)
The NPPL is a great asset and we do not need AME's to supervise this.

As my GP said,"if I reckon you're fit enough to drive a petrol tanker through town,I reckon you are fit enough to fly" .:)

[A and C]

I hope all above have made comments on the EASA website before posting here..................... It is only by objecting too EASA can we get rid of this rubish before it starts.

[Thud105]

The most frustrating aspect of the aviation medical is the lack of science. It is a throw-back to when governments who were considering spending a great deal of money on training a young man to fly for the military wanted to ensure he was basically 'fit for duties'.
I knew someone who dropped dead 3 weeks after passing his Class 2, and many pilots can tell similar stories. Indeed, some airliner flight crew (who have a Class 1 every 6 months) have actually died of natural causes in flight.
There is absolutely no science and little benefit to aviation medicals. However, it does make AMEs a great deal of very easy money!

[Miroku]

I've been in contact with AOPA regarding the proposed LAPL and received the following reply which I have their permision to quote:

I have been in contact with Dr Ian Perry, the AOPA/IAOPA medical representative at EASA, and he has been fully briefed regarding the importance ot UK NPPL holders being able to continue under EASA with a similar medical for the LAPL. as we have currently for the NPPL.

We will keep our members informed via the magazine when we have any final proposals regarding this matter.

Currently, EASA is proposing a medical with your GP for the LAPL, but the GP concerned is required to have some additional experience or qualification to cover him/her to undertake these medicals.

Ian Perry is currently at EASA at a meeting with the Medical Department and working on the subject of the LAPL medical for us.

[md 600 driver]

Will a Ame be able to issue a lpl licence? If your gp has not got the correct aviation experience or will you have to get a class 2

[Thud105]

Interesting that not one single AME has tried to refute my previous assertion about the lack of science in the traditional pilot medical. I wonder why? BTW A friend posted me the article by Dr. Saundby in Today's Pilot - very well informed piece, by someone who is clearly an expert in the field of aeromedicine.

[851Pilot]

Only just spotted this thread...

As a newly qualled NPPL (April '10) who wanted to be a pilot from age four - and until NPPL was told categorically NO because I have one weak eye - the reduced NPPL requirements with regard to eyesight have enabled me to achieve my dream.

I owe whoever was behind this licence a huge thank-you.

I'm now concerned that all the time, effort and money I've put into gaining the privileges of an NPPL may be taken away? Someone please tell me that won't happen?

Fortunately my GP is also a pilot and, also now, an AME :)

Iain

[Echo Romeo]

851 pilot, I think everyone who holds an NPPL due to medical issues feels just like you, it's the uncertainty, just hope common sense prevails and the NPPL and med dec survive the impending changes!

[Sir George Cayley]

If you think writing a well set out objection to EASA's proposals will help sway their opinion, think again.

Most of their previous NPA's including Air Ops and FCL have attracted huge numbers of responses and yet they've ploughed on and, in the case of FCL, introduced post CRD un-consulted changes to boot.

EASA have been described by better than me as arrogant; they keep reinforcing that in my view.

BTW the FCL Opinion has been published - it's an almighty cock up - funny there's not yet a thread on it?

SGC

[flybymike]

For Gawd sake why dont we just do what the Frenchies do and ignore all of this EASA crap. We are a sovereign state. Bring back the CAA. We invented the NPPL when JAA started producing mad regulations ten years ago. What the hell would they do about it anyway? Invade us?

[2close]

An interesting web-site here, explaining, amongst other things, how to challenge EU law proposals in the European Parliament.

EU Law: Getting an EU proposal blocked in the European Parliament | How do I | EU Information - European Law Monitor CIC (http://www.europeanlawmonitor.org/EU-Information/How-do-I/EU-Law-Getting-an-EU-proposal-blocked-in-the-European-Parliament.html)