Notice of Proposed Amendment published

[proudprivate]

http://hub.easa.europa.eu/crt/docs/viewnpa/id_228

The long expected NPA for Part MED has now been published for consultation on the EASA website. A first reading reveals a number of significant improvements (read : relaxations of previous medical requirements), but some remain still too restrictive to be justified by a (statistically) relevant safety concern.

I would invite all pilots reading this message to look up the file, register on the EASA website (if you haven't done so already) and comment where appropriate. And I would invite all medical staff who have never done any serious flying themselves to stay away

[Radgirl]

At first glance there does seem to be some common sense relaxation in some areas.

I have to say I find your final sentence unpleasant and stupid. Why do you think healthcare professionals should stay away? We need experts in each specialty to comment and engage, to educate the regulators about advances in their areas which mean pilots with these conditions can meet the risk requirements. Regrettably a pilot who has had a particular illness will rarely be able to make a persuasive argument for additional relaxation as the issue is population risk not individual outcomes.

You must have had a fight with a doctor in your previous life

[proudprivate]

Radgirl,

You've probably just entered the world of aviation related medicine. In general, Medical Examiners that do not fly themselves do not understand where a rule comes from or how it applies to aviation safety.

Moreover, as a they progress in the hierarchy, they tend to exercise their profession not in a caring and understanding way, but find self-gratification in their relative position of power. It becomes even worse when they contribute to medical regulation, as this results in a phletora of perceived risks converted into medical restrictions without any scientific or statistically sound base. In addition, there is a whole medical industry that profiteers from this regulation (test equipment, test development, etc... which would be completely superfluous in a normal diagnostic evironment).

That is why we pilots tend to avoid this crowd like the plague and we look at them with the disdain they deserve.

Up to you of course what kind of an AME you want to become. But if you haven't flown yourself so that you can appreciate what the risk/benefits are of a medical restriction, you haven't earned my respect. And no, you cannot learn this from an aviation medicine book.

Think that I'm exaggerating ?

- Blindness in one eye : is the risk acceptable to pilot solo ?
- Deafness in one ear : can the person fly IFR ?
- Color Blind : can the person fly safely at night ?
- Type I diabetic : ok to fly if blood sugar tested every 30 minutes ?
- Myopic coming for a first medical with 8 diopters but with 20/20 vision after correction. Ok as an ATP ?

Think carefully before you answer.

AME's that don't fly find their own profession too important so that they think they have to make a restrictive contribution, when in fact medically speaking, flying should be looked at the same way as driving a car. If the person is really medically unfit to fly, it will show in the training phase or at the very latest, on the checkride. And of course, AME's earn annual or bi-annual fees for each pilot willing to continue.

And the same applies the distinctions between Airline Transport Pilots (Class 1 medicals) and Private Pilots (Class 2 medicals).

The good thing about these amendments is that at least some people have seen the light in some areas. But it clearly doesn't go far enough.

[Radgirl]

Proud private

No I have not just entered anything and I am not and never want to be an AME

I do know about the risk of incapacitation and the latest discoveries of my sub specialty. I am able to objectively advise the regulators on risk. They can then decide on acceptability.

The idea that any senior doctor is non caring is just bizarre. The idea that anyone is medically fit to fly if their illness doesn't show on a check ride must be a wind up. Are you for real??????

[proudprivate]

No I have not just entered anything and I am not and never want to be an AME

yet you are a new pprune user and you just happen to hang around the medical section.

I do know about the risk of incapacitation and the latest discoveries of my sub specialty. I am able to objectively advise the regulators on risk.

Of course you're incapable of doing that if you have to rely on hearsay or often biased medical literature as to what the effects would be on flying.

Let's say that your specialty is internal medicine and that you happen to know the pain levels an acute cholelithiasis can cause. How would you determine if these are sufficiently incapacitating to prevent a solo pilot from safely landing an aircraft, if you have never done so ?

The idea that anyone is medically fit to fly if their illness doesn't show on a check ride must be a wind up.

That is not what I have said. If you would have read the post more diligently, you would have noticed "at the very latest during the check ride". The point I was trying to make was that an ab initio training process even up to the basic PPL level takes 50-60, sometimes up to 90 hours of intensive flight training, going through maneuvres, landings, procedures, etc... If a candidate pilot has a medical deficiency that is statistically relevant, there is a big chance that it will show up during the training. This is of course more so for commercial pilots or airline transport pilots, where the hours of dual instruction easily run into the hundreds.

The idea that any senior doctor is non caring is just bizarre.

The ones that don't fly are certainly not caring enough. And by caring I mean grasping the circumstances to a sufficient extent that before they prevent someone to exercise a profession or to pursue a passion, they will think twice about statistical relevance as well as operational relevance before sprouting medical wisdom for the sake of it. Or, if a medical issue has relevance, trying to think creatively under which circumstances or by which (preventive) treatment the risks can be contained.

There are just too many "advisors" roaming the Aviation Medical World who advocate restrictions for the wrong motives, be it monetary gain or an inflation of their own importance, to the detriment of the aviation community.

Instead we need more caring senior doctors who are aware of what flying is all about and who would speak up to eliminate many of the unnecessary restrictions that are there now and that are only tolerated because the pilot community is so small and because so few people truly understand the profession. Trying to foist some of these restrictions on car drivers using the same arguments as some of your "advisor" colleagues are doing would be met with Homerical laughter at the relevant transport authorities.

At the same time we witness how EASA is advocating extended work hours and the Aviation Medicine Professionals remain deafeningly silent.

[blind pew]

Rad girl
I see you live in kiwi land..(envy).
In the UK and Ireland the medical service is full of crooks....including some of those who control it...unnecessary operations, fake medicines and allowing patients to have needless painful deaths.
Then we have the Aerotoxic scandle kepts under wraps by the aviation industry as well as the "medical" advisors of the authorities...
It's all about money and nowt to do with ethics.

[Radgirl]

Two quite fascinating opinions. I am certainly not going to rise to the bait and respond to daft comments that the medical service is full of crooks.

However, whilst I don't want to get into a slanging match, may I point out that the rules on fitness to fly are set by regulators such as the CAA, not doctors. Even the CAA accept that some of their decisions are over tough - those that remember Uncle Ian's fight against ageism will recall the CAA admitted stopping single pilot passenger carrying operations at 60 was based on out of date data but stated they didn't have the resources to bring it up to date.

Doctors merely advise the CAA - I know many of the specialists employed by the CAA do not fully agree with the rules. Many try their best to keep pilots flying. Every AME I have known has done all they can to avoid pulling a license.

This document therefore is a breath of fresh air. Most of the changes arise not because of pilots nor the regulators but because medical research and advances in disease management mean the risk of incapacitation has fallen. I know one of the specialists who advised EASA and know he spend many months persuading them.

So to suggest doctors are uncaring crooks hell bent on grounding pilots and people who spend their time publishing fraudulent research is very much shooting yourselves in the foot. If EASA were to believe these silly claims they would immediately tear up the document, accusing the doctors of lying, and reimpose the older more stringent restrictions.

Let me finish with an example. Until recently you could not fly if you were an insulin dependant diabetic. Many insulin dependant diabetics continue to have hypos and poor control. So why are we seeing change? Is it because the public are shouting to be flown by a diabetic pilot? No. Is it because the regulators are having a be nice to diabetics week? No. It is because of newer insulins and research you seem to consider fraudulent showing we can obtain tight blood sugar control without hypos.

[Denti]

Interesting, 90 hours just for a PPL which any halfway non-stupid person can do in just 40 hours including the test ride. Tell that person to take up another hobby. And hundreds of hours of dual for a commercial pilot? Less than 100 from not knowing anything about aviation until sitting int he flight deck of an airliner is more like it. Of course only possible with very rigid entry level testing and training.

Anyway, it is quite bizzare to let stuff crop up during training instead of a few simple tests before spending all that money. Same as radgirl i have met many AMEs or in fact whole AMCs where everything is done to keep pilots flying, and yes the new EASA rules didn't make that easier especially in european countries that had several AMCs beside the authority (which doesn't have to be an AMC but has the last word). Therefore i do like the new NPR, but i would never dream of telling medical specialists not to comment. I would think that quite a lof of the considerable relaxation in medical rules within the last 10 years have been based on comments of those specialists.

[proudprivate]

A bit of nuance in this debate might help

@ radgirl :

Two quite fascinating opinions

by different people.

may I point out that the rules on fitness to fly are set by regulators such as the CAA, not doctors.

JAR Medical Rules proposals were mainly written by a very limited circle of UK Aeromedical Academics, supplemented by a few other Continental European ones. Then a few add-ons were made by “advisors” from various regulatory bodies, almost none of them based on scientific evidence relating to operational issues.
Actually, this attitude of “it’s the others that set the rules, not me” is a recurring theme. A (usually nameless) “Scientific Committee” makes recommendations that are then taken over without as much as a whiff of scientific scrutiny. These then go to regulatory committees, where other (almost certainly) nameless local regulators add a few rules based on their own gut feeling and bias.
Finally, a legal team at the regulatory authority drafts legislation, which is subsequently adopted by a parliament that has had no serious briefing on what it is they are voting on. Also, the preamble to the legislation contains sufficient bull**** to fertilize the country’s entire agricultural crop production.
Because the debate and contributions lack any form of meaningful transparency and because none of the contributing experts are accountable to anyone (even if they have a blatant conflict of interest in the matter) the intelligent members of the public are experiencing a vague sense of democratic deficit and which leads some members of the public (although I don’t count myself among them) to conclude that the medical profession contributors to this process are crooks.
As regards incidence of unnecessary surgery : I don’t have figures to back this up (I doubt anyone has, it would be quite shocking if such figures existed), but a two of my friends in the profession (a dermatologist and an oncologist) have told me that surgeons are known as “the plumbers among the medics” and that the surgical option is chosen in many a case when it could be avoided (through appropriate medication, physiotherapy or other methods) and every once and a while when it was truly counterindicated.

[Comment about] all medical research being fraudulent

Again you read things in my text that I haven’t said. Medical research in general is not more prone to fraud than other empirical research such as say, experimental physics or behavioral psychology. While fraud cases do occur regularly, usually motivated by academic career advancement, the large majority of it is not. In addition, pharmaceutical research such as the development of new insulin variants is subject to intense scrutiny by Drug Administrations worldwide, making fraud less likely (even though the temptation to defraud is higher).

However, Aeromedical Research is one of those areas where as a rule much more is at stake than mere academic advancement : there are potential costs for airlines and there is a whole “medical testing industry” behind the rulemaking.

Let me point out two concrete examples of what I would consider “biased” research :
- Aerotoxic Syndrome (as it was mentioned by another participant)
(This is about the couple of dozen flight and cabin crew members in the BAe146 suffering from a range of neurological-like symptons). The main points of criticism in the research I heard of were:
*Focus on the effect of Trycresyl Phosphate in Engine Oils whilst ignoring other additives or combinations of chemicals that might cause toxicity through inhalation.
*Ignoring of cabin pressure altitudes in evaluation of the toxicity
*Flawed use of statistics by using averages of exposures (and not distributions) to polluted cabin air and to fume events.

It is of course always easier to criticize methodology than to suggest better alternatives let alone do it yourself. Admittedly this is/was a tough case, because of the small population, the diversity of the symptoms and potentially extensive number of parameters to control for and I very much doubt that conclusions of any independent research, no matter how elaborate or costly (within reason) would have revealed anything other than that “there is no statistically significant evidence that proves the existence of an Aerotoxic Syndrome induced by Cabin Air in certain types of aircraft”.

The point I’m trying to make is NOT to discuss the various reports produced across the world on this topic or to criticize the methodologies myself. There are separate threads for this. But I do know that, if every aviation medical restriction were to be subjected to the same scrutiny, that is, if every medical restriction that would not persist under evidence based testing for operational relevance and statistical significance were to be deleted, the aviation world would be a much better place.

It is in this sense that I reproach the senior aviation medical staff to use a bias (or a double standard) : when an airline company or an aircraft manufacturer is at risk for paying out substantial medical compensation claims, they apply a statistical significance methodology to reject them (which, under the circumstances, might be perfectly valid). But for medical restrictions, it’s apparently ok to work with some gut feelings, anecdotes and oversimplifications.

- Use of EFIS displays by Colour Blinds
This is a very well documented flawed piece of research by an Australian Professor trying to demonstrate that colour blind people would be less effective in a modern cockpit.

There is evidence about multiple correspondence between the Australian CAA and said professor on devising the best strategy to reject appellants with a colour deficiency. The most blatant example of a conflict of interest, in order to maintain a constant stream of ophtalmologic research grants to his institute and to protect his sponsors, the companies that manufacture or sell expensive optimetric testing equipment for pilots.

Again, I DON’T want to open the debate on colour blindness in aviation here. But in view of the large diversity in colour deficiency and in the absence of scientifically sound work on specific operational limitations of colour deficient pilots, I find it mind boggling that in this day and age the Aviation Medical community is putting up with nonsense that colour blinds must not get a class 1 medical.

And there are many other regulations in place that should be backed by medical evidence but in fact are not. Do you know of an aeromedical topic more intensively studied than hypoxia ? Well then, why is the altitude limit 10,000 feet in Europe and 12,500 feet in the US ? Is there scientific evidence about enhanced incapacitation at 11,000 feet ? Do we have accident statistics in support about pilots crashing on landing more after a high altitude cruise ?

Yes I’ve experienced some euphoria when seeing my altimeter at FL 110 and I’ve been known to occasionally yawn after two hours at that flight level, but then again it is relatively lonely up there (the airlines are flying higher and the flying club enthusiasts lower).

The point is that this is an example of a regulation that actually should be a recommendation. Indeed, hypoxia (effects) can occur at any flight level and a lot depends on the circumstances (e.g. it is suggested to fly lower at night). But it should suffice that pilots (through their theoretical and practical training) are made aware of the dangers of hypoxia and able to recognize telltale signs of its occurrence.

Even the CAA accept that some of their decisions are over tough

But they don’t seem to admit that in public. Otherwise they would make themselves liable under a discrimination case. On the contrary, some CAA’s even conspire to keep rules tough (for whatever motives). Which is why senior doctors should be a lot more outspoken about some of the CAA decisions being over tough.

This document therefore is a breath of fresh air. Most of the changes arise not because of pilots nor the regulators but because medical research and advances in disease management mean the risk of incapacitation has fallen. I know one of the specialists who advised EASA and know he spend many months persuading them.

I agree with that.

So to suggest doctors are uncaring crooks hell bent on grounding pilots and people who spend their time publishing fraudulent research is very much shooting yourselves in the foot. If EASA were to believe these silly claims they would immediately tear up the document, accusing the doctors of lying, and reimpose the older more stringent restrictions.

Here you are mixing up two posts into a non-existent opinion. In my experience, most non-flying doctors are sufficiently uncaring not to speak up. And the Australian professor for one has been spending his time publishing fraudulent research. But of course the prevalence of crooks among the medical community is unlikely to be higher than among the rest of society.

No, because EASA has spent quite a bit of time carefully drafting this document, which we both agree is a breath of fresh air.

Let me finish with an example. Until recently you could not fly if you were an insulin dependant diabetic. Many insulin dependant diabetics continue to have hypos and poor control. So why are we seeing change? Is it because the public are shouting to be flown by a diabetic pilot? No. Is it because the regulators are having a be nice to diabetics week? No. It is because of newer insulins and research you seem to consider fraudulent showing we can obtain tight blood sugar control without hypos.

Exactly. What I’m saying is that we should be having a “nice to diabetics” attitude every single day of the year. I’ve seen an older pilot (a Mooney owner) in tears at the AMC being after being grounded as a diabetic. All the AME’s were sympathetic in the “poor Jean, we’re really sorry for this” sense. But that is not caring. Caring would have been : “Jean, if you’re willing to go for this treatment and then perform these tests while flying, we can still grant you the class 2 medical and you can do such and such. The reason why we're imposing this on you is that, if you don't do such and such, there is a significant chance that you would faint and we can't have that while you're up there”.

It is that kind of attitude that I’m lacking with the non-flying AME’s and advisors. And that was actually the only point I was making.

@ Denti :
You're of course right about the "hundreds of hours of dual". That was a contamination of "well over a hundred hours of dual" and "hundreds of hours of flight time". The point being that it takes a bit of flying before becoming an ATP.

The 90 hours case I read about in AOPA magazine a couple of years ago. It was an interview with a movie star recently having obtained his private certificate (PPL). You can get to 90 hours if you don’t have time to train every week and if you want to be thorough and confident in all the manoeuvres and procedures. I fail to see the link with stupidity. The movie star probably makes about 20 times the average dentist’s income. But then again, money is not everything in life.

Anyway, it is quite bizzare to let stuff crop up during training instead of a few simple tests before spending all that money.

I was not advocating not doing a medical test before starting flight training and warn aspirant pilots about potentially incapacitating issues further down the road. But it’s another matter to restrict pilots from exercising their profession or means of transport if there is insufficient evidence to do so. Then it quickly reeks of unlawful discrimation.

I would think that quite a lot of the considerable relaxation in medical rules within the last 10 years have been based on comments of those specialists.

That is undoubtedly so. Notwithstanding that, we pilots have encountered quite a bit of grief too from “those specialists” over the last 10 years. And I my opinion, Aeromedical Experts that fly themselves have a more reasonable view on regulations, which was the only reason for my initial smiley comment.

Incidentally, that applies to any kind of aviation regulation. One of the things that EASA is suffering from (or should I say, the citizens are suffering from) is the lack of actual pilots involved in the rulemaking process on the regulator side.

[Gulfstreamaviator]

My AME experience has all been good

I passed my Class 3 for my PPL, many years ago, and was surprised that I passed.

A few years later I took the UK CAA ATPL medical, and passed. very pleased and surprised.

Each year since then, (35+) I have passed a UK Class 1, as well as GCAA Initial, and FAA Initial, (which was no different than a recurrent).

There have been many examples of when the AME suggested that I either loose weight, or learn the eye chart, or next time have a set of eye glasses.

I have had only one problem AME, he insisted in an anal exam, to verify no hemorrhoids. Also that the dangly bits looked OK. I changed examiners, to a lady doctor, she was not so concerned.

I have FAA renewals in various countries now, and have no problem attending with a open mind.
However I would never pass a (revised) EASA recurrent.

Glf

[Viola]

Interesting, 90 hours just for a PPL which any halfway non-stupid person can do in just 40 hours including the test ride. Tell that person to take up another hobby.

It took me nearer 90 hours than 40 hours to get my PPL and I've several hundred hours, IMC (renewed) and night. I hope I'm better than half stupid!