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Pilots showing psychological abrasions may be referred to AFCME, New Delhi/IAM Bangalore for further evaluation before release.

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To
Shri Lalit Gupta
Jt. Director General

O/o DGCA
Opp Safdarjung Airport
New Delhi 110003

2nd August 2015

Respected Sir ,
After having read the " REPORT OF THE GROUP TO RECOMMEND POLICY ON MANNING OF COCKPIT AND MEDICAL/PSYCHOMETRIC TEST FOR FLIGHT CREW " we have the following comments to make on the report .

We understand that this report arises out of the need to prevent a crash similar to the German Wings flight 4U9525.

We request the DGCA to please look into these comments urgently

1. We appreciate the DGCA policy on cockpit manning and have no further suggestions to make on the same.

2. The terms Psychometric Analysis / Test , Psychology and Psychiatry have not been defined in the report . There seems to be utter confusion as the report treats all three terms as one and the same and keeps interchanging them through out the report.

3. In order to become a Psychiatrist one needs to study and obtain an MBBS degree followed by an M.D in Psychiatry.

A Psychologist is someone who has studied the subject of psychology at the Bachelor / Masters degree level.

4. The fundamental difference between a Psychiatrist and Psychologist is that a Psychiatrist can prescribe medication while a Psychologist on the other hand cannot do the same.

5. As far as our understanding goes Psychometric Analysis / Tests are nothing more than JOB APTITUDE tests used to PREDICT whether a particular candidate is ideal for a particular position.

The ideal candidate is based on PRECONCEIVED NOTIONS and varies from company to company even for exactly the same kind of job.
Psychometric tests are used by a wide variety of companies all over the globe for variety of professions.

It is nothing more than a predictability / probability indicator and has no guaranteed accuracy whatsoever.

Psychometric tests suffer from the VICE of ARBITRARINESS as candidates receive no feedback / explanation or opportunity to explain themselves the results of the psychometric test

They have no clue what constitutes a pass or a fail or what they can do to improve themselves.
This was observed by us during the Air India recruitment for A320 type rated pilots.

I would like to remind you that some pilots rejected by Air India have been offered jobs at other airlines flying the exact same kind of airplane.

When compared to normal medical tests candidates are told whats wrong with them and what they can do to cure or improve their medical condition if a cure exists.

However psychometric tests do not offer a chance for review.

6. The report has not justified as to why Psychometric Testing should be made mandatory for pilots despite the report very clearly pointing out that no other Civil Aviation Authority in the world has the recommended the same for its pilots.

It has not quoted any sources which say that psychometric testing would prevent an accident similar to the German Wings crash.

It has however used the German Wings crash as an excuse for making psychometric testing mandatory.

7. Even the EASA task force setup in the wake of the German Wings crash has recommended Psychological tests and NOT Psychometric Tests.
http://ec.europa.eu/…/germanwings-ta...inal-report.p…

8. We would like to inform you that the pilot involved in the German Wings crash successfully cleared all the necessary psychometric tests needed to join as a cadet pilot known as the DLR Test.

Despite passing the psychometric exam the FAA had initially denied him a medical certificate as he had declared suffering from depression on his medical application and had taken medication for the same.

It was only after the FAA obtained a letter from the pilots doctor saying that he is cured and no longer on medication that the FAA issued a medical.

This above mentioned point is the biggest and most GLARING example that is available in the Aviation world that psychometric tests cannot test / predict the Mental Health of a Pilot.

It was only on the own admission of the pilot that the aviation authority was even aware ofa mental health disorder that needed medication.

9. We are quite perplexed as to why the DGCA would suggest a JOB APTITUDE test in place of a medical test for picking up mental health issues .

This very important in light of the report 3.1 saying
" It may be seen that the medical standards of flight crew mandated by DGCA are in line with international best practices and do not require any amendment " ( copy pasted from the report )

Recommendation 4.2
" There is no need to amend CAR Section 7, Series C, Part I on “Medical Requirements and Examination for Flight Crew Licences” as it is in line with ICAO Annex 1 requirements " ( copy pasted from the report )

On page 8 of the report the DGCA has shown a sample psychometric test via a) , b) and c) .

However nowhere in the example does it indicate that these tests are designed to detect issues of mental health.

Item c) clearly states that its a PILOT APTITUDE TEST.

These tests would not indicate someone suffered from depression or other mental health disorders unless expressed explicitly.

The present DGCA medical standards nor the medical standards anywhere in the globe have seem to have any sort of procedure to potentially identify someone with mental health disorder UNLESS admitted to by the pilot.

A pilot is not subjected to a Psychiatric assessment during the initial and renewal medicals.

Then why does the report blindly declare that nothing needs to be done to the medical standards in dealing with what is essentially a medical problem ?

10 . The German Wings crash is the best example to point out the failure of Psychometric tests in picking out mental health disorders.

It would be extremely unwise on the DGCA's part as safety regulator to suggest Psychometric Test which has proven itself to be a known failure as a some sort of solution in predicting one's mental health.

11. We do not agree with recommendation 4.3 a) , 4.3 b) , 4.3 c) as these have nothing to do mental health issues but more based on what an individual perceives to be an IDEAL PILOT or IDEAL LEADER . These notions are based on ones background and varies from individual to individual.

The DGCA should respect the right to recruit / admit individuals as per the needs of a particular organisation and not interfere in their recruitment methods.

Since mental health issues are medical problems then should it not be detected by the DGCA when it conducts class 1 medical tests ?
Are not medical tests the responsibility of the DGCA ?

12. I recommend the DGCA to wait for the final German Wings crash report and observe the policies by other Aviation Authorities including ICAO in dealing with mental health issues .

13. The DGCA should also hold a public hearing in this regard and give an opportunity to debate these issues with the people that are most affected by the implementations of this report i.e Pilots of India.

I sincerely hope that the DGCA listens earnestly to the above recommendations at the earliest.

Yours Sincerely

Unemployed Pilots Welfare Association

Copy of this email to

Smt M Sathiyavathy - Director General ( DGCA )

Shri Rajiv Nayan Choubey - Secretary ( MoCA )

Dr. Mahesh Shamra - Hon'ble MoS ( MoCA )

Shri Ashok Gajapati Raju - Hon'ble Minister ( MoCA )

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