EASA Opinion 9/2016: PART-MED Update
It is recognised that:
— although the overall number of aviation accidents with a medical cause or contribution is small, they have the propensity to result in rare, catastrophic accidents; and
— not all medical events are predictable.
An initial Class 1 medical assessment includes a review of the medical history, examination and several tests, among which a general mental health assessment. If the medical history or discussion raises concerns about the candidate’s psychiatric or psychological status, the candidate is referred to a psychiatrist or a clinical psychologist for review prior to their fit status being decided.
The system puts emphasis on the ability of the AMEs to detect disorders in all fields of medicine, including psychiatric and psychological disorders. Sometimes these disorders are difficult to detect, for example because no early symptoms exist, or when individuals are not open about their symptoms, thoughts or behaviour.
Psychiatric conditions or disorders, which are likely to interfere with the safe exercise of the privileges of the licence, may remain undetected. The probability of such occurrences depends on the competency of physicians performing aero-medical assessments. Currently, aero-medical assessments of pilots include questions and interview techniques that can be used to assess mental fitness. However, it is recognised that the effectiveness of such methods is limited due to the following:
— Clinical signs of psychiatric deficiencies may vary over time.
— Aero-medical training in psychology/psychiatry of AMEs does not provide them with the sufficient knowledge to diagnose (and treat) these medical conditions on a professional level.
— There are barriers affecting a frank discussion on mental health issues between an AME and a pilot.
In addition, no systematic satisfactory psychiatric assessment is required for the renewal of class 1 medical certificates of applicants with an established medical history of psychiatric condition such as: mood disorder, neurotic disorder, personality disorder, mental or behavioural disorder or misuse of psychoactive substances.
Consequently, current aero-medical assessment techniques do not efficiently address the risks related to psychiatric conditions which are likely to interfere with the safe exercise of the privileges of a licence, as initially intended by MED.B.055.
Furthermore, currently aero-medical assessments do not include systematic psychological assessment. Therefore, psychological deficiencies, which are likely to interfere with the safe exercise of the privileges of the licence, may remain undetected, for the reasons explained above.
Consequently, current aero-medical assessment techniques do not efficiently address the risks related to mental or behavioural disorders which are likely to interfere with the safe exercise of the privileges of a licence, as initially intended by MED.B.060.
The available guidance on risk assessment for pilot incapacitation in a multi-crew environment is not adapted to mental impairment and incapacitation. Mental illnesses may lead to deliberate harmful actions, which may be conducted to ‘maximise damage’. The second pilot can be physically prevented from taking over. Acceptable mitigation measures for other medical incapacitations are not adequate for mental impairment.