In the wake of the March 2015 Germanwings crash (http://bit.ly/2NS1jjv), a quickly assembled EASA task force (http://bit.ly/2p3ck9o) came up with 6 recommendations, including the implementation of PSPs. On these 6 recommendations, 3 were either abandoned or never followed up and 3 have been included in EASA’s Regulation EU 2018/1042.

Pilots should undergo a psychological evaluation before entering airline service

Most pilots already underwent psychological screening before entering airline service as part of the airline selection programme. For obvious reasons, some smaller (e.g. Pay-2-Fly) companies did not bother. As from 14 August 2020, CAT.GEN.MPA.175 ‘Endangering safety’ (http://bit.ly/2PW1z3w) will require every airline “to ensure that a psychological assessment has been performed to (1) identify psychological attributes and suitability of the flight crew in respect of the work environment, and (2) reduce the likelihood of negative interference with the safe operation of the aircraft.” This assessment can be internal or external, should be overseen by an aviation psychologist and should include at least the following criteria:

• cognitive abilities
• personality traits
• operational and professional competencies
• social competences in accordance with crew resource management principles

Additionally, the AMEs are advised by AMC1 MED.B.055 ‘Mental health’ (http://bit.ly/2NQ0wQd )that the assessment should include review and documentation of:

• current work and life stressors;
• coping strategies under periods of psychological stress or pressure in the past, including seeking advice from others;
• any difficulties with operational crew resource management (CRM);
• any difficulties with the employer and/or other colleagues and managers; and
• interpersonal and relationship issues, including difficulties with relatives, friends, and work colleagues.

Obviously, the AME should obtain expert advice when there are signs or established evidence of a psychiatric or psychological disorder.

Unfortunately, this requirement has led the Austrian CAA to set up a questionnaire including questions such as ‘Does your relationship status change frequently and how often?’, ‘Are you looking for a new job at the moment?’, ‘Do you have any problems with your employer or managers?’. But even more worrying is that the Part MED suggests using accidents or incidents, problems in training or proficiency checks and behaviour or knowledge relevant to the safe exercise of the privileges of the applicable licence(s) as sources for this information! BeCA has raised these questions with ECA and will be doing the same at BCAA level.

Airlines should run a random drug and alcohol programme

Although drugs and alcohol were no issue in the Germanwings disaster, the UK and Germany gratefully used it to push their agenda on random testing of psychoactive substances. This is why CAT.GEN.MPA.170 ‘Psychoactive substances’ now requires operators “to develop and implement a policy on the prevention and detection of misuse of psychoactive substances by flight and cabin crew members and by other safety-sensitive personnel under its direct control in a consistent, just and fair manner.” Furthermore, the operator needs to educate and train crews on the misuse of psychoactive substances including the assistance provided by support programmes. Testing needs to be done:

• upon employment
• following a reasonable suspicion and assessment by appropriately trained personnel
• after a serious incident or accident within the meaning of Regulation (EU) No 996/2010, provided that testing is possible.

In Belgium drugs and alcohol-testing can be performed by the police and by your company, but only if such procedures and their consequences have been stipulated in your employment contract under CLA100 (NL: http://bit.ly/2Q0nYwG; FR: http://bit.ly/2ritAbg). Company tests can only be performed with prior agreement of the employee and with the objective of prevention. This means that in case of a positive test, it cannot be the sole argument for disciplinary action. Neither can these tests be a source of discrimination.

However, it may still be an element in the overall evaluation.

As BeCA we share the position of the European Cockpit Association (ECA) (http://bit.ly/2K3K9hJ) and believe that the money spent on random testing would be of better use when invested in Peer/Pilot Support Programmes (http://bit.ly/2WUZvu8). At the same time, BeCA and ECA are worried about the lack of internationally agreed thresholds, risk levels, and lists of unacceptable drugs. Together with the lack of uniformly accepted testing methods, these may lead to significant ‘false positives’ rates. This is why whenever pilots are subjected to random testing it is essential to adhere to some key requirements. Testing…

• needs to be fail-proof and protect against ‘false positives’, with any test having a B-sample that is to be used to confirm a positive outcome, after analysis by a different laboratory;
• needs to be subject to stringent procedures and testing methodologies, and to high standards of forensic reliability;
• should provide for a non-punitive appeal mechanism;
• can only be carried out by properly trained and mandated (external) personnel;
• should be strictly confidential and performed away from the public and passengers;
• should preferably be carried out prior to reporting for duty and not interfere with flight preparation;
• should provide for a staff representative to be involved on the crew’s request.

Robust programme for oversight of aeromedical examiners should be established

The fourth recommendation suggested establishing a robust programme for oversight of aeromedical examiners. Apparently, there is improved cooperation between the Part MED responsible departments of the different EU Member States, but for now, it is unclear if there are any changes in the way AME oversight is conducted.

A European aeromedical data repository should be created

In order to avoid ‘medical shopping’ among aspiring pilots, the EASA task force suggested setting up a European aeromedical database. ARA.MED.160 talks about such a repository, but it’s still unclear what information will be included in the repository.

The principle of ‘two persons in the cockpit at all time’ should be maintained

A few days after the crash, many airlines followed EASA’s Safety Information Bulletin 2015-04 (http://bit.ly/2WZhvDU) and implemented a so-called 4-eye cockpit rule: at any given time there needed to be two persons in the cockpit. This new rule was nothing more than window-dressing and a shortsighted reaction to show the frightened travelling public that the airlines were taking care of the problem. All the contrary. This rule actually meant that it became easier for terrorists to get access to the cockpit: the pilot leaving the cockpit needed to call beforehand, making it easy for any passenger to know when the door would be opened; furthermore it’s far easier and faster to train a suicide cabin crew member than a pilot. One year later, following a regulatory survey (http://bit.ly/2p3cU74)to which BeCA and other pilot associations contributed, EASA revoked the recommendation and most airlines abandoned the ineffective rule.

Pilot support systems should be implemented within airlines (see previous article)