Helicopter Pilot Medicals
It would seem that just about everything we do in commercial aviation is associated with a verified procedure or checklist and pilot medicals are no exception – lines drawn in the sand that may be bent only when the pilot-in-command has a very real reason to do so. Rather than being unduly restrictive, such guidelines provide a framework around which routine operations are built, enhancing safety through their predictability.
But, as always, there is the human variable and for this there is no preflight checklist where one size fits all.
The human factor has long been recognised as both a potential strength and weakness. Studies have tried to identify the human holes in Dr Tames Reason’s Swiss cheese model before they occur, but still they do – and unfortunately always will. We arc a diverse breed and any attempt to place a rigid template over a fluid form will only ever meet with limited success.
The transition from CAO 48 flight and duty time limitations to a more tailored fatigue risk management system (FRMS) is one example of trying to make the template a little malleable. Even then, it can never cater for all scenarios, in all companies, for pilots of all makes and models.
The human condition is just too far ranging and consequently, the pilots themselves must become the final slice of Swiss cheese once again. Into the mix is the fact that fatigue is only one aspect of assessment for an individual’s fitness to fly. When considering the physical wellbeing and the psychological state of a pilot, these two towering oaks branch off into a mire of low-lying weeds.
Financial pressures, personal relationships, drug and alcohol issues, depression, commuting and even the common cold are just a few of the potential threats that need to be assessed and navigated. Complicating matters is that these troubles may well be interrelated showing up in pilot medicals.
Stress of finances can put pressure on the relationship and then the constant duress leads to a collapse of the immune system, resulting in physical illness. Now the pilot is trapped in a Catch 22. When money is the issue, sick leave can impact upon the household income and the spiral just keeps tightening. And this is just one possible scenario.
Complicating matters, often the pilot in the spiral can’t recognise the critical nature of the situation. Like hypoxia, where the brain is deprived of oxygen, the sufferer may not see the symptoms. A dipstick can check oil levels in an engine and a transmissometer can measure the visual range on a foggy runway, but there is no means by which pilots can readily self-assess their fitness to fly.
In a perfect world, at the first sign of any self-doubt an individual would advise flight operations that they are unable to fly and seek help. On recovering, they would return to flying the line, happier and healthier than ever. However, other human weaknesses such as denial, pride, ego and embarrassment can begin to whisper in the ear. Task-driven, pilots can be their own worst enemy.
Even though support systems exist within an airline, some are hesitant to use them. Others may have close workmates who can read the warning signs, but too often any signs of weakness can be hidden by a master of disguise. It can be tough enough for a trained professional to recognise the signs, let alone a friend or colleague who may have their own struggles.
Perhaps a starting point is to treat one’s personal fitness as if it were a flight. Check the serviceability of the machine, brief on what lies ahead, ensure there is enough fuel in the tank and have an alternate plan to cater for the situation if it changes.
It may sound strange, but it is the language of a pilot’s brain and might just lead them into familial” decision-making territory. And let’s not forget the multi-crew aspect, where the subsequent decisions are cross-checked before they are enacted.
Pilots have an important role in looking out for each other…
Aviation is no different to any other cross-section of our society. Pilots are bombarded with information from all directions and are inherently time poor, the vice can turn so slowly upon us that we may not even realise that we are in its grip. However, as difficult as it may be, pilots must find a way to self-assess that they are truly fit to take their seat for the commencement of each and every sector.
They have a responsibility to their family, crew and passengers to be rested and ready to deal with what may come their way. And should they find that something just isn’t right, or it be suggested by another, then they need to step back and sometimes this is the bravest decision of all.
If a pilot’s performance is impaired, it will not manifest in their failing to meet KPIs and budget targets. Nor can they step out momentarily into the stairwell and throw their head into their hands. If a pilot is off their game and fate deals a tough hand, they can be found wanting with the lives of all on board in their care.
For all the reporting systems, educational slide shows and reading material a well-intentioned employer may provide, a pilot’s fitness to fly is as individual as it gets. Ultimately, it is another situation to assess and another decision to make before the wheels ever leave the ground.
There is no checklist or promulgated procedure, only friends and family to recognise the warning signs and the courage to discuss it. The means of rectification are as varied as the problems themselves, but the first and most difficult step can be recognition through pilot medicals.
Perhaps after all, in life as in flying, we have to check the serviceability, current and future conditions, fill the tanks and allow for the unexpected. And only then will we be truly fit to fly.
NEW THIRD CLASS PILOT MEDICALS PROVISIONS
It is now official, as of May 1,2017, the FAR’s will contain provisions that allow an individual to exercise the privileges of a private pilot without the need for a third class medical certificate. But. let me quickly add, there are a number of conditions and caveats in the new rule. Those looking for specific details must review the “Final Rule.”
www.faa.gov/news/updates’ media/final_rule_faa_2016_9157.pdf, and Advisory Circular 68-1, www.faa.gov/document Library/media/Advisory Circular/AC_68-l.pdf. These two fun-filled documents total 112 pages of legal language that needs to be read several times in order to get a full grasp on what is going on.
It had been the intent of this writer to summarize this final ruling, but space will simply not allow this. Instead, allow the opinions of this writer to set the stage and then take a look at the FAQ’s that are included directly from Advisory Circular 08-1. This is probably the fastest way to get some idea of what this ruling entails.
But first, a small dose of history. Why do we care about dropping the third class medical? Simply stated, the third class medical certificate has become a major cost factor and obstacle for those currently involved in recreational flying and for those who would like to start flying.
Policies of the FAA Medical Division have moved far away from the original intent to ensure that we have reasonably healthy pilots. It has become an overwhelming intent of die bureaucracy to maintain jurisdictional power and self-preservation.
While it is certainly reasonable to have rules that try to ensure that pilots with health issues, which can affect flight safety do not endanger passengers or persons on the ground, we do not need the huge expense and complexity of the current FAA medical structure.
The main point to remember is that medical issues that affect the pilot’s ability to fly the plane are not even a “nit” in safety statistics and never have been. There has never been a statistical reason for having a medical certificate for recreational and amateur pilots.
There were no federal medical standards for pilots from the Wrights’ first flight until 1926. The Department of Commerce did pick up some responsibilities in 1927 for professional pilots, as did the U.S. Postal Sen ice (airmail pilots). In many instances, a pilot certificate could be issued by a state with no federal intervention.
Civil aviation was fully federalized in 1938, with creation of the Civil Aeronautics Authority, (CAA) the direct predecessor of the FAA, created in 1958. However, medical standards for civil pilots came into play in late 1938, with the creation of the Civilian Pilot Training Program (CPTP).
This was a grant program designed to help pull the private aviation industry out of the doldrums of the Great Depression, but it had a dark secret. While sold to Congress by the Roosevelt Administration as a boost to civil industry, it was actually designed to train pilots for the upcoming war that loomed on the horizon.
As such, pilot medicals standards were included, primarily to identify those who would later be drafted into military service. The plan worked, but the medical standards designed for military service became entrenched in civil aviation, to include recreational flying. Once in place, they have never been withdrawn.
Now we jump forward to 2012, when Congress decided that it needed to put a lid on the draconian enforcement practices of the FAA, The Pilot’s Bill of Rights, passed in August 2012, required the FAA to stop unilateral enforcement actions and required the FAA to use the same practices of due process that are afforded a jerk who robs a convenience store.
The FAA implemented normal legal practices but did not pursue an action in a reasonable time, meaning pilots accused of an infraction might have the threat of action hanging over their heads for years. Along came the Pilot’s Bill of Rights 2, which corrected this problem and sought to do away with the obsolete and very costly process of the third class medical.
Regretfully, the Executive Office made it very clear that the Pilot’s Bill of Rights 2 would not be signed if any part of the FAA bureaucracy ended up without a job, even if the job was obsolete. Federal employee unions won the day, and Congress wrote a compromise to the “ending of the third class medical battle” that would help get rid of this obsolete “boat anchor” while maintaining a useless bureaucracy.
Yep, only our politicians could figure out how to make this happen. The result is the Final Rule, to be enacted on May 1,2017.1 think the FAQs will answer some of your questions, and this writer will follow this rule closely with more details in continuing issues of In Flight USA. It is the intent of this writer to utilize the new provisions, so stay timed for a firsthand account.
AC 68-1 Appendix B.
Frequently Asked Questions
Q: How did the FAA come up with these BasicMed pilot medicals requirements?
A: The FAA did not develop these requirements. The requirements are from the U.S. Congress, which enacted the FAA Extension, Safety, and Security Act of 2010 (PL 114-190) (FESSA) on July 15, 2010. Section 2307 of FESSA, Medical Certification of Certain Small Aircraft Pilots, directed the FAA to “issue or revise regulations to ensure that an individual may operate as pilot in command of a covered aircraft” if the pilot and aircraft meet certain prescribed conditions as outlined in FESSA.
Q: Is there a grace period for meeting BasicMed?
A: You can operate a covered aircraft either with a medical certificate or by using BasicMed privileges. If you don’t meet all of the BasicMed requirements, then you must hold an FAA medical certificate.
Q: Does BasicMed affect sport pilots?
A: No. If you are exercising sport pilot privileges in an aircraft that meets the definition of a light-sport aircraft, then you may continue to operate using either a driver’s license or an FAA medical certificate. BasicMed privileges are not intended to be exercised by Sport Pilots.
Q: What documents do I need to carry to exercise BasicMed?
A: Only a valid driver’s license (in addition to the other required documents not identified under BasicMed such as your pilot certificate and photo ID (which can be your driver’s license)).
Q: What documentation do I need to keep?
A: You only need to keep a copy of your Comprehensive Medical Examination Checklist and your medical education course completion certificate. You can store these in your logbook, or you can store them electronically in any format, as long as you can produce an accurate representation of these documents at the request of the FAA. You don’t have to carry these documents while flying under BasicMed.
Q: Can I exercise my CFI, as PIC, under BasicMed?
A: Yes. as long as you are flying a covered aircraft.
Q: Can I use BasicMed to act as a safety pilot, rather than holding a medical?
A: Only if you’re acting as PIC while performing the duties of safety pilot. BasicMed applies only to people acting as PIC; it cannot be exercised by safety pilots who are not acting as PIC but are required crewmembers.
Q: Do I still have to have a flight review required by § 61.56?
A: Yes. BasicMed does not affect any pilot requirement other than the holding an FAA medical certificate.
Q: I’ve mislaid my BasicMed course completion certificate. Can I still fly under BasicMed?
A: No. Although they don’t need to have them in your personal possession, you must be able to produce the BasicMed course completion certificate and the completed CMEC (or an accurate and legible representation of those documents) while operating under BasicMed. You should contact the provider of the medical course to obtain a replacement course completion certificate.
Q: Can I tow advertising banners or gliders while exercising BasicMed?
A: Yes, as long as you are not receiving any compensation for those flights.
Q: Can I use BasicMed privileges to take an Airline Transport Pilot practical test?
A: Yes. A person taking any FAA practical test is exercising no more than private pilot privileges because the operation is not being conducted for compensation or hire.
Q: I use an electronic pilot logbook. Can I use this to store my BasicMed documentation?
A: You can attach those documents to your electronic logbook, or you may store them in any other fashion as long as an accurate and legible representation of those documents can be made available upon request, the same as for your pilot logbook.
Q: The pilot medicals course required that I enter my personal information and the name and license number of the physician who conducted my individual medical examination. Why is the FAA collecting this information?
A: The legislation (FESSA) requires the FAA to collect that information. The pilot’s personal information will be used to conduct the NDR check. The FAA will store the information. It is required by FESSA to collect in the airman’s record. Hold, or Have Held, a Medical Certificate Since July 15, 2006.
Q: I can’t remember if my medical certificate was valid after July 15, 2000. How can I find out if I meet the BasiciMed requirements?
A: You may contact Federal Aviation Administration. Medical Certification Branch, AAM-331, P.O. Box 26200, Oklahoma City, OK 73125-9914 (phone: 405/954-4821) to ask when your most recent medical certificate expires or to request a copy of your most recent medical certificate.
Q: Can I exercise BasicMed and hold a medical certificate at the same time?
A: Yes. If you are operating under BasicMed. then you must comply with the BasicMed operating limitations (such as flying only within the U.S. and at or less than 250 knots). When operating under BasicMed, you are not exercising the privileges of your medical certificate.
Q: My medical certificate expired in 2011 and I submitted an application for an FAA medical certificate using MedExpress. but I never went to an A M E for my physical exam. Does this application prevent me from using the previous medical certificate to meet the requirement to hold a medical certificate at any point after July 15,2006?
A: No. Since an A M E never accessed your application, you didn’t complete the application process, and you may use the previous medical certificate (before you submitted your MedXpress application) to comply with BasicMed.
Q: My most recent medical certificate was suspended by the FAA and then later reinstated. May I operate under BasicMed?
A: No. If your most recent medical certificate was suspended (even if it was later reinstated) you must obtain a new FAA medical certificate of any class before operating under BasicMed.
Comprehensive Medical Examination
Q: How do I find a physician to conduct the BasicMed medical examination?
A: Any physician who is familiar with your complete health history would be a good choice. Also, some AMEs may elect to provide medical examinations under BasicMed.
Q: My state-licensed physician who conducted my medical examination refused to sign the CMEC. What can I do?
A: You should check with your physician to see what the medical reasons were behind his or her decision not to sign the CMEC. You may not operate under BasicMed without a completed CMEC, and the FAA strongly recommends addressing those medical issues before flying under any circumstances.
FAA ISSUES GENERAL AVIATION MEDICAL RULE
The Federal Aviation Administration (FAA) on Jan. 10 issued a final rule (www.faa.gov) that allows general aviation pilots to fly without holding an FAA medical certificate as long as they meet certain requirements outlined in Congressional legislation. “The United States has the world’s most robust general aviation community, and we’re committed to continuing to make it safer and more efficient to become a private pilot,” said FAA Administrator Michael Huerta.
“The BasicMed rule will keep our pilots safe but will simplify our regulations and keep general aviation flying affordable.” Until now, the FAA has required private, recreational, and student pilots, as well as flight instructors, to meet the requirements of and hold a third class medical certificate. They are required to complete an online application and undergo a physical examination with an FAA-designated Aviation Medical Examiner.
A medical certificate is valid for five years for pilots under age 40 and two years for pilots age 40 and over. Beginning on May I, pilots may take advantage of the regulatory relief in the BasicMed rule or opt to continue to use their FAA medical certificate.
Under BasicMed, a pilot will be required to complete a pilot medicals education course, undergo a medical examination every four years, and comply with aircraft and operating restrictions. For example, pilots using BasicMed cannot operate an aircraft with more than six people onboard, and the aircraft must not weigh more than 6,000 pounds.
A pilot flying under the BasicMed rule must:
Possess a valid driver’s license;
Have held a medical certificate at any time after July 15,2006;
Have not had the most recently held medical certificate revoked, suspended, or withdrawn;
Have not had the most recent application for airman medical certification completed and denied;
Have taken a medical education course within the past 24 calendar months;
Have completed a comprehensive medical examination with a physician within the past 48 months;
Be under the care of a physician for certain medical conditions;
Have been found eligible for special issuance of a medical certificate for certain specified mental health, neurological, or cardiovascular conditions when applicable;
Consent to a National Driver Register check;
Fly only certain small aircraft, at a limited altitude and speed, and only within the United States; and
Not fly for compensation or hire.
The July 15, 2016 FAA Extension, Safety, and Security Act of 2016 directed the FAA to issue or revise regulations by January 10,2017, to ensure that an individual may operate as pilot in command of a certain aircraft without having to undergo the medical certification process under Part 67 of the Federal Aviation Regulations, if the pilot and aircraft meet certain prescribed conditions outlined in the Act.
The FAA and the general aviation community have a strong track record of collaboration. The agency is working with nonprofit organizations and the not-for-profit general aviation stakeholder groups to develop online pilot medicals courses that meet the requirements of the Act.
EAA STATEMENT ON FAA RELEASE OF THIRD-CLASS MEDICAL REFORM RULE
FAA’s BasicMed Hill Take Effect on May 1, 2017
Years of effort by EAA and AOPA culminated last month as the FAA announced regulations that will implement the aeromedical reform law passed last July. The regulations will be published as a final rule, to take effect May 1,2017.
According to the FAA, no changes have been made to the language in the law. Because it is final, the rule—named “BasicMed” by the FAA—will not go out for a typical public comment period. The FAA also said it would publish an advisory circular describing the implementation of the rule later this month.
“This is the moment we’ve been waiting for, as the provisions of aeromedical reform become something that pilots can now use,” said Jack J. Pelton, EAA CEO chairman. “EAA and AOPA worked to make this a reality through legislation in July, and since then, the most common question from our members has been. ‘When will the rule come out?’ We now have the text and will work to educate members, pilots, and physicians about the specifics in the regulation.”
Last month’s announcement finalized the highly anticipated measure that was signed into law last July as part of an FAA funding bill. That was the ultimate success of a long effort by EAA and AOPA to bring significant aeromedical reform to pilots flying recreationally and eliminate the time and expense burdens on those holding third-class pilot medicals certificates.
The law guaranteed that pilots holding a valid third-class medical certificate issued in the 10 years before the reform was enacted will be eligible to fly under the new rules. New pilots and pilots whose most recent medical expired more than 10 years prior to July 2010 will be required to get a one-time third-class exam from an FAA-designated AME.
The FAA was required to implement the law within 180 days of its signing and did so by Jan. 12. Since AirVenture 2016, FAA senior leadership has been assuring EAA that the 180-day deadline would be met. Despite the release of the regulations as a final rule, EAA will be reviewing the language carefully to ensure it fully reflects the language and intent of the law.
EAA has updated its Q&A and will continue to update them to provide the latest information. EAA is also working with its aeromedical and legal advisory councils to provide resources that will help members and their personal doctors understand the provisions of the new regulations. For more information, visit www.eaa.org.
UK changes PPL medical standards
The UK Civil Aviation Authority (CAA) has announced that medical requirements for some private pilots will change. The move will lead to both cost and time savings for pilots and, in most cases, remove the need for General Practitioner (GP) or Authorised Medical Examiner involvement in the process. The change follows a public consultation, in which 96 percent of those responding agreed with the proposal.
Once the change takes place later this year, the medical requirement for UK private pilot licence and national private pilot licence holders will be to meet the same standard as that required to hold a driver and vehicle licencing agency (DVLA) Group 1 Ordinary Driving Licence (ODL).
These changes do not apply to pilots with commercial licences or those displaying at airshows who will still need to be approved as fit to fly by a specialist aviation medical examiner.
The announcement is in line with the CAA’s top level principles for GA regulation:
Only regulate directly when necessary and do so proportionately
Deregulate where we can
Delegate where appropriate
Help create a vibrant and dynamic GA sector in the UK.