Primarily for general aviation discussion, but other aviation topics are also welcome.
By riverrock
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#1839395
nickwilcock wrote:The PMD has now drifted so far from its originally intended purpose that safety issues perhaps need to be discussed.

Can you provide some numbers?
What quantity is the additional risk? Why would
getting a medicall change the risk level to occupants in IMC in an aircraft that may be less stress / more stable to fly than some smaller lighter aircraft? Does risk change the number of hours you are in the air?

Is flying quantifiably more medically risky then driving, and does a Class 2 reduce that risk?
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By flybymike
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#1839401
nickwilcock wrote:
The PMD has now drifted so far from its originally intended purpose that safety issues perhaps need to be discussed.


Nick can you provide us with details of numbers of accidents, fatalities etc which have been linked to medical incapacitation since the PMD introduction 5 years ago, and how these might have been avoided had a full medical been held?

The whole problem with the NPPL GP self declaration was that large numbers of GPs were not inclined to countersign them either because they were too busy, did not understand what they were being asked to sign or take responsibility for, thought that they were authorising pilots to fly a 747 internationally, thought that they might be held responsible for any medical eventualities to which they had leant their name, or were otherwise not willing or too apprehensive to do so.
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By Flyin'Dutch'
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#1839408
@flybymike

Indeed, however it is smart to look at it, because it takes no brain power to understand that should such an incident occur it will cause a major review and probably scaling back of the whole PMD provision.

The major beneficiaries of PMD are pilots of gliders and small SEPs - as we saw from the uproar by those affected when the sub 2000kg category was lost (hopefully pro team only).

There are times when we need to be smart and apply some foresight.

The general public, and therefore politicians/rule makers are not particularly interested when we kill ourselves, involve innocent non-participants or passengers and that emotion changes very quickly.
Last edited by Flyin'Dutch' on Sat Apr 10, 2021 8:15 pm, edited 1 time in total.
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By gaznav
#1839437
@Flyin'Dutch'

I agree, but I believe that the “risk based” approach has already been used to assure the roll out of PMDs?

I tend to look at it this way with risk in mind. The normal UK driving medical standards allow me to drive a vevicle up to 3,500kg MAM with up to 8 passenger seats (with a trailer up to 750kg). Should I have a medical episode, then I am far more likely to cause death and serious injury to a 3rd Party than a light aircraft operating to a similar declared medical standard. That is due to the fact that most roads concentrate 3rd party individuals either on that road, or very adjacent to it, so the likelihood of causing 3rd party injury is higher due to the concentration of the driving activity.

However, I fear that you are right, that the first medical episode that causes a PMD Pilot to have an accident will immediately cause a disproportionate response. Why do I say disproportionate? I can look back a lots of accidents where Pilots with Class 1 and Class 2 medicals that have had medical episodes that have caused fatalities. I lost a friend in the last couple of years who had an undetected heart condition that likely led to their death and their student. There is also, always the spectre of someone with a Class 1, Class 2 or LAPL medical going flying with a known medical issue that has developed after the last medical examination anyway?

So, I agree with you, that this should be revisited, but also kept in perspective as it was originally under Tony Rapson’s tenure (this was probably the best thing he did for GA). But I do think there are some tweaks to be made (see later my suggestion of a printable PMD certificate), with a formal statement of the risk based analysis.

If I take my own example. I don’t fly Part-21 (ex EASA) aircraft, I don’t need to fly to IR privileges and I don’t fly GA outside the UK. My job gives me a medical check frequently (the last one in June last year) and I have to conduct an annual fitness test (shuttle runs, sit ups and press ups) to achieve a VO2 max of greater than 38. I have no medical history of interest and no hereditary illnesses of interest. So from a risk based perspective I am 100% content to sign a declaration that I believe that I am fit to fly a civil GA aircraft. Other than the off chance of a civvy AME finding an issue with me, because it would increase the frequency of personal medical examination over that of the Class 1, what else would it bring? Apart from seeing me part with the best part of £200 for the privilege! :D

So, I believe that the PMD is a good thing. I believe that the only improvement would be to produce some sort of certificate of declared conformity, as it is a little un-nerving to not have any demonstrable evidence to show that you have made the PMD - I carry a screenshot of my application, but it looks a bit pants.

Best, Gaz :thumleft:
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By Flyin'Dutch'
FLYER Club Member  FLYER Club Member
#1839449
gaznav wrote:@Flyin'Dutch'

I agree, but I believe that the “risk based” approach has already been used to assure the roll out of PMDs?

I tend to look at it this way with risk in mind. The normal UK driving medical standards allow me to drive a vevicle up to 3,500kg MAM with up to 8 passenger seats (with a trailer up to 750kg). Should I have a medical episode, then I am far more likely to cause death and serious injury to a 3rd Party than a light aircraft operating to a similar declared medical standard. That is due to the fact that most roads concentrate 3rd party individuals either on that road, or very adjacent to it, so the likelihood of causing 3rd party injury is higher due to the concentration of the driving activity.

However, I fear that you are right, that the first medical episode that causes a PMD Pilot to have an accident will immediately cause a disproportionate response. Why do I say disproportionate? I can look back a lots of accidents where Pilots with Class 1 and Class 2 medicals that have had medical episodes that have caused fatalities. I lost a friend in the last couple of years who had an undetected heart condition that likely led to their death and their student. There is also, always the spectre of someone with a Class 1, Class 2 or LAPL medical going flying with a known medical issue that has developed after the last medical examination anyway?

So, I agree with you, that this should be revisited, but also kept in perspective as it was originally under Tony Rapson’s tenure (this was probably the best thing he did for GA). But I do think there are some tweaks to be made (see later my suggestion of a printable PMD certificate), with a formal statement of the risk based analysis.

If I take my own example. I don’t fly Part-21 (ex EASA) aircraft, I don’t need to fly to IR privileges and I don’t fly GA outside the UK. My job gives me a medical check frequently (the last one in June last year) and I have to conduct an annual fitness test (shuttle runs, sit ups and press ups) to achieve a VO2 max of greater than 38. I have no medical history of interest and no hereditary illnesses of interest. So from a risk based perspective I am 100% content to sign a declaration that I believe that I am fit to fly a civil GA aircraft. Other than the off chance of a civvy AME finding an issue with me, because it would increase the frequency of personal medical examination over that of the Class 1, what else would it bring? Apart from seeing me part with the best part of £200 for the privilege! :D

So, I believe that the PMD is a good thing. I believe that the only improvement would be to produce some sort of certificate of declared conformity, as it is a little un-nerving to not have any demonstrable evidence to show that you have made the PMD - I carry a screenshot of my application, but it looks a bit pants.

Best, Gaz :thumleft:


Your analogy with driving goes wrong in that the passengers in a minivan are way better protected than those in a light aircraft and that the chance where cyclists and pedestrians are likely to get injured by an errant minivan are small as we have seen from accidents whereby even in the unfortunate event of an incapacitated bus or truck driver the number of unfortunate casualties is low.
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By MattL
#1839458
[not intended to be provocative honestly!] but asking AMEs to promote/recommend the PMD regime would be like asking FEs to recommend a self assessment flight test system. Any review should include a cross section of subject matter experts to remove any unconscious bias.
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By flybymike
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#1839460
I carry a screenshot of my application, but it looks a bit pants.


The CAA send an email acknowledgement of the declaration.
I printed it off and keep it with my licence.

(And of course, DVLA do not require you to carry any medical documentation either. :wink: )
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By gaznav
#1839479
@flybymike

Yes, that was kind of what I meant. It’s a PDF screenshot that you get back. 5 pages long. It doesn’t print out into a neat certificate, like a med certificate. So I have a 5-pager that looks like this stapled together. It could be better in my opinion :thumleft:
Image

@MattL yes, good point, although I trust Frank’s opinion on this as he is semi-retired anyway. So business considerations are unlikely to be a factor.

@Flyin'Dutch' I agree that passengers will be protected better in some accident scenarios. But a 3.5T lorry with a 0.75T trailer is going to make an awful mess regardless of the number of airbags, crumple zones and safety restraints that you have. Flat as a pancake comes to mind! [pun intended]

Best, Gaz
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By Flyin'Dutch'
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#1839506
MattL wrote:[not intended to be provocative honestly!] but asking AMEs to promote/recommend the PMD regime would be like asking FEs to recommend a self assessment flight test system. Any review should include a cross section of subject matter experts to remove any unconscious bias.


Maybe for some AMEs but this one was working at the CAA when the LAPL came in and went to GP conferences to promote the issue of LAPLs by GPs, has been the advisor to the two largest representative bodies in GA and medical advisor to them as well as for some time AOPA speaking to what felt like a gazillion GPs as to why they could sign off NPPL medical declarations and who has a regularly full email inbox with queries from LAA/BGA members.

So your suggestion is bollox.

Some people have professional and personal integrity.
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By MattL
#1839513
@Flyin'Dutch' I specifically said I wasn’t being provocative.

My point is that I hope any review is done holistically with the full range of industry views and analysis taken into account. This can build on the amazing work and data set done in the U.K. on PMDs to date. I would be amazed if a group of clinicians was not in any little way subconsciously biased to preferring clinical checks and tests for medical certification rather than self declaration. I’ve frequently read on here that it has been the AME lobby across Europe that has blocked EASA relaxation of private pilot medical standards or is that not correct?
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By Flyin'Dutch'
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#1839543
MattL wrote:@Flyin'Dutch' I specifically said I wasn’t being provocative.

My point is that I hope any review is done holistically with the full range of industry views and analysis taken into account. This can build on the amazing work and data set done in the U.K. on PMDs to date. I would be amazed if a group of clinicians was not in any little way subconsciously biased to preferring clinical checks and tests for medical certification rather than self declaration. I’ve frequently read on here that it has been the AME lobby across Europe that has blocked EASA relaxation of private pilot medical standards or is that not correct?


Writing that you dont want to be provocative and then launching into a provocative post about AMEs protecting their work by being against relaxation of rules is the same as stating not wanting to be rude to then just launching into a rude tirade.

There is no lobby against relaxation of rules; what there is that there are some people in regulatory places, not in the UK CAA Medical department (where the PMD and flying for pilots with insulin dependent diabetes for all classes emanated from) nor EASA are against a liberalisation of the regulations of aeromedical rules.

There may be some in places in some NAAs who are concerned of a change to rules because the human conditions doesn't like change, but there is less opposition than might be suspected amongst Internet dwellers.

Going on what is posted on internet forums, change resistance is pretty rife amongst pilots themselves.

The PMD and previously the GP signed declaration found favour in EASA towers and I can obviously not guarantee but was pretty sure that if it had not been for B****t it would have found wider adoption in EASA land just as the UK was the first EASA NAA to allow insulin dependent diabetics to fly across the world followed by Ireland and Austria. It has to start somewhere.

With the UK place at the EASA table gone I am pretty sure this is not going to happen now for much longer; the UK CAA is both in size and scientific power a lot larger than most of the other NAAs.

The FAI is working on promoting the further relaxation of medical regulations at the ICAO table but this is a slower process, they still have some UK experience on board and we have used the extensive UK experience to make the case. BTW the medical expert group of both that and EASA are without fail all AMEs or medical assessors. Most NAAs require those people to be pilots either active or at least have been.
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By Flyin'Dutch'
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#1839606
MattL wrote:What’s your view on the PMD out of interest?


Who? Me?

Bloody brilliant.

For small GA, gliders, SEPs, basically for everything you can do with a LAPL but then over the whole globe.

I don't see any particular problem with it being valid for night/IR flying either although I also don't see it would liberated a lot of GA pilots with that extension either.
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