On 24 March 2015, SIC Andreas Lubitz of Germanwings Flight 9525, deliberately flew an Airbus A320-200 into a mountain side near Prads-Haute-Bléone, Alpes-de-Haute-Provence. All 144 passengers and six crew members were killed. In response to that tragedy the European Aviation Safety Agency convened a Task Force to determine how this tragedy would not reoccur. Much to its credit EASA issued an Action Plan (version 1) on October 7, 2015.
The primary findings are as follows:
- “The Task Force recommends that the 2-persons-in-the-cockpit recommendation is maintained. Its benefits should be evaluated after one year. Operators should introduce appropriate supplemental measures including training for crew to ensure any associated risks are mitigated.
- The Task Force recommends that all airline pilots should undergo psychological evaluation as part of training or before entering service. The airline shall verify that a satisfactory evaluation has been carried out. The psychological part of the initial and recurrent aeromedical assessment and the related training for aero-medical examiners should be strengthened. EASA will prepare guidance material for this purpose.
- The Task Force recommends to mandate drugs and alcohol testing as part of a random programme of testing by the operator and at least in the following cases: initial Class 1 medical assessment or when employed by an airline, post-incident/accident, with due cause, and as part of follow-up after a positive test result.
- The Task Force recommends the establishment of robust oversight programme over the performance of aero-medical examiners including the practical application of their knowledge. In addition, national authorities should strengthen the psychological and communication aspects of aero-medical examiners training and practice. Networks of aero-medical examiners should be created to foster peer support.
- The Task Force recommends that national regulations ensure that an appropriate balance is found between patient confidentiality and the protection of public safety. The Task Force recommends the creation of a European aeromedical data repository as a first step to facilitate the sharing of aeromedical information and tackle the issue of pilot non-declaration. EASA will lead the project to deliver the necessary software tool.
- The Task Force recommends the implementation of pilot support and reporting systems, linked to the employer Safety Management System within the framework of a non-punitive work environment and without compromising Just Culture principles. Requirements should be adapted to different organisation sizes and maturity levels, and provide provisions that take into account the range of work arrangements and contract types.” [emphasis added]
EASA will implement the first three work packages (air operations, aircrew and IT). The actions related to data protection go beyond EASA’s competencies, since they require national regulations/ statutes. The legislative determinations will be faced with “ensuring balance between patient confidentiality and the protection of public safety.”
The below table shows action items for EASA (blue) and for the individual nations (gray) which are part of the EU:
The “two pilots in the cockpit” practice has been either an airline rule or a CAA requirement. The promulgation of mandatory rules should be swift.
The closer surveillance of AMEs is also not particularly controversial proposal, but the specific diagnostic tools for these medical professionals to assess the state of mind of pilots likely will attract a lot of attention.
Similarly, the continuous attention by management, pilots and CAAS devoted to the mental well-being of all cockpit members will delve into areas which will make those involved uncomfortable, at best and some feel incapable of such an invasion of a peer.
The Continent’s various legislative bodies value highly personal rights. Consequently, the substance of this Action Plan may not transition to a practical reality soon:
- The implementation of the initial and reoccurring mental evaluation assessments will likely find resistance in each home country.
- Even though the FAA has had a robust and aggressive alcohol and drug program for all aviation safety professionals for a number of years, Europe has resisted for many years any testing. [That difference has been a major cause célèbre for US unions in the FRS context.] Did the Germanwings horror so alter that opposition that this EASA recommendation will be implemented?
- EASA recognized that a multi-national aeromedical data base might be negatively received. That may be an understatement.
Thus, the EASA timetable might be a little optimistic.
The Report outlines work projects to expand these one line recommendations into full packages. The global Aircrew Medical Fitness workshop will be called to develop more substance for each of the six points. The workshop will take place before the end of 2015, grouping a large audience of European and worldwide stakeholders. Representatives from at least the following organizations will be invited:
- International Air Transport Association,
- International Federation of Airline Pilots Association,
- European Cockpit Association,
- European Transport Workers’ Federation,
- International Air Carrier Association,
- European Low Fares Airline Association,
- National Aviation Authorities,
- European Commercial Aviation Safety Team,
- aero-medical examiners,
- medical experts providing training and aero-medical assessors,
- European Society of Aerospace Medicine,
- Pompidou Group from the Council of Europe (Co-operation Group to Combat Drug Abuse and Illicit Trafficking in Drugs),
- European Workplace Drug Testing Society,
- FAA , and
- CAA Australia.
As a result of these deliberations, EASA expects that concept papers will be written, further consultations will be held with the affected workers and Operational Directives will be produced. Once all of these actions are completed, EASA will follow up to determine the effectiveness of the resulting implementation. The applicable means of compliance (AMCs), Guidance Material (GM) and the use of the European aeromedical data repository will be subject to further EASA-NAA discussions.
The European Aviation Safety Agency should be commended for expediting its response to Flight 9525, but the ultimate test will be the record of converting recommendations into effective requirements throughout Europe.