The issue of cockpit crew mental health is complex and controversial. The recent tragedy, in which a co-pilot appears to have intentionally flew his plane into a mountain, has precipitated strong recommendations. That EASA report may result in significant changes in how pilots are screened for employment and how their health is monitored. The regulatory regime will likely engender considerable debate about intrusion on these professionals’ privacy and the efficacy of the new mental health methods.
The probable cause of the Germanwings Flight 9525 horrible accident has not yet been announced by the Bureau d’Enquêtes et d’Analyses (BEA), but the European Transport Commissioner Ms. Violeta Bulc tasked EASA to review the BEA preliminary findings and to issue recommendations on how to avoid a reoccurrence of this tragedy. The aviation safety agency’s Executive Director Patrick Ky, the Task Force consisted of 14 senior representatives from airlines, flight crew associations, medical advisors and authorities. Their report focused on Co-pilot Andreas Lubitz’s mental issues and made 6 recommendations.
Recommendation 1— that two pilots must always occupy the cockpit. That’s not too surprising, but will this requirement mean that there need be a third pilot to cover when one of the cockpit crew needs to exit?
Recommendation 2— that the airline, not the CAA, verify that a prospective pilot has successfully been evaluated psychologically. The report notes that additional guidance for this “test” will be provided. A mental health examination measures the patient’s mental health at the time of examination. While fissures in the pilot’s stability may be detected, future capacity to handle stress varies over time. EASA covers that phenomenon with “recurrent” examinations. “How often, how thorough, what cause(s) may trigger an unscheduled test?” are all unanswered, important questions which may influence the unions reactions.
Recommendation 3— EASA, some six years after the FAA issued its Part 120, now will consider requiring random Drug and Alcohol testing of pilots (no mention of other safety related positions). It will be interesting to see if the European pilot unions will oppose this and if the testing is extended to other aviation safety professionals.
Recommendation 4— a more robust oversight of aero-medical examiners’ performance will be imposed. The CAAs 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.”
Recommendation 5— EASA recommends that the EU nations issue regulations which create “an appropriate balance is found between patient confidentiality and the protection of public safety.” Europe has a very long tradition of protecting individual privacy; the balance between safety regulatory access to these records and the rights of pilots may be difficult to attain.
Plus— the report request that a European aero-medical data repository should be established as a first step to facilitate the sharing of aero-medical information and tackle the issue of pilot non-declaration. This appears to be a very useful tool, fraught with legal questions. The FAA is facing similar issues.
Recommendation 6— EASA envisions that Safety Management System should be extended to individual pilots. The thought is that the just safety culture and non-punitive principles of SMS could be conducive to pilot support and reporting (like ASAP?). The trust between regulated and the regulator must be VERY high in order for a pilot to submit information about his/her mental health. Perhaps equally important as a detection mechanism for mental health problems, professional peers should be trained to identify behavioral “tics.”
The EASA report is clearly the work product of an excellent team of experts and its recommendations must be carefully considered in Europe, the US and around the world. Ultimately airline safety mandates that these human factors be incorporated in the regulatory regime and/or the airline safety culture.