FAA request for Pilot Medical Records may harm effort to find Mental Health Solutions

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The Germanwings 9525 suicide flight has raised the question of pilots’ mental health and there is no doubt that assessing the psychology of a captain or second-in-command is very hard to determine. There are now two related tasks established by the FAA to find solutions.

The first is the Pilot Fitness Aviation Rulemaking Committee (PFARC) was established by the FAA to “examine issues including the awareness and reporting of emotional and mental health issues, the methods used to evaluate pilot emotional and mental health, and barriers to reporting such issues.” It will be composed of “U.S. and international government and industry aviation experts, including a working group of medical professionals who specialize in aerospace medicine.” Presumably one or more of the ARC members will include the unions which represent airlines.

The charter defines this federally chartered advisory committee is charged with doing. Their agenda includes analysis of the available data, review of the public’s and the aviation community’s awareness of mental illness, inventory the methods of determining mental health, identify methods of self-reporting and appropriate actions after such a report, catalogue barriers to self-reporting, call out the gaps in coverages and then find approaches to closing the gaps—medical methods, aircraft design mitigation, training/testing, union/airline professional standards and AME training.

It is expected that the PFARC might result in the FAA’s adopting “changes to medical methods, aircraft design, policies and procedures, pilot training and testing, training for Aerospace Medical Examiners, or potential actions that may be taken by professional, airline, or union groups.” Their timeline is to provide a full report by the end of the year.

This is a delicate subject. Unions have historically zealously guarded the privacy rights of their members. Past efforts by governments to add restrictions to pilots have not been welcomed by their unions. The Associate Administrator for Aviation Safety and other FAA participants will have to show considerable deference to the labor concerns. They will also have to establish a strong correlation between the additional pilot requirements/scrutiny and safety increase.

The second action was announced by the FAA Office of Aerospace Medicine (AAM) and there was no explicit link to the work of PFARC. The initiative was described as “a market survey for a major update to its aeromedical technology infrastructure called the Aerospace Medicine Safety Information System (AMSIS).” AAM, in the very recent past, has exhibited a tendency to assert medial goals over a reverence of procedural niceties. The data to which AAM seeks access would be used “to develop a new information system for tracking and analyzing a broad selection of medical information associated with pilots, air traffic controllers and other aviation-related personnel.”  That sounds like the macro analysis of the numbers for which the unions might have little worry.

The AAM’s statement of its needs for the survey included

  • Reducing falsification of health records and preventing pilots or ATCSs (air traffic control specialists) from operating in the [National Airspace System] when they have medical conditions hazardous to aviation safety;
  • Improving the ability to analyze medical data and identify and mitigate hazards related to specific and/or systemic airmen and ATCS health issues;
  • Improving the ability to match airmen and ATCS medical records with the electronic health records of other government agencies and departments;
  • Ensuring the accuracy and integrity of airmen and ATCS medical data;
  • Leveraging the National Health Information Network (NHIN), Health Information Exchange (HIE) system medical records, and ad hoc, regional and multi-regional HIEs, to improve the accuracy of airmen and ATCS medical data; and
  • Improving the surveillance and oversight of designees and aviation industry substance-abuse programs.

Those words are far more likely to cause concern about the potential of micro use of the data. Falsification, matching, accuracy, integrity and the other words all indicate intent to use specific data in efforts to take actions against individual airmen.

Analytically, the accumulation of this data could create basis to avoid serious safety problems. The general public would likely support such an initiative. However, as an early announcement (even if not directly related to the PFARC), AAM’s AMSIS request is likely to create considerable doubt among the union members of the federally chartered group.

Process is an overused word, but this may be an instance in which delaying the request might have enhanced the chances of good karma in the ARC proceedings FIRST. It is quite possible that in the course of the discussions, review of options might have convinced the union members that some or all of the Amsis data could be very relevant to their tasks. Presenting it as a fait accompli and placing the control in the hands of AAM alone are likely to create an early sense of distrust.

ARTICLE: FAA Wants More Access to Airman Health Records

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