Response to Germanwings’ Pilot Mental Health issue—not more examinations, but constant management/peer awareness?

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The below-linked article is one of a myriad of sources suggesting that the regulators urgently need to respond to the Germanwings 9525 tragedy. They assert that it is necessary to escalate the frequency of trained health care professionals’ examination of the psychological status of the pilots flying in commercial service. This approach is neither ethical for doctors nor adequately time comprehensive over the career of all of the pilots.

There is an existing, useful model for effectively identifying people who may be mentally unfit for flying.

Mental health is not a still photograph; it is a movie with images of one’s stability changing over time and responding randomly to any number of catalysts. A psychiatrist can see a patient/pilot regularly at  specific intervals in time, as may be required by some tougher new regulation. [Note: this observation excludes the insight gained by a psychiatrist who is under long term care.] At that appointment, a determination can be made that (s)he is fine. Days or weeks thereafter the same individual’s ability to cope could be lost.

In one article, a knowledgeable doctor does not place much reliance on the likelihood that a pilot experiencing severe mental problems can or would report his/her problems. The Doctor also explains the ethical prohibitions of the examing psychiatrist  for contacting the authorities and violating doctor/patient confidentiality. Resorting to a finer psychological sieve to find problems does not appear to be the answer, if the subject pilot and/or the health expert are required to make such judgments.

As a matter of the Federal Aviation Regulations, 14 CFR §117.3, “Fitness for Duty”, imposes a duty of each cockpit member as follows:

Fit for duty means physiologically and mentally prepared and capable of performing assigned duties at the highest degree of safety.

Later in 14 CFR §117.5 adds the following details

(a) Each flightcrew member must report for any flight duty period rested and prepared to perform his or her assigned duties.

(b) No certificate holder may assign and no flightcrew member may accept assignment to a flight duty period if the flightcrew member has reported for a flight duty period too fatigued to safely perform his or her assigned duties.

(c) No certificate holder may permit a flightcrew member to continue a flight duty period if the flightcrew member has reported him or herself too fatigued to continue the assigned flight duty period.

(d) As part of the dispatch or flight release, as applicable, each flightcrew member must affirmatively state he or she is fit for duty prior to commencing flight.

AC 117-3, issued 10/11/2012, adds a lot of detail about what constitutes “fit for duty”. These rules already create a self-report obligation on an airman.

It can be correctly asserted  that the existing system for detecting mental illness works. However,  there is every reason why the FAA should work with the psychological experts to develop symptoms of seriously deteriorating mental health.

The new Part 117 recognizes that the likelihood is low that an individual will declare that (s)he is unfit as to fatigue. The FAA’s solution in that recent final rule was to expand the band of people who have responsibility assessing whether a cockpit crew member is tired or not. Fellow pilots and management are expected to be part of a network to identify specific behaviors which are symptoms of fatigue. The new scientifically based approach includes a fatigue risk management system (§117.7) and a fatigue education and awareness training program (§117.9). That appears to be a better way to identify individuals who may be too tired to assume duties in the cockpit.

In response to the Germanwings 9525 crash, the regulators should use the model of the development of Part 117’s surveillance of fatigue. Aviation safety should never be deterred because past practices are good, when something new will be better. (The “If it ain’t broke…” aphorism should not guide aviation safety policy.) As with the new approach to detecting tired crewmembers, profiles of behaviors and intervention strategies can be developed and disseminated among the pilots and management.

Having a network beyond the pilot, having more knowledgeable disseminated among management and co-workers and having a system which can detect problems at all times (not just at an examination), flying will be safer.

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