Three Pilot Mental Health (PMH) tragedies have caused the FAA to establish the 2015 the Mental Health and Aviation Medical Clearances Rulemaking Committee (precipitants: Malaysia Airlines flight MH370 and Germanwings flight 4U9525 incidents) (MHAMC ARC) and recently Mental Health & Aviation Medical Clearances Aviation Rulemaking Committee (Mental Health ARC). It is 169-page-long report outlines 24 recommendations and that action precipitated a number of articles about their work.
PMH is one of the most difficult issues facing aviation safety. The indicia of psychological risks in the minds in the cockpit are more nebulous than any other factor withing the FAA’s mission to protect the public. Some airworthiness questions can be answered with a micron meter and complex analyses, but the results are measured in precise, objective terms. Most physical health statuses are more susceptible to more reliable, objective prognoses. Not so with how a pilot’s psyche is working.
The Journal has published a number of insights about PMH over more than a decade. Most recently, these two papers highlighted the complexity of the PUBLIC POLICY, SAFETY, MENTAL HEALTH issues—especially how can a safety regulator can find a point of equipoise between concern for these professionals and the safety of their passengers:
#FAA #pilotmentalhealth—enough progress or deficient?? differing views- which sounds right to you? DIFFERING VIEWS ABOUT FAA MENTAL HEALTH POLICY – JDA Journal (jdasolutions.aero)
Aviation seeking prescriptions for #pilotmentalhealth; ; state of the debate and the views of one who has been working this issue for 25 years!!! FAA #ALPA–with contentious debate, a 25 year professional’s pilot mental health insights – jda journal (jdasolutions.aero)
The 2015 MHAMC ARC included a list of experts drawn from industry academia and other contributors based on their superior knowledge and variety of perspectives. Federal Air Surgeon Northrup added their recommendations in frequent posts and podcasts [just two of many examples] directed to the AMEs.
The 2024 ARC report was recently announced; it attracted a number of reports about this accomplishment (see below for 2 of them). No doubt that their collective knowledge of PMH and their astute Recommendations are impressive:
Create a non-punitive pathway for disclosing mental health conditions and treatments;
a) Revise and evaluate the requirements for REPORTING and certification/qualification of psychotherapy (talk therapy), depression/anxiety; attention deficit hyperactivity disorder, and post-traumatic stress disorder;
b) Ensure that aeromedical screening protocols and requirements are based on Safety Management System principles (i.e., proportionate, relevant, and risk-based), and appropriately communicated to applicants.
c) EXPAND THE USE AND PROMOTION OF PEER SUPPORT PROGRAMS.
d) Develop mental health literacy, education, and awareness campaigns;
e)Increase mental health training and improve quality assurance for Aviation Medical Examiners (AMEs);
and
f) Modernize the FAA’s information management system/Aviation Medical Certification Subsystem.
COMMENTS
- Items c, d and e enhance the 2015 suggestions. The last point (f) probably was on the Air Surgeon’s list of things needing upgrading.
- Items a and b are the gravamen of their new ideas. They are both intended to enhance the likelihood that pilots who have problems disclose their conditions. As a broad objective, no one can disagree. The Mental Health ARC’s report adds greater detail as to what this means; here are some quotes on their goal of making disclosure non-punitive:
p.35 “APPROACH: The FAA should amend the instructions on medical applications to EXCLUDE MENTAL HEALTH TALK THERAPY services as a required reportable medical professional visit. 67 While the three examples of the instructions in Appendix D differ on what is reportable, it should be noted that the Guide for Aviation Medical Examiners-Version 03/27/2024 does state “The applicant should list visits for counseling only if related to a personal substance abuse or psychiatric condition.” During a periodic health assessment, pilots/controllers should be ASKED BY THE AME ABOUT PERSONAL, SOCIAL, AND OCCUPATIONAL ISSUES to identify relevant mental health hazards. OBTAINING THIS INFORMATION, DIRECTLY FROM THE PILOT/CONTROLLER, INSTEAD OF A MENTAL HEALTH PROVIDER, WILL REDUCE THE BEHAVIOR OF NON-REPORTING AND INCREASE SAFETY. If the AME senses a mental health concern during the screening process, additional information will be requested.68
…p.36 “APPROACH: The FAA should create a process whereby pilots/controllers who currently hold a medical certificate/clearance ARE ENCOURAGED TO REPORT PREVIOUSLY UNDISCLOSED MENTAL HEALTH CONDITIONS, DIAGNOSES, AND/OR TREATMENT. The person should be able to disclose WITHOUT FEAR OF IMMEDIATE REVOCATION or referral for disciplinary or administrative/criminal prosecution for falsification, misrepresentation, or omission of information on the required disclosure documents. The non-revocation protections should extend to the medical certificate/clearance, as well as to any other certificates, ratings, clearances, or qualifications the person holds. This process should also allow pilots/controllers to MAINTAIN AEROMEDICAL CERTIFICATION/CLEARANCE, WITH APPROPRIATE RESTRICTIONS AS NEEDED, WHEN THE CONDITION/TREATMENT IS AEROMEDICALLY ACCEPTABLE, AND THERE IS EVIDENCE OF PRESENT ABILITY TO FUNCTION WELL. Any pathway developed would require a good faith effort by the certificate/clearance holder to provide all information required by the FAA to render a determination on the status of the medical clearance/certificate. To be eligible for this pathway, the certificate/clearance holder must disclose the information prior to the FAA discovering the withheld information through other means.
p.37 Caveats to the Guarantee of Non-Revocation and Non-Referral:
• the pilot/controller provides all medical and pharmacy records of treatment.
• the self-disclosure must be made before any FAA investigation. If the FAA discovers the undisclosed condition or treatment before self-disclosure, there is no guarantee of non-revocation or non-referral for prosecution; and
• IF A CURRENTLY DISQUALIFYING MEDICAL CONDITION IS IDENTIFIED, THE MEDICAL CERTIFICATE/CLEARANCE MAY BE REVOKED UNTIL THE PERSON MEETS THE CONDITIONS FOR MEDICAL CERTIFICATION OR SPECIAL ISSUANCE/SPECIAL CONDITIONS, but the person’s employment and the person’s non-medical certificates, clearances, ratings, or other qualifications should not be in jeopardy.
This approach incentivizes widespread self-disclosure while allowing the FAA to adequately assess the individual’s current medical status, and preserving the FAA’s authority to prosecute those who continue to conceal/falsify medical applications despite the opportunity to self-disclose with protection.”
COMMENTS
This macro guidance provides little specific measures of how the AME, or the FAA should allow the pilot to continue to fly.
- The ARC says WITHOUT FEAR OF IMMEDIATE REVOCATION. Does this language mean that if the ATP holder includes information about any mental health problem, the person charged with protecting the public’s safety MUST allow him or her [the ARC recognized that female pilots have higher rates of healthcare anxiety] to continue to fly.
- Elsewhere it is noted that the ATP should not be subject to “referral for disciplinary or administrative/criminal prosecution for falsification, misrepresentation, or omission of information on the required disclosure documents” p.36.
- The instruction at the 3d paragraph of page 37 does not suggest how disclosing a disqualifying condition can be “REVOKED” meets the earlier no fear principle.
- One of premises of the last quoted paragraph on page 37 seems to say that an ATP directly communicating “current medical status” to an AME will increase “self-disclosure’. The 3rd point on page 37 seems to suggest that a pilot may be taken off flight fit status.
There are necessarily AMBIGUITIES in assessing mental health. There is a continuum between an indisputable well pilot and one who should not be flying. There are shades of gray in the middle of this range. Determining where on this scale an individual’s PMH lies is heavily dependent on SUBJECTIVE JUDGMENT. Might it be that the MEDICAL RESEARCH on these gradations have not reached the level of precision which would GUARANTEE SAFETY or even define an ACCEPTABLE RISK?
Without greater certainty and/or clarity, pilots will not avail themselves of this option.
POSSIBLE ANSWER :Leave the definition of these points to the highly qualified Federal Air Surgeon?
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FAA should not requite pilots to disclose talk therapy, panel says
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FAA Committee Targets Pilot And Air Traffic Controller Mental Health Stigma
PUBLISHED 6 DAYS AGO
The latest committee was formed after an a jump-seating pilot attempted to shut down engines of an Embraer E175 mid-flight.
Photo: Welshboy2020 | Shutterstock
SUMMARY
- The latest FAA Mental Health and Aviation Medical Clearances Rulemaking Committee (ARC) was formed to address pressing pilot and controller mental health concerns.
- In 2015, the FAA formed the committee following the Malaysia Airlines flight MH370 and Germanwings flight 4U9525 incidents.
- The committee recommended SEVERAL IMPROVEMENTS to the way the industry deals with mental health issues.
The Federal Aviation Administration (FAA), which has formed a Mental Health and Aviation Medical Clearances Rulemaking Committee (ARC), is now reviewing the recommendations provided by the committee in order to improve the current mental health situation in the industry.
Breaking down barriers
The FAA’s statement noted that the latest iteration of the committee has provided recommendations to break down barriers preventing pilots and air traffic controllers from REPORTING THEIR MENTAL HEALTH ISSUES over their career concerns.
Photo : Chad Robertson Media | Shutterstock
The recommendations highlighted that the ARC members, observers, and contributors came from different backgrounds, including aerospace medicine, psychiatric and psychological medical experts from the FAA Office of Aerospace Medicine (AAM), FAA Flight Standards Service (AFS), the National Transportation Safety Board (NTSB), US aviation industry trade associations, pilot/controller representative organizations, academia, and international aviation industry associations and civil aviation authorities (CAAs).
The team is the latest initiative addressing the importance of disclosing mental health conditions.
Mental health stigmas
According to the ARC, the working groups addressed four main issues, including:
the FAA’s handling of mental health diagnoses,
current mental health screening processes,
barriers preventing pilots or controllers from reporting mental health issues, and
education about pilot/controller mental health issues.
The committee held three plenary meetings in the United States, with remote participants joining virtually.
The committee’s foreword noted that pilots have to obtain and maintain an FAA medical certificate to operate aircraft, with pilots working in commercial airlines being employed under the condition that they have their medical certificate. Similarly, controllers have to have an FAA medical clearance to continue their work.
Photo: ahmad.faizal | Shutterstock
The FAA had already formed an ARC committee in 2015 after the Malaysia Airlines flight MH370 and Germanwings flight 4U9525 incidents. While investigators could not establish a probable cause for the former’s deviation from its planned flight path, the French Bureau of Enquiry and Analysis for Civil Aviation Safety (Bureau d’Enquêtes et d’Analyses pour la sécurité de l’aviation civile, BEA) concluded that one of the causes of the latter accident was,
“[T]HE CO-PILOT’S PROBABLE FEAR OF LOSING HIS ABILITY TO FLY AS A PROFESSIONAL PILOT IF HE HAD REPORTED HIS DECREASE IN MEDICAL FITNESS TO AN AME[.]”
That committee concluded that one of the main factors why pilots or controllers could be discouraged from reporting about their mental health conditions is the stigma associated with mental health, the potential impact on one’s career, and the fear of financial hardship.
The final fate of the 239 occupants of MH370 remains shrouded in mystery.
Latest recommendations
While the 2015 COMMITTEE provided recommendations, and the FAA acted on them, including expanding coverage of mental health issues in TRAINING provided to AVIATION MEDICAL EXAMINERS (AME) and encouraging peer support programs (PSP) organized by airlines and unions, the regulator admitted that “there remained much work to do,” as highlighted by a Department of Transportation (DoT) report in July 2023.
“The [DoT Office of the Inspector General (OIG) – ed. note] report found that although the FAA has comprehensive procedures to evaluate pilots’ psychological health, THE FAA’S ABILITY TO MITIGATE SAFETY RISKS IS LIMITED BY PILOTS’ RELUCTANCE TO DISCLOSE MENTAL HEALTH CONDITIONS.”
The latest committee was formed after an Alaska Airlines pilot, who was seated in the jump seat of a Horizon Air Embraer E175, attempted to shut down the engines on a commercial flight between Seattle Paine Field International Airport (PAE) and San Francisco International Airport in October 2023.
Photo: Alaska Airlines
As such, the latest iteration of ARC provided seven recommendations for the FAA, including:
creating a non-punitive pathway for disclosing mental health problems,
revising and evaluating the requirements for reporting various mental health issues,
and
others.
The committee’s full report can be read here.
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