It would appear that the UK Civil Aviation Authority (CAA) is concerned that self-assessed Pilot Medical Declarations (PMDs) are being misused by a small number of pilots who would have likely otherwise been declared unfit to fly by aeromedical examiners and as a result the Authority is considering enacting changes to tighten up the system.
The PMD has been around since October 2016 and is an extremely popular route used by private pilots to confirm medical fitness, given that it is the least restrictive form of aviation medical which doesn’t require an aeromedical examination and is cost-free. The PMD system allows private pilots who only want to fly UK registered aircraft in UK airspace to self-declare their medical fitness to fly, subject to certain operational conditions and limitations. Pilots may use the PMD system if they believe they meet the medical requirements for a Group 1 (car) licence issued by the Driver and Vehicle Licensing Agency. As the PMD is not recognised by the International Civil Aviation Organisation (ICAO) it cannot be used by commercial pilots and isn’t automatically recognised outside of the UK.
Prior to the introduction of the PMD, private pilots had to hold ICAO-compliant medicals (Class 1 or Class 2 medicals), which required a higher level of medical fitness and included periodic medical checks with registered aeromedical examiners. With the introduction of the PMD, private pilots can now medically self-certify on the basis that if they are medically fit enough to be permitted to drive a car then they are also fit enough to pilot an aircraft.
According to the CAA, more than 14,000 British pilots now use the PMD system, making it the most popular medical held by private pilots. In October 2020 the CAA commenced a post-implementation review of the PMD system and to date they have reviewed a sample of 800 holders, made up of 400 pilots who previously had a medical status of unfit or had a medical referred, and another 400 pilots who had no previous unfit or referred status. The CAA reports that it has found that four percent of the 800 PMD holders reviewed should not be self-declaring for various reasons and state that if this percentage is representative of all PMD holders then the number made in error is of concern. The CAA confirmed that issues identified included disqualifying heart conditions, neurological conditions and drug/ alcohol misuse, adding that it isn’t clear whether this is due to unclear guidance material or a misunderstanding on the pilot’s part.
The CAA reports that it has found that four percent of the 800 PMD holders reviewed should not be self-declaring for various reasons
The CAA has now published a public consultation of the PMD system, which opened on 24 October 2022 and closes on 05 December 2022. The consultation was enacted following responses received during an earlier consultation held in November 2020, looking at General Aviation (GA) regulatory change opportunities post-Brexit, including the current review of GA pilot licensing reported elsewhere in this edition.
Following its findings on misused PMDs, the CAA is using this consultation to revisit the questions originally asked as part of the consultation prior to the launch of PMD, with responses to the new consultation to be used to provide guidance for the future development of the PMD system.
The PMD appears to have the support of many within the aviation medical community. A senior aviation medical expert told FTN that he welcomed the review as a means of validating its utility.
He told us: “I am a great supporter of the PMD concept. It is a pragmatic interpretation of risk/benefit, and I am not aware of an accident caused by medical incapacitation of a PMD holder. When considering the risk of pilot incapacitation whilst flying a light aircraft, out of the 8,760 hours in a year, the pilot is airborne for an insignificant percentage of that time and is much more likely to collapse when not flying. The DVLA uses similar logic in assessing fitness to drive.”
“A review of how the PMD system is working is timely, if only to review the data to show no increased risk of accidents caused by incapacitation of pilots who have made a PMD, compared with Class 2 medical certificate holders.”
“In practice, I don’t think there are major failings with the system and in terms of risk/benefit and public safety, I believe it is a sound concept.”
The consultation is published under CAP 2408 and can be accessed via the CAA’s Consultation Hub at www.consultations.caa.co.uk
