The UK CAA has launched the second phase of its public consultation on the use of self-assessed pilot medical declarations (PMD) for private pilots, following concerns that a small number of pilots who might otherwise been declared unfit to fly had abused 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 (DVLA). 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, reviewing 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 reported that it has found that four percent of the 800 PMD holders reviewed should not be self-declaring for various reasons and said 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 wasn’t clear whether this was due to unclear guidance material or a misunderstanding on the pilot’s part.
Having launched an initial consultation in October 2022, which was enacted following responses received during an earlier consultation held in November 2020, looking at General Aviation (GA) regulatory change opportunities post-Brexit, the CAA is now moving onto the second phase of its consultation having now come up with some proposals to modify the PMD process and privileges.
Among the proposals open for consultation on are:
· A 2,000kg max aircraft weight for PMD holders, removing the previous 2,000-5,700kg aircraft category.
· Renewal cycles for PMD holders – five years for those under the age of 60 and two years for those over the age of 60.
· A physical certificate, including expiry form, with educational material given out as part of the issue and renewal process.
· Must hold a current driving licence or able to get a GP declaration stating able meet requirements for holding one.
· Allowing Sailplane Licence and Balloon Pilot Licence pilots to use a PMD for supervised solo flights.
· Removing psychiatric medication aspect for those who fly aircraft with maximum take-off weight up to 2,000kg.
· Continuing to permit microlight and autogyro aircraft instructors to continue to train with a PMD.
· Questioning whether cost-sharing flight with up to three passengers can continue for pilots holding a PMD.
· Other passenger restriction opinions.
· Permitting Instrument Rating Restricted (IRR) flight privileges to pilot using a PMD.
Commenting on the proposed changes, Michael Macdonald, Co-Head of General Aviation & RPAS at the UK Civil Aviation Authority, said: “We are committed to ensuring that the Pilot Medical Declaration scheme is effective and fit for general aviation pilots.
“The proposed changes represent some moderate measures to update the way pilots self-declare their fitness. We continue to support PMD as a useful and proportionate tool to enable pilots in their flying.”
This second consultation is published under CAP 2604 and can be accessed via the CAA’s Consultation Hub.
