LAPL MEDICAL – EASA INTENDS TO KILL THE MEDICAL DECLARATION

 

 

You may know that EASA are proposing to establish a Light Aircraft Pilots Licence modelled on the UK NPPL and including a medical that was to be a declaration much like the current UK system that benefits so many of us.  Originally EASA proposed that the declaration could either be oversigned either by a GP who had access to the applicant’s medical records or who has aeromedical training (essentially an AME) in those states that do not have a GP system like the UK’s.  That would be much as we have today.

However, following the consultation, EASA have revised the rule to change the “or” to “and” so throughout the EU the declaration can only be signed by a person who is a GP who has access to your medical records and who has aeromedical training.  So unless your personal GP happens to be an AME, the LAPL medical can never be issued.  Catch 22.  Moreover, the declaration to be signed after reviewing the applicant’s medical records now requires a medical examination and the completion of a medical certificate certifying the application if fit to fly an aircraft.  Clearly no GP would ever qualify to do that or be likely to sign such a document so this puts us back to a medical examination by an AME.  Apart from anything else, there are not enough AMEs in the UK to examine the 15,000 pilots (including 7,000 glider pilots) who could no longer use a GP medical declaration.

The EU rule making process allows us to express views on the Comment Response Document (CRD) which contains the rule it is proposed to put into law.  This must be done using the Comment Response Tool by the deadline of 23 August.  Not long then.

If you want to help us (and we do need help) to rescue this valuable medical system that will enable us to fly safely on the LAPL without undergoing the rigour and cost of an examination by an AME, please send your view to EASA by next Monday.

The new proposed rule is here.  Scroll down to NPA 2008-17c and look at Part Med.  You can see the killer changes from the original by clicking on Subpart D GMPs.  You can see the inflated requirement for examination by scrolling to the bottom of the EASA documents where hidden under “information” is the LAPL examination form and medical certificate

The comment response tool is here.  You will need to register and having done so you can log in and then find the NPA by clicking on “View Documents” and then looking for “NPA 2008 17c” in the number column.  It will be on page 4 or thereabouts.  This will give you a copy of the title page on the left and a freeform page on the right where you can write your views.  You cannot scroll through the documents in that view as only the title page is shown – if you need to open the document, do so in a new window from the link above.

Using your own words and ideas, please tell EASA what you think.  Here are some themes:

The amended rule would exclude your GMP from issuing a LAPL medical certificate as he/she is not trained in aviation medicine. 
No GMPs are trained in aviation medicine unless they are AMEs
That to make this rule work for GMPs in the UK, every one of them would need aviation medical training – there are about 36,000 doctors in general practice in the UK.
This appears to be protectionism by the AME sector and protectionism is contrary to EU law.
It is disproportionate, contrary to EU law.
The medical declaration is entirely satisfactory and has been shown to be safe.
EASA presents no evidence that the declaration by an ordinary GMP is unsafe.
An examination by an AME is unnecessary.
The additional examination load on AMEs would not be manageable resulting in pilots being grounded.

Please do not just copy these words or we will be ignored.  Tell EASA what You think of this but you may want to finish by saying that you support the detailed comments sent by the British Gliding Association on behalf of many UK pilots.

Note that the UK NPPL and perhaps the UK PPL should continue into the future with the current medical declaration but the EASA LAPL will need a medical by an AME unless this is changed now.

Thanks for your help

 

John Brady
LAA