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Current status of medical concessions

Despite the work done on the EIR and the CB IR, and other stuff, what is called Part MED has not really changed. I think it just escaped everybody’s attention, or maybe the AME bodies are just too powerful (having recently spoken to a CAA AME, I think both are true).

So what do we have that has changed for the better?

During JAR-FCL, there was no way to get an IR if you failed the audiogram in one ear. Many went N-reg for this reason. There was a route, in the UK, via an ICAO CPL or ATPL, described here which ended c. 2007 but continued “quietly” for some years after that. It may still be available, and I think on balance it is better to mention it than to keep quiet about it. No AME is likely to know about this, and the only way to find out is to phone the CAA.

During JAR-FCL, there was a way to get an IR if you failed the CV test. Your IR was limited to day only, and I really know one chap who got this, maybe 5-8 years ago. It was not advertised, of course, and almost no AME knew about it.

I have recently heard that Part Med contains a clause stating that each case “must be considered on its own merits”, and apparently this finally makes it possible to get an IR without the two-ear audiogram pass. You need to get an annual audiogram, to make sure the ear which has passed is not getting worse.

Can anyone think of other useful concessions?

Administrator
Shoreham EGKA, United Kingdom

Arguably just to waive any medical whatsoever for pilots flying single-seaters and/or without passengers and outside controlled airspace.

Last Edited by kwlf at 07 May 11:37

Which is exactly what the French ultralight license does.
Actually, it even allows flying a two-seater.

EBZH Kiewit, Belgium

I have recently heard that Part Med contains a clause stating that each case “must be considered on its own merits”, and apparently this finally makes it possible to get an IR without the two-ear audiogram pass. You need to get an annual audiogram, to make sure the ear which has passed is not getting worse.

I think this sensible approach has worked for years. My left ear is slightly below the limit. When living in Holland I needed to do a check flight with an examiner. He made sure my headset was on a normal volume level and see whether I could understand everything. And also without a headset.. (a bit of a challenge, even for people with good ears no doubt!). When I moved to Spain, and moved my Medical with it, after the failing audiogram they made me go to an otolaryngologist who tested me by standing a few meters behind me and tested my ears by making me repeat his whispering. Annual audiogram.

Private field, Mallorca, Spain

It was categorically not possible 10 years ago, in the UK.

It may have been possible more recently (but pre-EASA Med) but for sure no AME knew about it (or no AME was willing to discuss it).

Now it is possible but I doubt many AMEs know about it.

Checking hearing without a headset is outrageous. How can that work, in a SEP, at cruise speed?

Administrator
Shoreham EGKA, United Kingdom

Hope this goes somewhere.. It’ll be a while no doubt and no guarantee of success. But apparently EASA is listening.

https://www.aopa-spain.org/images/2023/1.6%20Pilot%20medical%20requirements%20for%20non-commercial%20flying.pdf

Private field, Mallorca, Spain

Since this thread was started in 2014, all that seems to have actually happened is the UK PMD (self medical declaration). France has had its no-medical UL license for many years; that summary seems to have missed that one.

The French UL one is FR airspace only. The UK PMD is UK airspace (plus Channel Islands) only except you can also do France if the aircraft is Annex 1 (the summary has missed that one too; they should spend more time participating on EuroGA ).

One might expect the above FR/Annex 1 concession to expand but in 2 years plus nothing has happened. The politics behind it are mind-boggling, too (why not in say a PA28?) although one can see that it could have just been agreed between UK CAA (on behalf of the LAA) and FR DGAC, and with no EASA involvement which was probably the key because most EASA member countries would be afraid of this (CAA medical departments are very powerful, not to mention airline unions who always resist this kind of stuff, and both do it under the table).

The wider factor one might observe is that each concession probably makes additional ones harder, not easier. This is because

  • it creates a precedent, at that regulatory point
  • relieves pressure for more concessions

For example, the UK-FR Annex 1 PMD agreement relieves a certain amount of pressure to do more. So its existence makes extending it to certified aircraft harder, not easier.

It also dovetails well into existing concessions e.g. UK-FR has allowed Annex 1 anyway, without needing a permission (for 28 days only, but this is enough – and funnily enough that 28 day deal was obviously a coordinated UK+FR move too). It’s very like in principle to the UK IMCR which works well because it bans Class A, and most UK “professional pilot” CAS is Class A, and this makes it absolutely impossible to enhance the IMCR, because the resulting demolition of the IR (the hallmark of professional pilots, hey) would be politically explosive.

So when pushing for concessions, one needs to be careful to push for what is actually useful, not just a little bit which merely redraws the front line 10km to the east and new trenches get built there.

Administrator
Shoreham EGKA, United Kingdom

Someone copied this to me. I don’t know if it covers all this topic. It is in English.TL_2_08_Travelling_abroad_in_a_Permit_Aircraft_pdf

France

Yes; that one was posted multiple times in the definitive thread on homebuilt privileges. No relevant reference to anything medical. Interestingly it also fails to mention the FR / annex 1 thing. Looks like @jacko was well ahead

Administrator
Shoreham EGKA, United Kingdom

Yes, it’s a shame that two years on from the UK-FR agreement to recognise each other’s national pilot license and medical requirements, no other EU member state has taken this small but sensible step.

Perhaps Peter is right – too many vested interests?

Glenswinton, SW Scotland, United Kingdom
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