– EASA CAT.GEN.MPA.175 Endangering safety
After the Germanwings Flight 9525 incident, the Regulatory Authorities have been looking at ways to ensure that the circumstances that lead to the loss of 150 lives on March 24 2015, should not be able to happen again.
It has been accepted that the main causative factor of this incident was the mental health issues suffered by the Co-Pilot, which resulted in his deliberate crashing of the aircraft, committing suicide, with the attendant collateral deaths.
With this in mind, the regulators have been looking at how cockpit, and therefore flight, safety levels can be improved. Initially, the knee jerk reaction of the ‘two person cockpit rule', was a band aid to show the world that action was being taken. This ‘bought' some time, whilst the wider issues of Pilot stress, mental health and wellbeing were considered.
After two and half years of consideration, as of 23rd July 2018, the first step has been taken, with the introduction of new guidelines in regulating air operators' means of ensuring that their flight deck crew are appropriately tested for psychological stability, and suitability for their profession, has been announced.
We do not believe that the new regulations will address the main issue of Flight Crew Mental Health and Wellbeing and ‘misses' this point. A start, yes, but more understanding and work urgently needs to be done if the required safety wish is to be granted!
Whilst this requirement to conduct appropriate testing has been declared, there is a two year period to allow operators to prepare themselves to be able to comply with the rules as soon as they become mandatory.
If history is anything to go by, specifically with regards to Aviation, this two year period will pass by, until Companies suddenly realise that they are going to have to actually have this process documented and working ‘next week'! Notwithstanding the apathetic approach to the need, there is the small matter of cost to address, which is yet another reason the fabled ‘bean counters' will no doubt want to avoid the topic where at all possible.
That aside, this is possibly one of the most important steps in Safety to be mooted for many years, and should be now being openly discussed and understood by all sectors of the industry, and seen for what it is, a way of raising the bar on safety, and also helping highlight one of the key factors of the decline in pilot numbers, the way which pilots are treated by their employers in many cases.
In the following, we will look at what the current situation is, what the new regulations actually achieve, and what we believe are the actual actions that are required to start to make a real difference.
To commence the discussion of the importance of this step, but also highlight why the new regulations do not go far enough, the keystone declaration needs to be understood.
Here is the EASA Terms of Reference for the regulatory changes.
(The link to the regulation published 26 July 2018 can be accessed: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32018R1042&from=EN)
The specific text therein is
CAT.GEN.MPA.175 Endangering safety
Note 1: Point c) would apply for an operator with only one or two aircraft, perhaps light aircraft doing displays. EASA probably would not look favourably on any larger commercial operator trying to do an internal assessment of psychological attributes and suitability, nor would the insurance companies!
Note 2: The line about ‘in respect of the work environment' supports the need to assess at every point of recruitment (i.e. change of company), not just before they start line flying in the first place, or based upon a ‘previous' assessment at a prior Operator. Work environments change between organisations, because there is a cultural element in stress as well as the actual role requirements.
So, this is the ‘new' regulation. Basically, it means that to comply with this, in a sensible and realistic manner, Operators merely have to conduct a ‘Psychometric' test.
‘Psychometric tests are a standard and scientific method used to measure individuals' mental capabilities and behavioural style. Psychometric tests are designed to measure candidates' suitability for a role based on the required personality characteristics and aptitude (or cognitive abilities)'.
– Introduction to Psychometric Tests – Institute of Psychometric Coaching.
Working extensively in the field of Pilot Recruitment and Management, it can be seen that most Airlines and Operators already have a testing procedure in place in their selection processes already. Therefore, it is not clear what effect the new regulation is going to have in the real world.
As would be expected there is a fair amount of disagreement among the Psychologists, including those on the EASA steering committee, about whether this new declaration actually changes anything from this present situation (ADAPT/Psychometric Tests being part of the airline selection procedure), adds to it, or indeed actually solves any of the main issues of actual mental health (as opposed to personality suitability) now and going forwards.
For the lay persons amongst us, there needs to be some clarity outlined here, so that we can understand the issues.
So to simplify,
1. What is the problem being solved?
This is the crux of the matter. Workers in any industry are subject to stress induced issues, depending upon a whole raft of factors. Whether a ‘situation' is work induced or due to personal issues, short term or long term, major or minor, how people ‘cope' in any given circumstance is the end result. That end result defines the outcome in terms of success or failure.
Flight Crew are no different. However, the outcome of an issue for a flight crew member can be dramatically more disastrous than in the majority of other industries.
Basically, Airlines/Operators of aircraft want to ensure that the Flight Crew members they employ will not only be able to cope with all the normal stresses and strains of the repetitive delivery of a successful outcome for every flight, but also to react and perform perfectly when under the most hideous of stressful situations. To achieve this ‘capability prediction', over the 100 years of aviation a series of tests have been developed to find out whether a pilot has ‘the right stuff'!
2. What is the current procedure for testing?
Developed by a variety of interested parties this has evolved from simply ensuring that your pilot had a straight back, and could survive a Chukka of polo in good enough order (flying skills were a secondary consideration), to modern day Psychometric testing to measure individuals mental capabilities and behavioural styles.
Present day crew selection processes will vary from company to company, but will usually be a mix of the following:
Psychometric tests are designed to measure a candidate's suitability for a specific role based on the required personality characteristics and aptitude. They can be used to determine whether or not a particular pilot is likely to follow set procedures, capable of handling stress, reacting under certain circumstances in a desired way that facilitates a successful operating environment, and whether they are able to fit into the particular culture of a particular Airline
3. What does the ‘new' procedure achieve?
The ‘new' procedure is simply the same as the ‘old' procedure of testing, but in a mandated format. This is fine for selecting your crew member from a pool of supposedly normal and well-adjusted individuals. It should even highlight some potential issues with personality types that have predispositions to susceptibility to metal health issues. It will predict which crew members are able to fit culturally in the organisation, which ones are able to carry out their tasks in a predictable and understandable manner, and those likely to be able to be upgraded to Captain/PIC
It ensures that Airlines document what they do, so that should an incident occur, then everyone can say they did the best they could.
There is no definition as to what extra is needed to add to current testing, nor what possibilities there are to make things much better. It pushes the responsibility onto the Airline with little further guidance.
4. Why is that not enough?
The simple Psychometric test, whilst still a valuable predictive tool for personality testing, does not give any further guidance as to how a crew member feels on a day to day basis, as their life changes. It clearly does not ensure that the crew member is monitored for the changes in mental health that occur due to the stress and strains of normal life, work and also the unavoidable crises that occur throughout life
The vital fact being missed here is that Personality and Mental Health are two different things!
Personality is stable over time, but mental health fluctuates from day to day, so a personality profile cannot measure or accurately predict mental wellbeing state at a particular time.
Whilst the above mentioned selection procedures have very successfully worked for many years in the vast majority of cases, and ‘weeded' out very many individuals whose personal choice of career unfortunately did not necessarily match their overall suitability for the role, the compounding issue is that the role of pilot is changing due to a range of new factors.
Expansion – Due to the vast increase in the air travel industry over the last few years, there is an ever increasing requirement for new crew to fill new aircraft front seats. The public expects to fly, and airlines (as corporate entities) want to fly them (revenue generates profit for stakeholders). So, there is a an expansion in the number of crew required, which is unfortunately not matched by the number of crew coming into the industry, nor the capability of training crews quickly (but properly).
Expectation - This leads to Airlines ever increasing expectations for their current crew to fly to the maximum hours as possible. This leads to stress at work, fatigue and a quality of life reduction. No longer are the 7 day lay overs on the beach in the Maldives a 'perk of the job'. Minimum rest turn rounds are the rage which, mixed with crossing numerous time zones for long haul crew, can lead to serious health and fatigue induced issues. For short haul ‘Low-Cost' crew the work day can be seriously busy with some flying six leg days, with early starts and late finishes, and split shifts, not uncommon
Automation – The changing face of the role of pilot from being ‘hands on fighter pilots' to the role of systems monitor, is not one that sits kindly with the previous definition of the right stuff. Whilst automation is championed by many to prevent the ‘human error' part of an accident chain, over automation has brought many problems of its own. This will actually get worse with the push to ‘single pilot cockpits'. This affects the pilots by effectively emasculating the role (females pilots suffer similarly so the word is not meant in a sexist definition) that they have trained for. There is also a reduction in manual handling skills through lack of practice. This shows itself usually at the point where the pilot needs to be exactly at their best…when automation fails, and the aircraft is in a perilous position.
Erosion – There has been not only a reduction in the salary and benefits of the position of pilots in value terms (Pilots earn largely the same amount they did 20 years ago in real terms, but the value has vastly reduced), but a big erosion in the attractiveness of the position. Piloting is no longer perceived in the same way it was 20 or 30 years ago, nowadays many just think of their pilot as a glorified ‘bus driver'. Luckily there are still enough new aspirant pilots, but the numbers are definitely dwindling, so the technological push to single pilot cockpits, may be the way that Aviation survives in the medium term!
These factors have changed the face of piloting to such an extent that simply knowing the character of the pilot may not be enough to prevent the type of incidents such as the Germanwings case. Even more so, when that profile may have been assessed some years ago, and no longer reflect the level of resilience needed to cope with today's environment. Add in the fact that the personality profiles do not assess mental health, and you can see the gaping hole!
The need for attention on this subject becomes more urgent as time passes. However, finding a workable solution in the face of cost, time and a lack of understanding of the real issues, is not going to be easy or quick. The simple fact is that something needs to start now, and at least EASA have got that part right.
Consider the following, Regulators mandate that the Commercial Pilot licence, once gained, is checked by LPC every 12 months, and by OPC every 6 months. Yet, the same Regulators accept that the Pilot mental health needs only be checked at the beginning of their work, and no more. This seems strange unless you consider the difference between licencing and mental health. One has been developed over the years by Aviation technical people, all of whom at least once had the ‘right stuff' themselves. The other is an ethereal human factor that is hard to understand for the technical mind.
To make it simple, and understandable, the following check list should be applied:
Realistically, if you have a check at the beginning and have no further checking, how can an Airline or Operator be said to be doing their ‘best' to ensure that an incident such as the Germanwings crash is unlikely to happen again, when the parameters change very quickly over time?
Robin Hepworth. M.R.E.C. Business Manager, Resource Group Flight Crew Services; Commercial and VIP Flight Crew Management and Recruitment Specialists
Karen Moore CPsychol CSci AFBPsS, MD and Principal Occupational Psychologist at Symbiotics; specialist in assessing human behaviour and potential.