EASA intends to kill the medical declaration

John Brady · Post by **John Brady** » Thu Aug 19, 2010 10:43 am

Ladies and Gentlemen,

please would you help by sending a comment to EASA on this - details linked from the story on the Homepage. The deadline is next Monday 23rd!

Can you also raise awareness elsewhere on other fora, clubs, websites etc.

Thanks,

John Brady

Jim Gale · Post by **Jim Gale** » Thu Aug 19, 2010 11:49 am

Thanks John for this expose on such a retrograde proposal relating to private flying.
Forwarded on to our members for action, this very moment.
Rgds,
Jim.

Terry Lee · Post by **Terry Lee** » Thu Aug 19, 2010 6:42 pm

I've just read some of the EASA fcl document and found it mostly confusing. Could someone kindly explain to me why any of this is necessary, from a GA stand point it just seems so utterly pointless, what is wrong with existing regulation whether here or elsewhere in Euroland

John Brady · Post by **John Brady** » Fri Aug 20, 2010 5:23 pm

Only 3 days to go

Chris B · Post by **Chris B** » Fri Aug 20, 2010 6:53 pm

John,
Looking at the EASA documents, via the CRT tool, the original proposal for "MED.D.001 Requirements for general medical practitioners" and related Sub Parts was issued in 2008.
Reading the broader requirements and the associated forms etc., it is debateable that there was ever any intention for GMPs to be able to sign off a self-declaration along the lines of the NPPL. In context, the “or” to “and” switch appears to be tidying up the drafting rather than a sea change through the back door.
We appear to have had two years to input to, develop and clarify these proposals and now have only three days left to respond. What happened?
Please could you point me in the direction of any documentation where EASA confirms that the original intention was to have a simple NPPL type sign-off as this may be more persuasive? Can we also see the BGA and LAA responses?
Any extra info in support of the case gratefully received.
Chris

Trevor Harvey · Post by **Trevor Harvey** » Fri Aug 20, 2010 7:00 pm

A difficult site to get to but eventually, comment sent.

Ian Melville · Post by **Ian Melville** » Fri Aug 20, 2010 7:11 pm

My do they make it difficult to respond

But done despite the hurdles

Alan Kilbride · Post by **Alan Kilbride** » Sat Aug 21, 2010 8:12 am

Done it...Thanks for the heads up.

GRF7R7 · Post by **GRF7R7** » Sat Aug 21, 2010 10:00 am

Help
Having registered. I have spent the last 2 hours trying to send a response but it has all disapeared yet again.
It is driving me mad.
G Hammond

ChampChump · Post by **ChampChump** » Sat Aug 21, 2010 12:47 pm

It's an unfriendly and over-complicated process. No suprises there, then.

On the Flyer forum, there's a thread with several links to step by step help; also suggested was to use a Word doc. for your reply then cut and paste it into the response form. Getting it to paste was my problem. I ended up having to type something onto their page first, before I could paste. Usual methods did not seem to apply.

Perseverence is all. Now what does that remind me of?

John Brady · Post by **John Brady** » Sat Aug 21, 2010 6:35 pm

Sorry I don't have time to dig out any more background just now but the BGA are leading on this for UK sport flyers so look on their website for more info.

If you cut and paste into the EASA CRT your time will be wasted as there is a screening program that compares replies and bins any that contain duplicates. Moreover doing that weakens our position as the number of duplicates is recorded against the UK and copying the LAA response may result in it being deleted and never read by anybody.

So please don't do that and please ask the Flyer forum not to do it.

Ta,

John

Ian Melville · Post by **Ian Melville** » Sat Aug 21, 2010 6:59 pm

John, I don't think they are cut-n-pasting from other peoples text. Just using notepad/word etc to type the text then transfer it to the CRT. That way if it goes belly up, you still have a copy of your text to try again.

I've posted a comment for you just in case

Dave Hall · Post by **Dave Hall** » Sun Aug 22, 2010 12:24 pm

Reading the broader requirements and the associated forms etc., it is debateable that there was ever any intention for GMPs to be able to sign off a self-declaration along the lines of the NPPL. In context, the “or” to “and” switch appears to be tidying up the drafting rather than a sea change through the back door.

I believe Chris B is right. I raised the matter at NC when the NPA first came out, as ISTR it was stated then that the GP would have to be trained in aviation medicine or be/have been a pilot.

That does not appear to have been relaxed at any stage, so the concession for a GMP medical may as well not have been included at all.

"What happened" is probably simply that everyone thought others had it covered. To be fair it should have been 'us guys' actually using GP medicals who kicked up rather than expect our lobbyists on Class 1 or 2 to pick up the baton and do it for us. That said, a comment from the LAA carries more weight than a dozen individual responses.

One slight advantage over the NPPL provisions is that the 65 to 70 yr-olds only have to get it renewed every 2 years, as compared with annually for the NPPL.

I have added a general comment to the consultation, but have no expectation that it will make the slightest difference, any more than the IMC battle will succeed. We justify the need for that because of our changeable weather, just as we justify the GP medical as we have a good GP system. The French justify their mountain certificate because they have mountains. Is it irrational that these are national provisions rather than Europe-wide?

I have some faith that our CAA will grant exemptions for national use, but I fear we will never get common-sense into the minds of the Eurocrats.