President’s Corner 2nd Quarter Issue 2024


Skies are Clearing! The FAA ARC Lands Ashore

Just as Noah brought every species back to land in his ARK after the legendary flood, the FAA ARC has landed with a full spectrum of recommendations on nearly every aspect of Mental Health and Aviation Medical Certification.  The recent FAA Aviation Rulemaking Committee, released a report noting 24 recommendations directed not only at the FAA medical system, but also included recommendations related to airman certification, education, Safety Management Systems, aviation stakeholders and both financial and legal roles in aviation mental health.

The ARC is chartered for two years through December 2025, but was required to submit its first report by 30 March 2024.  The ARC charter’s objectives were to identify barriers to seeking health care and make recommendations for policy and protocol revisions based on the assessment of barriers. Upon convening the ARC which was co-chaired by representatives from pilot unions (ALPA-I), the airlines (A4A), international aviation mental health coalitions (IPAAC) and an FAA representative, there were two working groups, an operational/peer support group and a medical group.  I had the privilege of co-chairing the medical working group.  Starting in mid-January, meetings were held almost daily until the report was published.

Five specific ARC Tasks were assigned.  The ARC was to make recommendation based on (1) identifying barriers to reporting healthcare issues and make recommendations to the FAA or others to reduce the barriers, (2) how the FAA should address mental health diagnoses (3) reduce safety risks between identification of diagnoses and medical certificate/clearance (4) review how international regulators address mental health issues and (5) educational needs to reduce stigma and encourage care and reporting in a confidential and protected manner.

The ARC report identified seven major barriers to aviation professionals avoiding seeking health care and reporting healthcare to the FAA.  The categories of barriers include:

  • Culture
  • Trust
  • Fear
  • Stigma
  • Financial
  • Processes
  • Knowledge and Information Gaps

The report outlines in detail how each of these barriers contribute to healthcare avoidance (HCA) with pilots and controllers.  These barriers are not independent but are closely linked to each other and compound the HCA problems, ultimately compromising aviation safety.

The working group consolidated their recommendations into 24 individual ones, each with a specific recommendation and four explanations of Intent, Rationale, Approach and Barriers Addressed.  Grouping the 24 Recommendations into broad categories yields 7 main areas:

  • Protections for disclosure and Peer Support programs [1-4]
  • Protocol suggestions for specific mental health diagnoses [5-8]
  • Incorporating mental health policies into a safety continuum and integration into Safety Management Systems with operational considerations [9-12, 22]
  • Improvement in FAA Information systems including the AME Guide, and FAA forms, use of modern means of communications and document verification submission systems [13-16]
  • Education programs for pilots/ATC’s, AME’s, mental health providers and aviation stakeholders with a long running multimedia approach [17-20]
  • Incorporation of mental health awareness in all aspects of aviation training and testing [21]
  • Improvement in insurance coverage for mental health diagnoses that result in medical disqualifications [23-24]

Although the FAA Aeromedical staff were not officially members of the ARC, they were active participants in providing expert insights essential for the ARC to achieve its goals.  The Federal Air Surgeon, Dr. Northrup, and her HQ staff, are addressing the mental health issues contributions at every meeting.  Although the ARC report has not yet been released, Dr.  Northrup and her staff were already actively working on policies to address some of the ARC preliminary recommendations.

FAA activities to support the ARC recommendations included numerous speaking and media presentations to aviation stakeholder groups about the FAA philosophy, and plans to act on the recommendations. See the Podcast with ALPA-I President Jason Ambrosi and Dr. Northrup – Navigating Pilot Mental Health and Wellness .  The Pilot Minute, a series of 1-2 minute videos by Dr. Northrup, have been addressing these issues for several years.  In April, just days after the ARC report was publicly released, the FAA added three antidepressant medications to the list of those allowed for treatment of depression.  Dr. Northrup and her staff also held a two-night webinar, “Grand Rounds”, for several hundred AME’s and industry advocates to educate them on recent changes (29 May 2024) in the AME Guide in mental health; there is also additional information on these medications below in the FAA Medication Update section. They indicated further changes would be forthcoming soon, once the safety of pending policy changes are confirmed and the language of the policies are reviewed.

Dr. Northrup and her staff have been actively speaking at numerous aviation events about her commitment to optimizing the mental health of aviation professionals as a key to safety and personal health even prior to the ARC report release.  I have had the privilege of joining her in at least a dozen of these events at national and international forums.  There is no doubt that she is “All-In” to improve the FAA system, policies and regulations to address this critical safety and health issue.

Several other important documents regarding aviation mental health and psychosocial risk have been released since the ARC report.  Each of these documents addresses a different aspect of the same issue and are complementary to each other.  I recommend that anyone interested in this topic read the very short Royal Aeronautical Society paper on The Mental Health Challenge to Civil Aviation Safety and the Summary of the 900+ page EASA ME SAFE – Mental Health in  Aviation Safety (scroll to bottom of page and read D5.1/D6.1 Review Report and Impact Statement).

To conclude my rough analogy to Noah’s ark, although the ARC report has landed, it will take time to implement many of the recommendations and fully populate the aviation mental health world.  There is a shared responsibility with all stakeholders; funding is needed.  Culture change will evolve over years or generations.  Education is an ongoing process. The good news is that the sun is shining on mental health as an essential aviation safety component and those that will help proliferate this message are moving out as the flood waters of health care avoidance and concealment are starting to recede.

Be well and Fly Safely,