In response to the Germanwings tragedy, EASA has made a number of flight safety recommendations and is seeking to introduce new rules covering the four main issues set out below. BALPA has been working closely with ECA, a group of UK employers, the CAA and the DfT to ensure that any new rules are appropriate and effective:

Drug and alcohol testing

In addition to post-accident testing, EASA is proposing to introduce D&A testing (i) when a pilot is first employed by an airline, (ii) when there is “reasonable suspicion” and (iii) as part of a return-to-work / rehab programme. The European Regulator is also considering the introduction of “random” testing.

BALPA response: We support testing in relation to (i), (ii) and (iii) above. BALPA has already agreed D&A policies in most airlines covering these three scenarios. On “random” testing, the Association is not opposed in principle.  However, we remain to be convinced that this is the best way of addressing D&A issues.  We believe the emphasis should be on effective peer intervention programmes (see below). BALPA and ECA has also pointed out that D&A issues were not, as far as we know, relevant to the Germanwings crash and have questioned why they have been included as part of EASA’s recommendations.

Peer intervention

EASA is proposing the introduction of peer intervention as a way of addressing any D&A issues in the workplace and supporting any individual pilots suffering from alcohol or drug problems.

BALPA response: We strongly support this proposed way forward.

Psychological testing

EASA is proposing the introduction of psychological testing when (i) a pilot is first employed by an airline and (ii) a pilot is seeking to renew their medical certificate following its suspension due to a psychiatric illness and/or a drug or alcohol problem.

BALPA response: We do not support the use of psychological testing on the basis that (i) there are no reliable tests for accurately determining the true mental state of a pilot and (ii) a false positive result could have potentially career-ending consequences. BALPA and ECA have also pointed out to EASA that the use of psychological testing would almost certainly not have prevented the Germanwings tragedy.

Minimum occupancy

EASA is considering the introduction of a “two people on the flight deck” rule.

BALPA response: We would not support any “two people on the flight deck” rule on the basis that (i) this is unlikely to be a very effective security measure and (ii) the focus should be on addressing any security issues on the ground, not after the aircraft has taken off. In our view, individual airlines should be able to develop their own rules regarding minimum occupancy based on an appropriate risk assessment.

We expect EASA to put forward its final proposals at a special conference in mid-June and will report further following this event.