BALPA has been keeping a watchful eye on EASA's proposals for random alcohol testing and peer support programmes, and we can now bring you the latest information. 

Pilot peer support programmes

In February 2018, EASA finally confirmed that it will be introducing new rules requiring all EU airlines to introduce peer support programmes. These programmes are designed to provide a confidential support structure for any pilot who feels they have issues (including drug and alcohol problems) which may have a detrimental impact on their ability to perform their duties. Importantly, the peer element of the programmes provides not only a ‘friendly ear’ from someone who understands the job, but also a mechanism for obtaining professional support and assistance to individual pilots who might need help with addressing their particular problems in life – including mental health, drug and alcohol problems. Confidentiality is key to the whole process and the EASA regulation will mandate that this is a requirement of any peer support programme.
 
BALPA has always strongly advocated peer support as the most effective way of addressing mental health, drug and alcohol issues and, as previously reported, we have worked with airlines and the regulator to produce a model peer support policy. This model policy has already formed the basis of BALPA-agreed peer support programmes in several airlines including British Airway, easyJet, Thomas Cook and Flybe. Several other Company Councils are also in the process of agreeing peer support programmes in their companies. 
 
Although the new EASA rules are not likely to be fully implemented until late 2020, we will continue to get ahead of the game and will aim to ensure we have good BALPA-agreed peer support programmes in every BALPA-recognised UK airline well before the final implementation date (probably late 2020).

Mandatory random alcohol testing

In February 2018, EASA also announced that it will be introducing mandatory random alcohol testing conducted as part of the ramp inspection programme. Where possible the testing will be conducted outside the aircraft (e.g. in the crew room) and will take place after a pilot has reported for duty. Random alcohol testing will apply to pilots and cabin crew.
 
Random alcohol testing will not be evidential testing. Therefore, if the ramp inspectors record a positive alcohol breath test, this will need to be followed up by an evidential test conducted by the police. In other EU countries, and depending on national legislation, the testing may be done by either ramp inspectors or by the police, or both.
  
Although BALPA is not opposed in principle to random testing, we have always argued that the best way of addressing drug and alcohol issues is via peer support. The emphasis should therefore be on building strong and effective peer support programmes. We also argued that any system of random alcohol testing should be conducted via employers using a properly accredited testing agency and under BALPA-agreed arrangements, not by ramp inspectors or the police. BALPA is therefore disappointed that EASA has chosen to adopt random alcohol testing via the ramp inspection programme. We will, however, now focus our efforts on liaising with the CAA to ensure that random testing is conducted in an appropriate manner with proper safeguards in place (for example, proper chain of custody, measures to avoid or minimise any false positive test results, etc). 
 
While random alcohol testing is to become mandatory, drug testing will not. However, the new rule set leaves an open door to EU countries if they want to introduce a national scheme for mandatory random drug testing in the future. 

Psychological assessment when pilot first employed

EASA will also introduce a new requirement for a psychological assessment when a pilot is first employed by an airline. Although BALPA still has concerns about the effectiveness of any psychological assessment – on the basis that there are no reliable tests for accurately determining the true mental state of an individual – we will work with the CAA to ensure the assessments are undertaken appropriately and with proper safeguards in place. 

Timeframe

EASA’s new rules will now go through the usual EU law-making process, which will include approval by the European Parliament. We expect this process to be completed by the end of 2018. With a two-year transition process, the new rules are likely to come into effect in late 2020.