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TRANSCRIPT
Disabled Pilots 1
Disabled Pilots Lecture given at Aviation Medicine Basic Course
8. September 2015
by Michael Amtmann
at European School of Aviation Medicine, Frankfurt
� The Legal Basis An overview of the basic regulations
concerning the subject Disabled Pilots
� Existing Solutions An overview of flying activities of disabled pilots
and of modifications to aircraft controls
� Appendix Source texts
Disabled Pilots 2
� The Legal Basis
1. The basis for the assessment of a disabled person is the
Regulation 1178/2011 of the commission of the EU.
In Germany this document became effective on 8th of April 2013.
2. This regulation is supplemented by the document
Acceptable Means of Compliance (AMC)
and Guidance Material (GM) to Part-MED, 15 December 2011.
Amendment 1, 8 August 2013 (not binding - see http://easa.europa.eu >>> the agency >>> FAQs >>> Acceptable Means of …)
3. Regulation 290/2012, amendments to Regulation 1178
4. Some corrections to Regulation 1178.
(with no effect on our subject)
Disabled Pilots 3
1. Regulation 1178, ANNEX 6, PART-MED
Paragraphs applicable especially for handicapped applicants for a pilot’s licence:
MED.A.025 Obligations of AeMC, AME, GMP …
Letter (b) deals with information to be given to the applicant for an aeromedical
certificate, in particular:
“(3) if the person has been assessed as unfit, inform him/her of his/her right of a
secondary review, …”
MED.A.030 Medical certificates
Letter (a) defines that a student pilot needs the appropriate medical certificate only
for his solo flights.
That prescription makes flights with the applicant and an FI/Examiner possible
in order to assess the needs and to evaluate if the applicant is able to perform
his duties safely when complying with certain limitations!
MED.A.040 Issue, revalidation and renewal of medical certificates
Letter (e) deals with the need for the applicant to undergo additional medical
examinations and investigations if needed.
Letter (f) deals with the right of the licensing authority to issue or re-issue a medical
certificate.
MED.A.050 Referral
rules the transfer of the relevant medical documentation in case of referral.
MED.B.001 Limitations to medical certificates
This paragraph deals with applicants who do not fully comply with the requirements
for the relevant class of medical certificate but are considered to be not likely to
jeopardise flight safety (“non-standard-applicants”).
Letters (a) and (b) rule the competency
-- to evaluate whether the non-standard-applicant is able to perform his duties safely
when complying with proper limitations,
-- and to issue the medical certificate.
At the end of the listing of applicable paragraphs an overview over this process will be given by means of a diagram!
Also ruled in (a) and (b): A revalidation or renewal of a medical certificate with same
limitations can be made by AeMC or AME or GMP without referring to the licensing
authority or without referring to an AeMC or AME.
Letter (c):
Part (1) of this letter could be seen as an appeal to beware of unnecessary
limitations.
Disabled Pilots 4
Part (2) of letter (c) states that the applicant’s ability, skill and experience are to be
positively considered.
Letter (d) defines codes OML, OSL, OPL for limitations
There are more limitation codes listed in the document Acceptable Means of Compliance and Guidance Material to Part-MED. I haven’t been able to unravel the mystery why some codes are defined here in MED.B.001 (d), others in AMC1 MED.B.001, others in GM1 MED.B.001.
Letter (e) makes any other limitation possible if required to ensure flight safety.
In my judgment that sentence provides the chance for flying activities also for applicants with disabilities not explicitly mentioned in those regulations.
Letter (f) states that any limitation shall be specified in the medical certificate.
MED.B.005 General
Letter (b) and (c) state that in case of a referral to the licensing authority this authority
may delegate the decision to an AeMC or AME.
MED.B.010 to MED.B.095
-- give detailed information about the examinations needed and about the medical
facts and limits that are relevant for the fit or unfit assessment
-- and defines when a referral to or a consultation with the licensing authority is
indicated.
A remark to the paragraph MED.B.050 Musculoskeletal System: Here are the conditions depicted that are mostly important for people like me with a physical handicap that affects their ability to operate the common control devices of an aircraft. The statements of this paragraph are rather vague – adequate to the wide variety of disabilities concerning the musculoskeletal system.
Disabled Pilots 5
2. Acceptable Means of Compliance (AMC) and Guidance Material (GM)
to Part-MED:
Important: AMC are non-binding:
“AMC illustrate a means to comply with the rule, but not the only means: they are
non-binding. So you are not obliged to follow an EASA AMC, and may choose other
means to demonstrate compliance with the rules.”
Applicable paragraphs:
AMC1 MED.B.001 Limitations to class 1, class 2 and LAPL medical certificates
Letter (a) allows an AeMC or AME to refer the decision to the licensing authority in any borderline case, not only in the cases listed in regulation 1178
Letter (b) allows the consultation with flight operations and other experts.
Letter (c) gives a list of limitation codes.
Letter (d) and (e) rule the entry and removal of limitation codes.
GM1 MED.B.001 Limitation codes gives additional explanations to the limitation
codes.
Especially the listing of limitation codes demonstrates the wide variety of disabilities that not necessarily cause the unfitness of an applicant for flying activities, for example: APL - valid only with approved prosthesis OAL - restricted to demonstrated aircraft type AHL - valid only with approved hand controls SSL - special restriction as specified Particularly the last code may suggest that no restriction is excluded a priori.
AMC1 MED.B.010 to AMC1 MED.B.090 states specific requirements for class 1,
AMC2 MED.B.010 to AMC2 MED.B.090 states specific requirements for class 2,
AMC1 MED.B.095 to AMC16 MED.B.095 states specific requirements for LAPL
medical certificates
The AMC concerning the item Musculoskeletal System MED.B.050 and MED.B.095 highlights especially the possibilities or the need of a medical flight test. Such a flight test could lead to a kind of “demonstrated ability”.
Disabled Pilots 6
3. Regulation 290/2012, some amendments to Regulation 1178
Applicable paragraphs:
ARA.MED.120 and 125 define the procedure in case of a referral to the licensing
authority (for the competent respectively licensing authority).
ARA.MED.315 particularly demanding a process to assist AMEs and AeMCs on their request regarding their decision on aero-medical fitness in contentious cases (from the licensing authority).
ARA.MED.325, that deals with the process of a secondary review to be established at the competent authority.
In Germany the Verordnung über Luftfahrtpersonal (LuftPersV) §21 Number (4)
rules the procedure of secondary review of an aeromedical assessment as
demanded in this paragraph!
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SUMMARY
Responsibilities for assessment and issue of the medical certificate for “non-
standard” applicants according to
MED.B.001 (a) (b) - MED.B.005 (b)(c)
AMC1 MED.B.001 (a) - AMC1 MED.B.001 (b)
AMC1 MED.B.001 (a)
may refer
AeMC
MED.B.001 (a)
may delegate
MED.B.005 (b)
AME, AeMC shall refer,
as indicated* licensing
authority
* as indicated in SUBPART B SECTION 2 - Medical requirements for Class 1 and Class 2 medical certificates, MED.B.005 - 090
Class 1
may delegate
AeMC or AME
MED.B.005 (c)
may refer licensing
authority
AMC1 MED.B.001 (a)
MED.B.001 (a)
nsultaion
with AME, AeMC
licensing
authority
Class 2
MED.B.001 (b) AMC1 MED.B.001 (a)
may refer licensing
authority GMP shall refer to AeMC or AME
LAPL
… evaluates whether the applicant is able to perform his duties safely when complying with one or more limitations endorsed on the medical certificate, and issues the medical certificate with limitation(s) as necessary
Red/twin frames:
AMC1 MED.B.001 (b):
In cases in which a fit assessment can only be considered with a limitation, the AeMC, AME or the licensing authority should evaluate the medical condition of the applicant in consultation with flight operations and other experts, if necessary.
Generally:
…
Disabled Pilots 8
� Existing Solutions
There are some standard solutions, made for pilots who cannot operate the rudder
pedals with their feet due to an amputation or a palsy. Those are the pilots with the
AHL limitation - ”valid only with approved hand controls”.
For Ultralight / ULM / Microlight aircraft (pictures on page 11)
Some producers offer a hand control for their aircraft:
• COMCO IKARUS for the C-22, C-42, C-52 • fk Leichtflugzeuge for the FK 9 • B.O.T. Aircraft for the SC07 • Pipistrel for the Taurus (and other models) • AEROPRAKT for the A-22 • Magnaghi Aeronautica for the Sky Arrow • Flysynthesis for the Texan • Paradise Aircraft for the Paradise P1 • AutoGyro for the gyrocopter MTOsport and CAVALON
For other types exist individual adaptions,
for instance for Sunny, Skywalker, Tecnam P92.
The basic principles of those hand controls are quite diverse:
Partly they have an additional stick on the right or on the left side of the pilot’s seat,
partly they move the hand controlling the rudder like at a bicycle, partly contrarily (like
the corresponding foot), partly left-right.
Partly the pilot can control the throttle with the same lever, partly the pilot must
unhand the lever for the rudder to adjust the power.
Just as diverse is the way to control the brakes.
For gliders: (pictures on page 12)
Hand controls are available at Alexander Schleicher Flugzeugbau for the ASK 21, at
Schempp Hirth for the Duo Discus and the Discus, and at and Jonker Sailplains
(South Africa) for the JS1C. There is also an HC for the GROB Twin Astir III.
The hand controls in those gliders all have the same principle:
The rudder is controlled with the left hand, the movement of the hand is the same as
the movement of the left foot would be, opposite to a bicycle.
The lever for the air brakes can be locked in different positions.
The modification for ASK 21can also be retrofitted in the workshop of an aero club;
the producer sells a kit for it.
The additional parts in the aircraft are quickly removable, so there is no restriction for
the operation of an aircraft equipped with such controls in an aero club or a flying
school. ASK 21 and Duo Discus fly all over the world with those hand controls.
Disabled Pilots 9
An unusual, but good and very easy to install hand control is used mostly in Austria:
They mount a control wheel for the rudder on the top end of the control stick. The
control wheel is connected to the rudder steering system by Bowden (push-pull-)
cables. It is used in Grob Twin Astir, in the good old Scheibe Bergfalke, in the
aerobatic glider Pinocchio by Dietmar Poll, and in the TMG Scheibe Falke SF25.
By the way, the above-mentioned gyrocopters are modified according to this
principle.
For airplanes: (pictures on page 13)
The oldest system is the Blackwood hand control, a simple bar connected to the left
pedal of the right front seat. It is controlled with the right hand. Right rudder deflection
is made by lifting the lever, left rudder by pushing it down. For adjusting the power
the pilot must unhand the rudder lever. For braking he uses the hand brake lever with
the left hand.
Another classic system is the Union Aviation hand control for Cessna 172, 177, 337,
also a very simple construction.
Both systems, Blackwood and Union Aviation, are certified in the European Union by
the Grandfathered Approval Regulation (information about it on the ROLLI FLIEGER
website www.rolliflieger.de).
Both hand controls are for non-permanent installation.
In France they have a hand control developed by Aerospatiale for the Socata Rallye
series (“Morane”), but adapted also for Robin and other Socata aircraft: The pilot
controls the rudder with a lever at the right hand. The movement of that hand is
“bicycle like”: Right hand forward causes a left deflection of the rudder, and vice
versa. The grip of that lever is pivotable (not like the grip of a motorcycle, but e.g. as
a door handle) to control the throttle. The grip is equipped with additional switches for
flaps or the push-to-talk-switch. That modification is permanent and rather expensive.
The French pilots also developed a new version of the Blackwood hand control with
more natural, reversed moving direction (down = right, up = left rudder) and an
additional brake lever for the left hand. It is certified by EASA.
The hand control I designed for the Piper PA 28 series (for models with fixed
propeller only) works like the French system, but it is made for non-permanent
installation. The installation in and the removal from an aircraft takes about 30
minutes. I made my flight training using different aircraft Piper PA 28-140, -161
Warrior and -181 Archer of my aero club in Aschaffenburg.
For braking I use the hand lever, which is prolonged so that I can reach it with the left
hand.
Disabled Pilots 10
In Great Britain they have an improved version of the Blackwood HC, called VisionAir
Hand Control, which was developed in Australia.
There are still some more hand controlled aircraft in GB.
Especially worth mentioning is the disabled pilot John Askew. He successfully flew a
hand controlled YAK 52 and now he flies a CAP 232 at national aerobatic
competitions in Great Britain! You can find the link to a YouTube video that shows
him flying with the CAP.
Also worth mentioning is the hand control for the Italian Tecnam P2002JF.
There are dozens of pilots flying with hand controls in many European countries. The
precise number is unknown. Unfortunately there are only three pilots flying airplanes
with hand control in Germany (one flying Cessna, one flying Piper Arrow – he has
also the Instrument rating, and me flying Piper PA 28), but many glider pilots and UL-
pilots.
There are also some flight training organizations and especially aero clubs providing
aircraft with hand controls - in Germany only UL and gliders, in France and England
also hand controlled airplanes.
An important note: Flying with hand controls may require some modifications in flight
procedures, for example for the use of the flaps, go around procedures and more.
These procedures are depicted in the manual of the hand control or must be
developed according to the student’s needs during the flight training.
Other limitations concerning Musculoskeletal System
There are many pilots with amputation of a foot or lower leg. Often they can fly an
aircraft without any modification, depending on the style of construction of the rudder
and brake system. That can be assessed with a simple practical test.
Some pilots with above-knee amputation can fly certain types of aircraft without any
modification, other types with very simple modifications.
For example: There is an attachment for the pedals for Cessna 172 that allows
controlling that aircraft with an above-knee prosthesis. Another pilot flies the Robin
DR 400 with a special shoe only, and gliders with a minimal modification.
In other countries there are also one-legged pilots controlling the rudder by pulling
and pushing one pedal, or by alternately pushing the left and right pedal with the
remaining leg. The possibility to do so depends on the style of construction, off
course.
I personally know three pilots flying or having flown with one arm in Germany.
One of them flies UL aircraft with few modifications. The others flew aircraft like
Cessna 172 and also complex aircraft like DO 27 and Fieseler Storch with or without
using their prosthesis. The possibilities depend on the design of the aircraft controls.
Disabled Pilots 11
Hand controls for UL …
… Skywalker
… B.O.T. SC07
…Sky Arrow
Disabled Pilots 12
Hand controls for gliders …
rudder control lever
notch for airbrake lever
… ASK 21
… Astir
… Taurus
Disabled Pilots 13
Hand controls for airplanes …
Piper PA 28 …
… with Blackwood hand control
… with Amtmann HS1B hand control
Disabled Pilots 14
Deficits concerning other body functions
In the USA, England and France deaf pilots fly airplanes. I think that is possible
without the loss of safety with appropriate limitations. For example, their activity could
be limited to flights at an airfield with a proper communication system, their home
base, and in airspaces where radio communication is not mandatory. Flights to other
airfields and in other airspaces could be allowed with a safety pilot.
Hang gliding, Paragliding, Parachute jumping
There are also hang glider or paraglider pilots using a wheelchair. You can find many
videos on YouTube especially showing hang glider pilots using special wheelchairs,
also in Germany.
But for those activities they don’t need a medical certificate.
There are also parachute jumpers with handicaps, it’s said that even wheelchair
users dare to leave a flying, intact aircraft ;-) . Unfortunately I have no further
information about them.
“Leichte Luftsport-Geräte”, 120-kg-aircraft
Neither do I have information about handicapped pilots flying aircraft in the 120-kg-
class, in Germany called “Leichte Luftsport-Geräte” – for that aircraft a medical
certificate isn’t needed, either.
www.rolliflieger.de
I invite you to visit the website www.rolliflieger.de.
On the main page you will find some interesting web-links, and you will find my contact data there.
I would also enjoy helping you with more information in direct contact!
Disabled Pilots 15
� Appendix Source texts (extracts) to
1. Regulation 1178/2011 of the commission of the EU.
Full Text:
EN http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:311:0001:0193:EN:PDF
DE http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:311:0001:0193:DE:PDF
2. Acceptable Means of Compliance (AMC)
and Guidance Material (GM) to Part-MED, 15 December 2011. Full Text:
http://www.easa.europa.eu/agency-measures/docs/agency-decisions/2011/2011-015-
R/AMC%20and%20GM%20on%20the%20medical%20certification%20of%20pilots%20and%20m
edical%20fitness%20of%20cabin%20crew.pdf
Amendment 1, 8 August 2013
Full Text: http://www.easa.europa.eu/system/files/dfu/Annex%20to%20ED%20Decision%202013-016-R.pdf
Important – about the significance of AMC:
http://www.easa.europa.eu/the-agency/faqs/acceptable-means-compliance-amcs-and-
alternative-means-compliance-altmocs
3. Regulation 290/2012, amendments to Regulation 1178
Full Text:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:100:0001:0056:en:PDF
Disabled Pilots 16
1. Commission Regulation (EU) No 1178/2011 of 3 November 2011
ANNEX IV - [PART-MED]
SUBPART A - GENERAL REQUIREMENTS
SECTION 1 - General
MED.A.025 Obligations of AeMC, AME, GMP and OHMP
...
(b) After completion of the aero-medical examinations and/or assessment, the AeMC, AME, GMP and OHMP shall: (1) advise the person whether fit, unfit or referred to the licensing authority, AeMC or AME as applicable; (2) inform the person of any limitation that may restrict flight training or the privileges of the licence, or cabin crew attestation as applicable; (3) if the person has been assessed as unfit, inform him/her of his/her right of a secondary review; and
…
SECTION 2 - Requirements for medical certificates
MED.A.030 Medical certificates
(a) A student pilot shall not fly solo unless that student pilot holds a medical certificate, as required for the relevant licence
…
MED.A.040 Issue, revalidation and renewal of medical certificates
…
(e) The AME, AeMC or, in the case of referral, the licensing authority may require the applicant to undergo additional medical examinations and investigations when clinically indicated before they issue, revalidate or renew a medical certificate.
(f) The licensing authority may issue or re-issue a medical certificate, as applicable, if: (1) a case is referred; (2) it has identified that corrections to the information on the certificate are necessary.
MED.A.050 Referral
(a) If an applicant for a Class 1 or Class 2 medical certificate is referred to the licensing authority in accordance with MED. B.001, the AeMC or AME shall transfer the relevant medical documentation to the licensing authority.
(b) If an applicant for an LAPL medical certificate is referred to an AME or AeMC in accordance with MED.B.001, the GMP shall transfer the relevant medical documentation to the AeMC or AME.
Disabled Pilots 17
SUBPART B - REQUIREMENTS FOR PILOT MEDICAL CERTIFICATES
SECTION 1 - General
MED.B.001 Limitations to medical certificates
(a) Limitations to Class 1 and Class 2 medical certificates (1) If the applicant does not fully comply with the requirements for the relevant class of medical certificate but is considered to be not likely to jeopardise flight safety, the AeMC or AME shall: (i) in the case of applicants for a Class 1 medical certificate, refer the decision on fitness of the applicant to the licensing authority as indicated in this Subpart; (ii) in cases where a referral to the licensing authority is not indicated in this Subpart, evaluate whether the applicant is able to perform his/her duties safely when complying with one or more limitations endorsed onthe medical certificate, and issue the medical certificate with limitation(s) as necessary; (iii) in the case of applicants for a Class 2 medical certificate, evaluate whether the applicant is able to perform his/her duties safely when complying with one or more limitations endorsed on the medical certificate, and issue the medical certificate, as necessary with limitation(s), in consultation with the licensing authority; (iv) The AeMC or AME may revalidate or renew a medical certificate with the same limitation without referring the applicant to the licensing authority. (??? respectively without consultation with the licensing authority ???)
(b) Limitations to LAPL medical certificates (1) If a GMP, after due consideration of the applicant’s medical history, concludes that the applicant does not fully meet the requirements for medical fitness, the GMP shall refer the applicant to an AeMC or AME, except those requiring a limitation related only to the use of corrective lenses. (2) If an applicant for an LAPL medical certificate has been referred, the AeMC or AME shall give due consideration to MED.B.095, evaluate whether the applicant is able to perform their duties safely when complying with one or more limitations endorsed on the medical certificate and issue the medical certificate with limitation(s) as necessary. The AeMC or AME shall always consider the need to restrict the pilot from carrying passengers (Operational Passenger Limitation, OPL). (3) The GMP may revalidate or renew an LAPL medical certificate with the same limitation without referring the applicant to an AeMC or AME.
(c) When assessing whether a limitation is necessary, particular consideration shall be given to: (1) whether accredited medical conclusion indicates that in special circumstances the applicant’s failure to meet any requirement, whether numerical or otherwise, is such that exercise of the privileges of the licence applied for is not likely to jeopardise flight safety (2) the applicant’s ability, skill and experience relevant to the operation to be performed.
(d) Operational limitation codes (1) Operational multi-pilot limitation (OML — Class 1 only) (i) When the holder of a CPL, ATPL or MPL does not fully meet the requirements for a Class 1 medical certificate and has been referred to the licensing authority, it shall be assessed whether the medical certificate may be issued with an OML valid only as or with qualified co-pilot’. This assessment shall be performed by the licensing authority. (ii) The holder of a medical certificate with an OML shall only operate an aircraft in multi-pilot operations when the other pilot is fully qualified on the relevant type of aircraft, is not subject to an OML and has not attained the age of 60 years. (iii) The OML for Class 1 medical certificates may only be imposed and removed by the licensing authority. (2) Operational Safety Pilot Limitation (OSL — Class 2 and LAPL privileges) (i) The holder of a medical certificate with an OSL limitation shall only operate an
Disabled Pilots 18
aircraft if another pilot fully qualified to act as pilot-in-command on the relevant class or type of aircraft is carried on board, the aircraft is fitted with dual controls and the other pilot occupies a seat at the controls. (ii) The OSL for Class 2 medical certificates may be imposed or removed by an AeMC or AME in consultation with the licensing authority. (3) Operational Passenger Limitation (OPL — Class 2 and LAPL privileges) (i) The holder of a medical certificate with an OPL limitation shall only operate an aircraft without passengers on board. (ii) An OPL for Class 2 medical certificates may be imposed by an AeMC or AME in consultation with the licensing authority. (iii) An OPL for an LAPL medical certificate limitation may be imposed by an AeMC or AME.
(e) Any other limitation may be imposed on the holder of a medical certificate if required to ensure flight safety.
(f) Any limitation imposed on the holder of a medical certificate shall be specified therein.
SECTION 2 - Medical requirements for Class 1 and Class 2 medical certificates
MED.B.005 General
(a) Applicants for a medical certificate shall be free from any: (1) abnormality, congenital or acquired; (2) active, latent, acute or chronic disease or disability; (3) wound, injury or sequelae from operation; (4) effect or side effect of any prescribed or non-prescribed therapeutic, diagnostic or preventive medication taken; that would entail a degree of functional incapacity which is likely to interfere with the safe exercise of the privileges of the applicable licence or could render the applicant likely to become suddenly unable to exercise the privileges of the licence safely.
(b) In cases where the decision on medical fitness of an applicant for a Class 1 medical certificate is referred to the licensing authority, this authority may delegate such a decision to an AeMC, except in cases where an OML is needed.
(c) In cases where the decision on medical fitness of an applicant for a Class 2 medical certificate is referred to the licensing authority*, this authority may delegate such a decision to an AeMC or an AME, except in cases where an OSL or OPL is needed.
* (??? legal basis ??? Regulation 1178: only “in consultation”, “referral” not provided; “transferal” only in AMC1 MED.B.001)
…
MED.B.050 Musculoskeletal System
(a) Applicants shall not possess any abnormality of the bones, joints, muscles or tendons, congenital or acquired which is likely to interfere with the safe exercise of the privileges of the applicable licence(s).
(b) An applicant shall have sufficient sitting height, arm and leg length and muscular strength for the safe exercise of the privileges of the applicable licence(s).
(c) An applicant shall have satisfactory functional use of the musculoskeletal system to enable the safe exercise of the privileges of the applicable licence(s). Fitness of the applicants shall be assessed in consultation with the licensing authority.
Disabled Pilots 19
2. Acceptable Means of Compliance and Guidance Material to Part-MED1
Initial issue - 15 December 2011
General
AMC1 MED.B.001 Limitations to class 1, class 2 and LAPL medical certificates
(a) An AeMC or AME may refer the decision on fitness of the applicant to the licensing authority in borderline cases or where fitness is in doubt.
(b) In cases where a fit assessment can only be considered with a limitation, the AeMC, AME or the licensing authority should evaluate the medical condition of the applicant in consultation with flight operations and other experts, if necessary.
(c) Limitation codes:
Code Limitation
1 TML restriction of the period of validity of the medical certificate
2 VDL correction for defective distant vision
3 VML correction for defective distant, intermediate and near vision
4 VNL correction for defective near vision
5 CCL correction by means of contact lenses only
6 VCL valid by day only
7 HAL valid only when hearing aids are worn
8 APL valid only with approved prosthesis
9 OCL valid only as co-pilot
10 OPL valid only without passengers (PPL and LAPL only)
11 SSL special restriction as specified
12 OAL restricted to demonstrated aircraft type
13 AHL valid only with approved hand controls
14 SIC specific regular medical examination(s) - contact licensing authority
15 RXO specialist ophthalmological examinations
(d) Entry of limitations
(1) Limitations 1 to 4 may be imposed by an AME or an AeMC.
(2) Limitations 5 to 15 should only be imposed:
(i) for class 1 medical certificates by the licensing authority;
(ii) for class 2 medical certificates by the AME or AeMC in consultation with the licensing authority;
(iii) for LAPL medical certificates by an AME or AeMC.
(e) Removal of limitations
(1) For class 1 medical certificates, all limitations should only be removed by the
licensing authority.
(2) For class 2 medical certificates, limitations may be removed by the licensing authority or by an AeMC or AME in consultation with the licensing authority.
(3) For LAPL medical certificates, limitations may be removed by an AeMC or AME.
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GM1 MED.B.001 Limitation codes
1 TML Time limitation
The period of validity of the medical certificate is limited to the duration as shown on the medical certificate. This period of validity commences on the date of the medical
examination. Any period of validity remaining on the previous medical certificate is no longer valid. The pilot should present him/herself for re-examination when advised and should follow any medical recommendations.
2 VDL Wear corrective lenses and carry a spare set of spectacles
Correction for defective distant vision: whilst exercising the privileges of the licence, the pilot should wear spectacles or contact lenses that correct for defective distant vision as examined and approved by the AME. Contact lenses may not be worn until cleared to do
so by the AME. If contact lenses are worn, a spare set of spectacles, approved by the AME, should be carried.
3 VML Wear multifocal spectacles and carry a spare set of spectacles
Correction for defective distant, intermediate and near vision: whilst exercising the privileges of the licence, the pilot should wear spectacles that correct for defective distant, intermediate and near vision as examined and approved by the AME. Contact
lenses or full frame spectacles, when either correct for near vision only, may not be worn.
4 VNL Have available corrective spectacles and carry a spare set of spectacles
Correction for defective near vision: whilst exercising the privileges of the licence, the
pilot should have readily available spectacles that correct for defective near vision as examined and approved by the AME. Contact lenses or full frame spectacles, when either correct for near vision only, may not be worn.
6 VCL Valid by day only
The limitation allows private pilots with varying degrees of colour deficiency to exercise the privileges of their licence by daytime only. Applicable to class 2 medical certificates
only.
- OML Valid only as or with qualified co-pilot
This applies to crew members who do not meet the medical requirements for single crew operations, but are fit for multi-crew operations. Applicable to class 1 medical certificates
only.
9 OCL Valid only as co-pilot
This limitation is a further extension of the OML limitation and is applied when, for some
well defined medical reason, the pilot is assessed as safe to operate in a co-pilot role but not in command. Applicable to class 1 medical certificates only.
10 OPL Valid only without passengers
This limitation may be considered when a pilot with a musculoskeletal problem, or some other medical condition, may involve an increased element of risk to flight safety which might be acceptable to the pilot but which is not acceptable for the carriage of
passengers. Applicable to class 2 and LAPL medical certificates only.
OSL Valid only with safety pilot and in aircraft with dual controls
The safety pilot is qualified as PIC on the class/type of aircraft and rated for the flight conditions. He/she occupies a control seat, is aware of the type(s) of possible incapacity
that the pilot whose medical certificate has been issued with this limitation may suffer and is prepared to take over the aircraft controls during flight. Applicable to class 2 and LAPL medical certificates only.
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12 OAL Restricted to demonstrated aircraft type
This limitation may apply to a pilot who has a limb deficiency or some other anatomical problem which had been shown by a medical flight test or flight simulator testing to be acceptable but to require a restriction to a specific type of aircraft.
14 SIC Specific regular medical examination(s) contact licensing authority
This limitation requires the AME to contact the licensing authority before embarking upon renewal or recertification medical assessment. It is likely to concern a medical history of which the AME should be aware prior to undertaking the assessment.
15 RXO Specialist ophthalmological examinations
Specialist ophthalmological examinations are required for a significant reason. The limitation may be applied by an AME but should only be removed by the licensing
authority.
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3. COMMISSION REGULATION (EU) No 290/2012 of 30 March 2012
amending Regulation (EU) No 1178/
ARA.MED.120 Medical assessors
The competent authority shall appoint one or more medical assessor(s) to undertake the tasks described in this Section. The medical assessor shall be licensed and qualified in medicine and have:
(a) postgraduate work experience in medicine of at least 5 years;
(b) specific knowledge and experience in aviation medicine; and
(c) specific training in medical certification.
ARA.MED.125 Referral to the licensing authority
When an AeMC, or aero-medical examiner (AME) has referred the decision on the fitness of an applicant to the licensing authority:
(a) the medical assessor or medical staff designated by the competent authority shall evaluate the relevant medical documentation and request further medical documentation, examinations and tests where necessary; and
(b) the medical assessor shall determine the applicant’s fitness for the issue of a medical
certificate with one or more limitation(s) as necessary.
ARA.MED.315 Review of examination reports
The licensing authority shall have a process in place to:
(a) review examination and assessment reports received from the AeMCs, AMEs and GMPs and inform them of any inconsistencies, mistakes or errors made in the assessment process; and
(b) assist AMEs and AeMCs on their request regarding their decision on aero-medical fitness in contentious cases.
ARA.MED.325 Secondary review procedure
The competent authority shall establish a procedure for the review of borderline and
contentious cases with independent medical advisors, experienced in the practice of aviation
medicine, to consider and advise on an applicant’s fitness for medical certification.
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Contact:
www.rolliflieger.de
Michael Amtmann
Schurzstraße 18
63743 Aschaffenburg
Tel. +49 6021 960685