With the provisions of EASA ‘Rule Making Task.0700’(RMT.0700) about to find their way into EU legislation sometime this year, operators, regulators and other stakeholders will face a number of challenges, especially when it comes to proper implementation of the provisions related to Pilot Support, especially Peer Support.
The currently anticipated deadline for implementation of 24 months should in theory give ample time for both operators and regulators to prepare, especially considering that principles surrounding Peer Support Programmes have been known and actively promoted for the last 18 months.
Before we look closer at the challenges faced by the industry, however, we believe that we should congratulate the European Aviation safety Agency (EASA), the EU Member States and the EU for taking the bold step of mandating Pilot Peer Support and defining clear standards based on industry best practices.
It is an important point to note that medical and safety experts do not expect that the implementation of a Peer Support Programme – nor any of the other measures proposed in ‘RMT.0700’– can guarantee that a «black swan» event like the Germanwings tragedy will never happen again. However, they are convinced, as we are, that with a Pilot Peer Support Programme we have the tools at our disposal to collectively address safety hazards related to mental health issues, such as caused by life- and job stresses, fatigue, and/or substance dependency and abuse. Pilot Peer Support Programmes are considered to give the best possibility that pilot’s mental health problems will not reach a stage where psychiatric disorders or long-term unfitness occur, and the evidence from the few existing Peer Support Programmes supports this.
Nevertheless, a number of challenges need to be overcome before we will have effective Peer Support Programs running Europe-wide.
Perhaps the biggest challenge is that not all stakeholders are convinced that Peer Support – as EASA foresees it – is in their best interest, or feasible for them. Indeed, being used to prescriptive regulation so far, we now will have to get used to a regulation that mentions «trust» and open cooperation between stakeholders as a key requirement to implementation. Basically, for Peer Support to work effectively, «box-ticking» both in the operational implementation and in an authority’s oversight will not be enough.
There might be a tendency by some in the industry to have «something on paper», to get it approved by their oversight authority, and then to put minimum effort and resources into it. Some authorities might also either be resistant or simply not have the expertise and resources to move away from the «traditional ways» and become more pro-actively involved on Peer Support oversight.
A big task will be on EASA to encourage the national authorities to understand the goals and basic principles that make Peer Support work as well as provide the resources, coaching and support to those authorities not yet familiar with Pilot Support systems. Equally, EASA can facilitate best practice exchange between authorities, to benefit from the know-how and experience of those authorities that are already more advanced on their way towards Peer Support.
Making Peer Support a success will also require a significant change in mentality – from all stakeholders. Regulators and operators will need to forfeit some of the control over the system. That will certainly be a leap of faith and will not happen overnight.
Another challenge will be that whenever new regulatory concepts are introduced one can expect all sorts of consultants and «experts» flooding the market and offering «their» quick fix solution to operators.
Peer Support will be no different.
However, most of these commercial solutions are unlikely to match their promises to reality. This is because Peer Support Programmes are so reliant on trust between parties, strict enforcement of confidentiality, as well as on open co-operation between stakeholders – including the pilot representatives and, most importantly, the crew members themselves. Intimate knowledge of the organisation’s internal culture is therefore one of the main pillars for setting up an effective and successful programme. We believe that commercially offered «quick fixes» will probably fail – unless they properly include all relevant parties and defer to their knowledge of the organisation.
EPPSI – the European Pilot Peer Support Initiative – was created in order to mitigate the proliferation of ineffective solutions and to prevent the need to ‘reinvent the wheel’, by creating a platform where interested and expert stakeholders can meet to exchange best practices and «Do’s and Don’ts» based on first-hand experience.
The four founding organisations ESAM, EAAP, ECA and Stiftung Mayday as well as Mayday Italia are committed to keep EPPSI a non-profit organisation, dedicated to the sharing of expertise to make Peer Support in Europe a success.
Despite all of our best intentions and efforts, however, the road to Peer Support will be a long, winding and uphill struggle with many of us taking wrong turns and dead-ends at times. We will see, along the way, probably unwarranted breaches of confidentiality, unsuccessful therapies, operators and regulators overstepping their mark by letting people go or revoking medicals; and each one of these instances will test our ability to trust each other and might jeopardise the workings of these programmes.
Each time we will need to find the resilience to and the courage to look beyond and learn from our mistakes and steer the programme back on track. Each time, hard won trust in the programmes might be jeopardised and will need to be regained under increasing efforts.
Finally, perhaps the major challenge might well be with the very people Peer Support Programmes are designed to help – the crews at the front end. One of the biggest efforts of this endeavour will be to gain their trust in the system. Making it acceptable, as a pilot, to show «weakness» by admitting not only to oneself but also to one’s peers that one needs help, seeking that help actively and putting one’s faith (and career) into the hands of these Peer Support Programmes will perhaps need the biggest leap of faith of all.
The change in mentality to make it not only acceptable, but also normal and routine to take that step to seek help might hopefully not require a generation’s time; however, it might realistically take a number of years to become widespread behaviour.
Therefore, we need to realistically manage our expectations and acknowledge that it is up to all of us, EASA, regulators, operators, professional associations and others to put our collective efforts into creating an environment that is favourable to trustworthy and effective Peer Support Programmes.
The EPPSI Board firmly believe that good, well-run Peer Support Programmes make a significant difference to the industry in terms of safety. Pilots are human like everyone else: identifying potential mental health problems early and away from the aircraft, and then offering appropriate support and treatment, can only be a good thing.
The next 24 months will be crucial in addressing the challenges of turning the concepts of RMT.0700 into reality – but then, what makes our industry stand out is that it has never shied away from a challenge because it is too big.
The EPPSI Board
Captain Paul Reuter European Cockpit Association (Chairman)
Captain Uwe Harter Vereinigung Cockpit
CaptainDave Fielding British Airline Pilots Association
Professor Robert Bor European Association for Aviation Psychology
Drs Ir André Droog European Association for Aviation Psychology
Dr Med Ries Simons European Society of Aerospace Medicine
Dr Med Kevin Herbert European Society of Aerospace Medicine
Captain Dr Gerhard Fahnenbruck Stiftung Mayday
Captain Hans Rahmann Stiftung Mayday
Dr Francesca Bartoccini Mayday Italia