AOPA comments for National Transportation Safety Board (NTSB) Safety Recommendations A-99-1 and A-99-2

May 2, 1999

Mr. Jim Hall, Chairman
National Transportation Safety Board
490 L’Enfant Plaza East, SW
Washington, DC 20594-2000

Dear Mr. Hall:

The Aircraft Owners and Pilots Association (AOPA), representing the aviation interests of more than 340,000 pilots and aircraft owners, has reviewed the National Transportation Safety Board (NTSB) Safety Recommendations A-99-1 and A-99-2 regarding airmen medical certification and G-tolerance during aerobatic flight. In the first safety recommendation, the NTSB calls for a restriction on all pilots with special issuance medical certificates due to a cardiac condition from engaging in aerobatic flight. The second recommendation places a similar restriction on pilots who are taking medication that reduces G tolerance. While these two recommendations may seem to represent common sense, the accident data cited by the NTSB in no way supports the conclusions of the safety recommendations or even indicates that the medical certification process currently employed by the Federal Aviation Administration (FAA) is flawed. In fact, it could be argued that the three accidents cited by the NTSB in support of its recommendations are entirely unrelated to the conclusion.

National Transportation Safety Board Safety Recommendations A-99-1 and A-99-2 cite three aerobatic accidents over a period of 17 years as the basis for imposing significant restrictions on aerobatic pilots. AOPA has examined each of the three NTSB accident reports in detail and will compare the circumstances of each accident to the conclusions drawn in the two safety recommendations below:

May 7, 1980—Olathe, Kansas (Accident Brief MKC80FA034)

Aerotek Pitts Special S2S collided with terrain at 1930 EDT while engaged in aerobatic flight maneuvers killing the pilot.

The NTSB safety recommendation cites this accident as a basis for restricting certain pilots from aerobatic flight. In the safety recommendation, it is stated that “the Board determined the probable cause of this accident to be the pilot’s preexisting heart condition, which made him more susceptible to the G-forces of aerobatic maneuvers.” We find this to be a very puzzling conclusion because a review of the NTSB accident report indicates that medical, pathological, and toxicological findings at autopsy were “of no significance to the accident.” The pilot held a regular issuance Class II airman medical certificate with no limitations. Witness statements in the accident report indicated that the pilot did not drink alcohol, did not smoke, and “exercised daily to maintain top physical condition.”

According to the NTSB’s own report, the pilot in this accident did not have the preexisting heart condition cited in the safety recommendation. The airman held a normal Class II medical certificate and was not taking any medication. From our point of view, this accident cannot possibly support the recommendation that airmen with special issuance medical certificates due to cardiac conditions or who are taking medication that reduces G tolerance should be restricted from aerobatic flight. In fact, this accident has no relationship whatsoever to Safety Recommendation A-99-1 and A-99-2.

If the NTSB were going to draw any conclusion for the 1980 Olathe accident relative to G tolerance, a recommendation might be issued to remind aerobatic pilots not to eat prior to engaging in aerobatic flight. In the accident report, a witness stated that the pilot completed eating dinner just prior to departing on the accident flight. An October 1982 study by the FAA Civil Aeromedical Institute titled “G Incapacitation in Aerobatic Pilots: A Flight Hazard” points out that postprandial state, or pooling of the blood in the abdominal organs following a large meal, can lower G tolerance significantly. The witness’ report concerning the timing of this flight may indicate that postprandial state was a contributing factor in this accident. However, there is absolutely no connection in this accident with the recommendations regarding special issuance medical certificates, cardiac conditions, or use of medication.

June 26, 1993—Concord, New Hampshire (Accident Brief NYC93FA127)

Boeing-Stearman PT-17 impacted the ground while performing aerobatics during an airshow killing both on board.

The safety board determined the probable cause of this accident to be a “loss of airplane control as the result of incapacitation.” A post-accident autopsy revealed severe atherosclerosis, 90-95 percent focal closure of the coronary arteries, “an old myocardial infarction scar,” and well-developed mature scar tissue indicating that the pilot had a long history of previous myocardial infarction as well as coronary artery disease. Had this condition ever been reported to the FAA, the pilot most certainly would have been required to undergo substantial cardiac evaluation and, had he passed, might have received a special issuance certificate. In all likelihood, however, such an advanced cardiac condition would probably have precluded medical certification at all. The fact that the pilot held a regular issuance Class II medical certificate indicates that the heart condition was never reported to the FAA or the aviation medical examiner (AME).

Failure on the part of an airman to report preexisting medical conditions on the airman medical application does not represent a failure of the FAA medical certification process. Further, neither of the NTSB safety recommendations would have had any bearing on this accident because the pilot did not hold a special issuance medical certificate, had not reported a cardiac condition to the FAA, and was not known to be taking any medication that could reduce G tolerance. Had the airman reported a cardiac history to the FAA on the medical application, the severity of his existing heart condition would likely have prohibited him from being eligible for an airman medical certificate and thus any form of aerobatic flight in the first place.

September 6, 1997—Camden, South Carolina (Accident Brief ATL97FA134)

North American T-6-SNJ5 experienced loss of control while conducting aerobatic maneuvers and subsequently collided with terrain, killing both on board.

This is the only accident of the three cited that actually involves a pilot with a special issuance medical certificate due to a cardiac condition. However, the only reported medication being taken by the airman was 5 grains of aspirin daily. While the airman involved in the accident partially fits the profile to which the NTSB safety recommendations in question are targeted, there are a number of extenuating circumstances surrounding this 1997 aerobatic accident that bring into question the relevance of the recommendations to this particular accident.

For the recommendations concerning cardiac conditions and the taking of medication to have any relevance to this accident, one has to be certain that the accident was in fact the result of a G-induced loss-of-consciousness (G-LOC) incapacitation. The NTSB accident report indicates that witnesses observed the aircraft in a 60- to 70-degree bank when they heard the airplane engine “begin missing.” Within 10 seconds, the engine quit, airspeed deteriorated, and the aircraft entered a spin to the ground. It is somewhat difficult to draw a link between G-LOC and an engine failure. However, even if a G-LOC was somehow responsible for the engine failure that led to the accident, the pilot in command of this aircraft never should have held a medical certificate in the first place.

According to the NTSB accident report, post-accident toxicology tests revealed the presence of Fluoxetine, Norfluoxetine, Cimetidine, and Diltiazem in the pilot’s system. None of these medications were reported to the FAA on the airman medical application, and only the “aspirin 5 grains daily” appeared in the medical records. It is possible that the combination of Cimetidine and Diltiazem could have resulted in a lowered blood pressure and slowed heart rate, lowering G tolerance. However, one medication (Fluoxetine) found in the pilot’s system would have been strictly disqualifying for a medical certificate of any kind had it been reported to the FAA as required under the regulations. Fluoxetine is an anti-depressant known to cause anxiety, drowsiness, nervousness, insomnia, and dizziness. Sold under the trade name Prozac, Fluoxetine is a strictly disqualifying medication under the FAA medical certification process. While some of the circumstances surrounding this accident can be made to fit the context of the safety recommendations, we believe the real issue in this accident is the failure on the part of the airman to report to the FAA the cocktail of medications he was taking.

The FAA 8500-8 Airmen Medical Certificate Application Form specifically requires a reporting of all preexisting medical conditions and medications being taken by the applicant. The penalty for withholding or presenting misleading information is suspension or revocation of the airman’s FAA certificates and ratings. While there are stiff penalties for withholding or falsifying medical application information, the medical certification system is not designed to police the efficacy of information provided by the airmen. Rather, it is designed to screen applicants for gross pathology that could unacceptably jeopardize the safety of airmen, passengers, or persons and property on the ground. Given the extremely low incidence of medical incapacitation-related accidents industry wide, it is clear that any additional restrictions on medical certification are unwarranted.

AOPA concedes that it is possible that sometime, somewhere, there may have been a G-LOC accident that might have been prevented by the imposition of restrictions similar to those outlined in Safety Recommendations A-99-1 and A-99-2. However, the three accidents used to justify these recommendations do not support the conclusions reached by the NTSB. Even if several examples of accidents that better support the recommendations could be found in the database, AOPA does not believe they would warrant significant restrictions being placed on the more than 35,000 pilots who have a cardiac condition or take medication for the treatment of high blood pressure.

The incidence of medical incapacitation is very rare among the pilot population. It is even more statistically unusual among aerobatic pilots. The low incidence of medical incapacitation versus decades of safe flying experience by tens of thousands of airmen simply does not support the need for new regulation or restriction. AOPA urges the board to withdraw Safety Recommendations A-99-1 and A-99-2 on the basis that the recommendations are unsubstantiated by operational experience and would not prevent the very accidents they were designed to address.

We appreciate your time and consideration of this matter and stand ready to assist you or your staff in further examining these safety recommendations.

Respectfully,

Dennis E. Roberts
Vice President
Government and Technical Affairs

February 1, 1999