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1.2.4.9 Medical confidentiality shall be respected at all times.
1.2.4.9.1 All medical reports shall be securely held with accessibility restricted to authorized
personnel.
1.2.4.9.2.1 When justified by operational considerations, the medical assessor shall determine to
what extent pertinent medical information is presented to relevant officials of the Licensing
Authority.
It is important that medical confidentiality is respected at all times. Medical information is of a sensitive
nature and a person who has undergone a medical examination for issuance or renewal of his licence has a
right to expect that such information is kept confidential and disclosed only to medical officials. In many
States a separate medical section is established, either within the authority or attached to it. Medical
confidentiality is best assured when this medical section, where the reports from the medical examiners
are received and evaluated, is headed by a physician and has its own staff, its own channels of
communication, its own filing system, etc. If the medical section is a sub-part of another non-medical
section and thus shares office space, office staff, and files with that section, medical confidentiality
becomes untenable.
Safety Management
1.2.4.2 Recommendation.- From 18 November 2010 States should apply, as part of their State
safety programme, basic safety management principles to the medical assessment process of licence
holders, that as a minimum include:
a) routine analysis of in-flight incapacitation events and medical findings during medical
assessments to identify areas of increased medical risk; and
b) continuous re-evaluation of the medical assessment process to concentrate on identified
areas of increased medical risk
Note.– A framework for the implementation and maintenance of a State safety programme is
contained in Attachment C, Guidance on State safety programmes and safety management principles
is contained in the Safety Management Manual (SMM) 1 and the Manual of Civil Aviation Medicine
(Doc 8984).
For a number of years ICAO SARPs in Annex 11 and Annex 14 have required safety management
systems to be implemented by organizations responsible for air traffic services and aerodrome operations,
and more recently this has been extended to aircraft operators (Annex 6). Whilst incorporation of a safety
management system (SMS) is relevant to organizations providing services, a State safety programme
(SSP) is the equivalent process for the management of safety by the State. The SSP and SMS frameworks
are complementary, yet distinct.
Details on both the SSP and SMS can be found on the ICAO website, but since aeromedical safety is
primarily the responsibility of the Licensing Authority, it is considered that an SSP, rather than an SMS,
is applicable in the aeromedical area, with the Chief Medical Officer of the Licensing Authority assuming
responsibility for aeromedical safety.
The implementation of an SSP will be commensurate with the size and complexity of the State’s aviation
system, but needs to consider the following:
1) State safety policy and objectives
2) State safety risk management
3) State safety assurance
4) State safety promotion
Each of these topics is important for aeromedical safety, but the most important is considered to be State
safety assurance, in particular, safety data collection, analysis and exchange.
In the area of aviation medicine, as in other aviation-related disciplines, safety policy has often not been
based on objective evidence of good quality, and few Licensing Authorities analyse, on a routine basis,
in-flight incapacitations, or the medical findings from routine medical assessments. Without such basic
data, regulatory policy is likely to be based primarily on expert opinion – and such opinion varies from
specialist to specialist and from State to State.
Significant resources are devoted to the aeromedical assessment process, and to applying aeromedical
policy. It is important that such resources are utilized in the most cost-effective manner, and the
application of safety management principles is one method of encouraging this, which has been
demonstrated to be effective. An international review has been published in the journal ‘Aviation Space
and Environmental Medicine’.2 and is recommended reading for this subject. It is reprinted in Appendix 1
to this chapter, with permission of the journal’s editor.
Flexibility
1.2.4.8 If the medical standards prescribed in Chapter 6 for a particular licence are not met, a
Contracting State shall not issue or renew the appropriate Medical Assessment unless the
following conditions are fulfilled:
a) Accredited medical conclusion indicates that in special circumstances the applicant’s failure to
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