Medical certification of pilots during EU-Exit transition and recognition periods
The UK-EU trade deal includes agreements on air transport and aviation safety, which came into effect at 23.00 GMT on 31 December 2020 when the UK ceased taking part in the EU Aviation Safety Agency (EASA) and other EU institutions.
While the agreements involve some elements of continuity, they do not constitute a replication of the UK’s regulatory arrangements as part of the EASA/EU framework and many sections (including the aircrew regulation (1178/2011), of which PART.MED is a part) of the aviation and aerospace industries face changes after 31 December 2020.
Aeromedical Examiners (AMEs), Aeromedical Centres (AeMCs), and Occupational Health Medical Practitioners (OHMPs)
The Statutory Instrument produced by the UK Government relating to the aircrew and ATCO regulations inter alia includes a ‘recognition’ period during which EU licences (i.e., non-UK State of Licence Issue / SOLI), approvals and medical certificates will be ‘recognised’ for the remainder of their validity, or for up to two years, whichever is the shorter and provided they are not revalidated or renewed, expired, suspended or revoked.
During the UK ‘recognition’ period from 1 January 2021
From 1 January 2021, all AMEs, OHMPs and AeMCs for whom the UK was the Competent Authority, continue to be certificated to perform medical examinations for UK certificate applicants and issue UK PART MED medical certificates and cabin crew medical reports under UK law.
UK-certificated AMEs wishing to undertake EU medical examinations have to apply to an EASA member state for third country approval (and / or to EASA for AeMCs).
From 1 January 2021 until 31 December 2022, non-UK EU AMEs / AeMCs (and therefore the EU medical certificates issued – see below) are only ‘recognised’ by the UK if the AME / AeMC approval certificate was valid on or before 31 December 2020 and had not expired, been revalidated or renewed, been suspended or revoked when the medical examination was performed.
When performing such medicals for applicants with UK licences, EU AMEs will have to include a copy of their current approval certificate together with all the usual medical examination reports and tests to the UK CAA to prove that they are recognised to do the medical. Applicants should emphasise this to the AME, as non-compliance may result in the examination and certificate not being considered valid. Where possible the EU certificate issued and the examination reports should show the UK pilot reference number (e.g. 1233456A).
EU AME / AeMC approval certificates that expire during the two-year ‘recognition’ period and are renewed or revalidated will not be ‘recognised’ for the issue of UK medical certificates. From 1 January 2021, new or currently certificated EU AMEs / AeMCs need to apply to the UK CAA for approval to conduct UK medicals as a third country AME / AeMC.
EU OHMPs are not recognised and therefore any examinations and assessments performed by EU OHMPs after 1 January 2021 are not recognised.
After the UK ‘recognition’ period ends on 31 December 2022
From 1 January 2023 EU AME, EU OHMP and EU AeMC approval certificates will not be valid for undertaking UK PART MED medical examinations / assessments. Separate approval must be granted by the UK CAA to perform UK medicals.
During the UK ‘recognition’ period from 1 January 2021 to 31 December 2022
- UK was the UK State of Licence Issue (SOLI)
From 1 January 2021, all EU PART-FCL and EU PART-ATCO Licences and EU PART MED and EU PART ATCO MED medical certificates for which the UK was the EU SOLI are now deemed to be UK licences and UK medical certificates. They continue to be valid to fly G-registered aircraft. UK licences (apart from the LAPL) will continue to have ICAO privileges. They can continue to have medicals with UK-certificated AMEs.
If a UK licence / medical certificate holder (i.e., held a UK-issued EU licence / medical on 31 December 2020) becomes medically unfit or requires AME medical assessment after 1 January 2021, they must consult a UK-certificated AME (not EU-certificated AME) to take over their case for assessment and subsequent medicals. The UK-certificated AME will liaise with the UK CAA Medical Department as required.
UK medical certificates issued by UK-authorised AMEs after 1 January 2021 will no longer be legally valid for use with non-UK issued EU licences. They may only then be used for validation of UK pilot and ATCO licences.
- Non-UK EU State was the EU State of Licence Issue (SOLI)
It is the CAA’s understanding that medical certificates for which a non-UK EU State was the SOLI that were issued by a UK AME before 31 December 2020 will only be recognised as valid by the EU until their natural expiry, or the pilot / ATCO suffers a decrease in medical fitness (whichever is the sooner).
If an EU licence / medical certificate holder becomes medically unfit or requires AME medical assessment after 1 January 2021, they must consult an EU-certificated AME (not UK-only certificated AME) who will liaise as required with the relevant EU SOLI’s medical department.
After the UK ‘recognition’ period ends on 31 December 2022
From 1 January 2023 all EU licences and EU medical certificates will no longer be recognised for UK licences. Licence holders will need a UK PART FCL Licence and UK PART MED Medical Certificate to fly G-registered aircraft, and separately an EU PART FCL Licence and EU PART MED Medical Certificate for EU licence privileges (similar applies to ATCO licence holders with Class 3 medical certificates).
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