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					International Civil Aviation Organization (ICAO)                                                            12/09/2006 01:46 PM




                                                                                                            AN-WP/8074
                                                                                                                Appendix B

                                                           APPENDIX B

                            COMMENTS OF STATES AND INTERNATIONAL ORGANIZATIONS
                                 IN RESPONSE TO STATE LETTER AN 5/16.1-05/17

 REFERENCE:                       Attachment A, pages A-2 and A-3

                               STATES AND INTERNATIONAL ORGANIZATIONS' COMMENTS

 Agreement with comments

 Argentina
 (Note.— See appropriate partial language version of this AN-WP for original text.)

 The Argentine Aeronautical Authority, through this Representation, expresses its “agreement with comments”, to
 wit:

 1)          We believe that the increase in the upper age limit for pilots should be introduced in two phases:

             a) First phase: Increase the age to 63.

             b)     Second phase: Increase the age to 65, with a requirement to carry out the medical tests described in
                   Attachment A to this letter.

 Additional Information

 1)          We believe that a medical fitness could be certified up to the age of 63, provided that the following
             conditions are met:

             a) There is no medical history of chronic, metabolic, cardiovascular and/or neuropsychiatric illness.

             b) There has not been any aviation accident and/or incident within the preceding 5 years in which human
                factors related to the pilot have been involved.

 2)          The medical examination shall also meet the following requirements:

             a) A semi-annual examination, consisting of:

                      •    Complete neuropsychiatric exam with electroencephalograph, ultrasound scan of blood vessels in
                           the neck, Rey complex figure test, MSG test, Weschler test.

                      •     Clinical cardiological examination with a graduated ergometric test, echocardiogram, digital
                           rectal exam.

                      •    Laboratory: complete set of routine tests including creatinine, lipid profile, hepatogram, PSA,
                           complete test for occult blood in feces and urine.

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                      •     Ophthalmological examination, including the fundus.

                      •     Audiometry within normal parameters.

 Canada

 Canada is in agreement with comments.

 Canada would like to see the age restriction removed entirely as the Canadian Charter of Rights and Freedoms,
 Article 15, makes limitations based purely on age, discriminatory. Canada currently does not curtail the privileges
 of pilots who have attained their 60th birthday. Canada has no objections to pilots who are 60 years of age or
 older, holding a medically valid ICAO Contracting State licence, from flying foreign registered aircraft within
 Canadian airspace.

 Canada would like to bring your attention to the inconsistency between 2.1.10.1 and 2.1.10.2. In paragraph 2.1.10.2
 it appears there is a technical error. In order to be a co-pilot, one must fly a two-crew aircraft. Therefore, the
 reference to 60 years should not apply as one cannot act as co-pilot unless there is a pilot-in-command. Canada
 recommends the following wording:

         2.1.10.2 Recommendation. — A Contracting State, having issued pilots licences, should not permit the
 holders thereof to act as a co-pilot of an aircraft engaged in international commercial air transport operations if
 the licence holders have attained their 65th birthday.

 This amendment will not change the fact that Canada has filed a difference to 2.1.10.

 Czech Republic

 We propose to leave “pilot” alone instead of “pilot-in-command” in Provision 2.1.10.1 and to cancel
 Recommendation 2.1.10.2 because of no upper age limitation for co-pilots at all.

 Ethiopia

 (I)          In accordance with our Technical Directive Chapter 5.1 Personnel Licensing (Pilots), we have raised the
             upper age limit to 65 years effective 10 March 2001 and ever since, it is per the revised age limit that our
             captains are exercising the privileges of their licence.

 The content of the amendment as per our directive is as follows:

             (1)              Subject to paragraph (2) below, no pilot shall act as pilot-in-command or co-pilot of any
                          commercial air transport aircraft required to be operated with a co-pilot after he attains the age of
                          60 years, unless the other pilot is below the age of 60 years.

             (2)            No pilot shall at any time after he attains the age of 65 years, act as pilot-in-command or co-pilot
                          of any commercial air transport aircraft required to be operated with a co-pilot.

             (3)          Pilots of commercial air transport aircraft certificated for single pilot operation shall be limited to a
                          maximum age of 65 years.

 This revised age limit has been notified to ICAO accordingly.

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 (II)           For your information Annex 1 specifies medical fitness examination to be made every 12 months for
             airline or commercial pilots whose age is below 40 years, and reduced to 6 months if above 40 years of
             age.

 Medical fitness examination as per our Technical Directive pertaining to the above is made every 6 months for
 both groups of pilots, i.e., be they below or above 40 years.

 Finland

 Finland wishes to follow the JAR-FCL regulations concerning this matter and is proposing that the following
 wording of JAR-FCL should be used in the ICAO Annex 1:

             (JAR-FCL 1.060) Curtailment of privileges of licence holders aged 60 years or more

             a) Age 60 to 64. The holder of a pilot licence who has attained the age of 60 years shall not act as a pilot
                of an aircraft engaged in commercial air transport operations except:

                        1) as a member of a multi-pilot crew and provided that,
                        2) such holder is the only pilot in the flight crew who has attained age 60.

             b) Age 65. The holder of a pilot licence who has attained the age of 65 years shall not act as a pilot of an
                aircraft engaged in commercial transport operations.

             (JAR-FCL 3.105) Period of validity of medical certificates
             (see Appendix 1 to JAR-FCL 3.105)

             a) Period of validity. A medical certificate shall be valid from the date of the initial general medical
                examination and for:

                         1) Class 1 medical certificates, 12 months except that for holders who have passed their 40th
                   birthday the interval is reduced to six months.
 Hungary

 We advocate the extension of the age limit of 65 years for pilots engaged in multi-crew operations, but considering
 the retiring age in Hungary, in case of commercial air transportation we define the age limit as 62 years.

 Japan

 The government of Japan agrees with the proposed amendment to increase the upper age limit for pilots and would
 like to take this opportunity to introduce the status of upper age limit in Japan.

             1)           Since 1996, the GOJ has allowed airline pilots who are under the age of 63 to continue to work in
                        air transport services under the following conditions:

                        a) In multi-crew operation, the other pilot shall be under the age of 60;
                        b) A pilot over the age of 60 shall be subject to additional medical examinations every six
                           months.

             2)            Last summer, after carefully conducting a study on the feasibility of extending upper age limits
                        based on our experience and the recent progress of medical sciences, the GOJ changed the upper
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                         based on our experience and the recent progress of medical sciences, the GOJ changed the upper
                         limits from 63 to 65.

             3)             So far more than 450 airline pilots over the age of 60 have met the requirements of additional
                         medical examinations, and of these, more than 120 are currently working in the air transport
                         services. No airline pilots over the age of 60 have been involved in an accident.

 Luxembourg
 (Note.— See appropriate partial language version of this AN-WP for original text.)

 The proposed text is difficult to comprehend. In our national regulations, the following text appears (in
 compliance with the provisions of the JAR-FCL code).

 “Curtailment of privileges of licence holders aged 60 years or more

             a) Age 60 to 64.

 The holder of a pilot licence who has attained the age of 60 years shall not act as a pilot of an aircraft engaged in
 commercial air transport operations except:

                   (1)        as a member of a multi-pilot crew and provided that,

                   (2)        such holder is the only pilot in the flight crew who has attained age 60 or more.

             b) Age 65.

 The holder of a pilot licence who has attained the age of 65 years shall not act as a pilot of an aircraft engaged in
 commercial air transport operations.”

 Mexico
 (Note.— See appropriate partial language version of this AN-WP for original text.)

 Article 8 of our Licensing Regulations keeps the application of paragraph 1.2.5.2 at 12 months.

 Note: paragraph 1.2.5.2 of ICAO's Annex 1 refers to the validity of the report of medical fitness, that is the proof
 of medical fitness of the aeronautical technical personnel.

 We consider that the 12-month periodicity is not affected, given our experience in applying this criterion.


             ICAO proposal in Attachment A: 2.1.10, 2.1.10.1

 The proposal made by ICAO continues to limit the exercise of this activity to pilots over 60 years of age and up to
 65 years of age.

 Our country only has a limitation of up to 65 years of age for all airline pilots and/or commercial pilots, but no
 international operation is to be performed as pilot-in-command.

 The above is indicated in Articles 42, 57 and 65 of the Licensing Regulations.


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 If one really wishes to increase the upper age limit for pilots to 65 years of age, one would have to accept the form
 in which our country's regulations are structured, with the following statements:

             •          All airline or commercial air service pilots with an Unlimited Public Transport (TPI) pilot licence,
                        once they reach 65 years of age, change their licence to that of a commercial pilot. They are
                        therefore immediately disqualified from operating aircraft with a maximum take-off weight of over
                        5 700 kg as pilot-in-command (Article 42, 57 and 65 of the Licensing Regulations).

             •          Regardless of holding a commercial pilot licence, if they are 65 years of age or more, in no case
                        can they act as pilot-in-command on international flights or act as pilot-in-command on aircraft
                        with a maximum take-off weight of over 5 700 kg (Article 42 of the Licensing Regulations).

             ICAO proposal in Attachment A: 2.1.10.2

 In our country, commercial pilots are not limited to act as co-pilots in international commercial air transport
 operations once they reach 65 years of age. The limitation is only as pilots-in-command (Article 42 of the
 Licensing Regulations).

 According to the privileges of the commercial pilot licence, holders of such licences can operate aircraft with a
 maximum take-off weight of over 5 700 kg as co-pilots (Article 55, Section III, of the Licensing Regulations).

 Our comments would be to allow personnel with a commercial pilot licence to be able to act as co-pilots,
 regardless of reaching 65 years of age. We agree that it be handled as a Recommendation.

 New Zealand

 New Zealand has no objection to the amendment proposal as it brings the Annex 1 Standards into closer alignment
 with the New Zealand practice which is to issue “lifetime” licences.

 Over the age of 16 years, employment discrimination on the basis of age is prohibited in New Zealand by the
 Human Rights Act 1993.

 The exercise of pilot licence privileges is subject to the licence holder having an appropriate current medical
 certificate and having the required recent flight experience and having completed a biennial flight review of
 operational competency checks in the case of the Commercial Pilots Licence and the Airline Transport Pilots
 Licence.

 Romania

 We consider that the provisions of the amendment to Annex 1 should be applied to all commercial air transport
 operations, not only for the international operations.

 For the aircraft with a crew of two pilots, this amendment should be applied with no differences between the pilot-
 in-command and the co-pilot.

 Seychelles

 We would like to suggest that a minimum age for the other pilot be introduced such as 50 or 55 years, in order to
 have an acceptable buffer in the age group. This will reduce the possibility and risk associated where the other
 pilot is aged 59 years.

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 Sri Lanka

 There are pilots who have either reached the age of 60 years or at the verge of reaching that age employed by
 operators licensed by this administration. It is the view of this administration that such pilots should be allowed to
 continue the employment with the airline until the new standard comes into effect on 23 November 2006.
 Otherwise, they will have to retire as per the existing standard and re-join the airline when the proposed
 amendment comes into effect, which this administration considers would cause a break in competency skills. In
 the same direction, Sir Lanka intends to propose the retiring age up to sixty-two years as an interim measure until
 the new proposal comes into effect. Hence, it is suggested that ICAO initiate action to obtain concurrence of all
 the member States to permit pilots to continue in employment on reaching the age 60 until the new Standard is
 adopted and brought into effect.

 Thailand

 …we have additional proposal that pilots whose age exceeding 60 should, in operation, not be permitted to change
 their types of aircrafts.

 Togo
 (Note.— See appropriate partial language version of this AN-WP for original text.)

 Proposals from Togo for 2.1.10.1:

 2.1.10.1: A Contracting State, having issued pilot licences, shall permit the holders thereof to act as pilot-in-
 command of an aircraft engaged in international commercial air transport operations if the licence holders have
 attained their 60th birthday, or their 65th birthday, only in the case of operations with more than one pilot and
 where the other pilots are younger than 60 years of age.

 United Kingdom

 The United Kingdom does not see any significant flight safety advantage in preventing two over 60s from flying
 together, in comparison to an over 60 flying with a 59 year old, for example, the latter being permitted under the
 proposal.

                                                     SECRETARIAT'S COMMENTS

 Argentina would like to see the increase to age 65 years introduced in stages, firstly to age 63 and then to 65
 years. It wishes to permit operations over age 60 and up to age 63 if:

             a) there is no medical history of chronic, metabolic, cardiovascular and/or neuropsychiatric illness; and

             b) there has not been any aviation accident and/or incident within the preceding five years in which
                human factors related to the pilot have been involved.

 Having considered the comments of Argentina, the Secretariat is of the view that any pilot with the medical
 conditions mentioned in a) should be assessed individually and appropriate action taken. There is, in principle,
 little difference in the assessment of a pilot over 60 in comparison to someone under 60. Also, whilst medical
 factors can be included within the field of Human Factors, many Human Factors-related incidents and accidents
 are not necessarily related to medical aspects.


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 Argentina also believes the age limit might be extended up to 65 years if additional, extensive, medical
 examination requirements are undertaken. Whilst the Secretariat can understand why a regulatory authority may
 wish to add additional requirements to the routine examination in older pilots, it is not yet convinced that they are
 necessary in two-pilot operations when the upper age limit is 65 years. Many States do not impose such
 requirements in their pilots aged over 60 years and these States have not indicated in their responses to ICAO that
 to omit these additional examinations is detrimental to flight safety. It can be noted that an ophthalmological
 examination (which should include an assessment of the health of the fundus) and an audiogram, two items
 specifically mentioned as desirable in pilots over 63 years in the response by Argentina, are currently specified in
 Annex 1.

 The position of Canada is noted. The proposal concerning the Recommendation for co-pilots is in accord with
 the wording suggested.

 In respect of the comments from Ethiopia, the Secretariat takes the view that single pilot operations pose a
 particular flight safety risk, since an incapacitation of the pilot is likely to result in an accident, whereas in a multi-
 pilot environment, there is another crew member available to assume control. For this reason, it is unable to agree
 that the upper age limit for single pilot commercial air transport operators should be relaxed to 65 years.

 Finland, supported by Romania, wishes the wording of the Joint Aviation Authorities to be adopted. This would
 result in the same age limitation (65 years) being applied, as a Standard, to both pilots-in-command and co-pilots,
 whereas the proposal of a limit of 65 years for a co-pilot is formulated as a Recommendation only. The Secretariat
 considers that the additional responsibility associated with the duties of pilot-in-command justifies an age limit as
 a Standard, whilst, for the co-pilot, it should remain as a Recommendation.

 It is noted that the Czech Republic, in contrast, would like any reference to an upper age limit for co-pilots, even
 as a Recommendation, to be deleted.

 As pointed out by Luxembourg and Togo, the French version of paragraph 2.1.10.1 is not very clear. The
 Secretariat therefore proposes an alternative French translation.

 Seychelles suggests that when one pilot is above 60 the other should be no older than 50 or 55 years. However,
 the Secretariat believes that by requiring the other pilot to be under 60 years, the risk of a double incapacitation
 during a flight is adequately mitigated.

 Thailand is of the opinion that pilots over 60 years should not be permitted to change aircraft type. It is clear that
 some older pilots may find difficulty changing types, because the learning process becomes slower with increasing
 age, particularly when the transition is to a more complex type. However, this suggestion involves operational and
 training aspects, rather than those of licensing.

 The comments of Hungary, Japan, Mexico, New Zealand, Sri Lanka and the United Kingdom are noted.

                                                       ACTION PROPOSED

   Amend the French version of paragraph 2.1.10 as follows: “Un Etat contractant qui a delivré une licence de pilote
   autorisera le titulaire de cette licence à remplir les fonctions de pilote commandant de bord d'un aéronef qui
   effectue des vols de transport commercial international jusqu'à ce qu'il atteigne l'âge de 60 ans, ou de 65 ans, dans
   le cas de vols avec plus d'un pilote et l'autre pilote a moins de 60 ans. ”

 REFERENCE:                       Attachment A, pages A-2 and A-3


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                               STATES AND INTERNATIONAL ORGANIZATIONS' COMMENTS

 Disagreement with comments

 France
 (Note.— See appropriate partial language version of this AN-WP for original text.)

 France considers that the draft amendment to ICAO's Annex 1 has no medical or scientific basis and it has not in
 any way been proven that the pilot's age has any effect on aviation safety. France therefore states its wish, already
 expressed in the response to the ICAO questionnaire (SL AN 5/16.1-03/110 refers), that a serious and documented
 study be undertaken, covering both social and medical aspects and human factors, before considering any change
 in the ICAO International Standards and Recommendations on this subject.

 United States

 At some age, every individual reaches a level of increased infirmity leading to decreased reliability. That age will
 vary from person to person but cannot yet be predicted in a specific individual. While science does not absolutely
 dictate the age of 60 for commercial passenger pilot retirement, that age is within the age range during which
 sharp increases in disease mortality and morbidity occur. Clearly, there is a progressive anatomic, physiological,
 and cognitive decline associated with aging, albeit variable in severity and onset among individuals. There is no
 absolute, scientific formula that may be readily applied.

 It is indisputable that, as people age, they experience more illnesses and disorders, and suffer more cognitive
 decline. Cardiovascular disease rises with age, steeply, beginning between ages 55 and 65, and, though mortality
 has dropped since 1960, cardiovascular disease remains the most frequent cause of death in pilots and the general
 population. With this increased incidence of cardiovascular disease in the older population, the risk for unexpected
 events that could be a threat to safety of flight is increased. Cardiac events (e.g., heart attacks, sudden death)
 during flight have continued to occur in low but fairly consistent numbers over the years and have caused general
 aviation accidents.

 Other health conditions are known to increase in incidence or to become more complicated with aging. Many
 present greater difficulties of detection and risk assessment than do cardiovascular disease. Among these are
 cerebrovascular disease; malignancies; endocrine dysfunction; neurological disorders; psychiatric disorders,
 including depression; and decline in sensory and motor capabilities. There has been an increasing awareness of the
 more subtle adverse conditions affecting performance, such as those related to cognitive functioning.

 The “Age 60 rule” has served well as a regulatory limit in the United States. It remains the best determination that
 can be made of the time when a general decline in health-related functions and overall cognitive capabilities has
 reached a level where decrements in a pilot's performance may jeopardize safety. The “Age 60 rule” has been
 repeatedly reviewed to determine whether new and sufficient evidence exists to warrant a reconsideration of the
 regulation. Studies conducted to date do not present sufficient information that would address concerns about
 negatively impacting the current level of safety by changing the rule.

 The Federal Aviation Administration (FAA) has invited the public to provide comments on the viability of the
 “Age 60 rule.” The most recent comment period was opened in September 2002 in relation to a petition for
 exemption to the rule filed by a coalition of U.S. pilots approaching age 60. Nearly 7 000 comments were
 submitted during the month-long open comment period. Overwhelmingly, the commenters favored retaining the
 current “Age 60 rule.” They cited safety and medical issues most often as reasons for retention of the current
 rule.


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 Several U.S. Courts of Appeals have reviewed the “Age 60 rule” and studies related to the rule. Uniformly, these
 courts have denied petitioners' requests for relief from the rule. In September 2004, the U.S. Court of Appeals for
 the District of Columbia Circuit issued a Judgment refusing to review FAA's denial of a petition for exemptions
 from the rule. In May 2005, the U.S. Supreme Court refused to hear arguments on the matter.

 In recent years, the U.S. Congress has introduced, but has not enacted, several bills to revise the age limit for
 airliner pilots. In March 2001, a bill to modify the “Age 60 rule” to age 63 was drafted to be reported by the U.S.
 Senate Committee on Commerce, Science, and Transportation. Neither of those two bills was enacted. Most
 recently, legislation was proposed that would tie an age limit for air carrier pilots to Social Security legislation.

 Modifying the long-standing baseline of age 60 in the U.S. requires that the public be shown how such
 modification would maintain an equivalent level of safety. The “Age 60 rule” is a long-standing operational rule
 that pre-dates subsequent studies completed over the years. None of the studies completed since implementation
 of the rule provide satisfactory data that conclusively supports changing the rule. No protocols exist to reliably
 predict when or whether an over-age-60 pilot might experience a medical event that could jeopardize aviation
 safety.

 Venezuela
 (Note.— See appropriate partial language version of this AN-WP for original text.)

 At the XVI Assembly of the Latin American Civil Aviation Commission held in Rio de Janeiro, Brazil, from 8 to
 12 November 2004, within the high-priority agreement on the determination of the upper age limit for pilots, the
 National Civil Aviation Institute (INAC) did not support the modification of that age limit, in accordance with the
 provisions in our legislation and the international civil aviation standards which set 60 years of age as the upper
 age limit for individuals who are holders of international airline transport pilot licences.

 IFALPA

 The upper age limit for professional pilots has always been a controversial subject, as would be expected from a
 limit which seeks to determine a reasonable and justifiable “cut-off point” for commercial pilots. Numerous studies
 have been carried out over many years, and it has ultimately been determined that safety considerations and
 scientific research dictate that no change to the 60-year upper age limit is warranted at this time. We remain
 unconvinced by the studies cited in the proposal. In the last 25 years, operational research conducted by NASA and
 other international agencies on the effects of jet lag, fatigue and circadian disruption in long haul flying has
 consistently demonstrated that older pilots suffer more from physiological effects.

 The current limit is a safety-based standard. We know from our Member Associations that many airlines, as a
 result of the crisis that the industry has been experiencing for some years, have drastically reduced their pilot
 numbers and almost completely curtailed pilot training. As the industry, at least in some areas, is now once more
 experiencing expansion, pilot shortages are therefore beginning to appear. In addition, many States are also
 experiencing difficulties with pension funding, so raising the upper age limit for pilots therefore becomes attractive
 as a solution to both these problems. However, these issues ignore the safety standards which should be
 paramount. The ICAO Annex 1 age limit of 60 has stood the test of time and proven to be a sensible cut-off point
 and should not be changed for current economic, political or legal factors.

 Any changes made to SARPs must preserve or improve upon existing flight safety levels, and there is no evidence
 to suggest that increasing the upper age limit for pilots will achieve this requirement. Therefore, IFALPA believes
 that the upper age limit for pilots must remain at 60.

                                                     SECRETARIAT'S COMMENTS

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 France and IFALPA believe that there is no medical or scientific basis for changing the age limits in Annex 1.
 Whilst it is true that the scientific evidence for change is not conclusive, neither is the evidence for maintaining
 the current upper age limit and there are studies which demonstrate an improvement, or little change, in
 performance with increasing age in the range up to 65 years. Although the Secretariat agrees that, ideally,
 scientific ‘proof' should underlie any changes to the Annexes, it accepts the reality that such proof is sometimes
 difficult or impossible to obtain. The Secretariat believes that the evidence that is available, combined with the
 positive experience of Contracting States that have already raised the age limits above those currently in Annex 1,
 makes a strong case for increasing the age limit, as proposed.

 The Secretariat agrees with the United States that there is a progressive decline in functioning ability with
 increasing age, and that this differs amongst individuals in a way that is not predictable in any reliable way. The
 Secretariat cannot agree, however, that there are ‘sharp increases in disease mortality and morbidity' between age
 60 and 65 years. There is certainly an increase in morbidity and mortality in this age range but this reflects a
 progressive change with increasing age, rather than a sudden increase above age 60.

 The United States identifies the increase in cardiovascular disease with increasing age, which occurs in all ICAO
 Contracting States, and that the incidence of a first cardiovascular event increases progressively with increasing
 age. However, since the early 1970s incapacitation training has been mandatory in airline operations (see Annex
 1, paragraph 2.5.1.5 e)) and the Secretariat is unaware of any fatal accident in the last 25 years in a multi-pilot
 airline operation where cardiovascular incapacitation was cited as a causal or contributory factor. This is despite
 the fact (as mentioned by the United States) that in-flight cardiac events, including sudden death, continue to
 occur. This indicates to the Secretariat that the risk to flight safety from cardiovascular incapacitation is
 adequately contained by the multi-pilot environment and the requirement for incapacitation training. Further, the
 change in age limit does not apply to single pilot operations, where the risk is greatest, which will remain at 60
 years.

 It may well be the case that the ‘Age 60 Rule' has served well as a regulatory limit in the United States, as agreed
 by IFALPA. However as mentioned by the United States, such a limit is somewhat arbitrary since ‘science does
 not absolutely dictate the age of 60 for commercial passenger pilot retirement'. The Secretariat does not believe
 that it is possible to state with any certainty that 60 years of age is the time in a pilot's career ‘when a general
 decline in health-related functions and overall cognitive capabilities has reached a level where decrements in a
 pilot's performance may jeopardize safety'. In some individuals this may be the case, but the evidence from
 Contracting States that have introduced a higher age limit suggests that it is safe to continue operating as a
 professional pilot, in two-pilot operations, beyond 60 years.

 The United States indicates that it is required to show to the public how modification of the ‘Age 60 Rule' would
 maintain an equivalent level of safety and it does not feel that data are available to conclusively support changing
 the rule. However, the current ICAO Standard is long-standing and there have been three major changes since its
 introduction which should be considered. The general health of the population has improved, so that 60 to 64
 year-olds in many Contracting States are now less likely to suffer a sudden incapacitation than were their
 predecessors. Further, should an incapacitation occur in flight, incapacitation training has been introduced which
 mitigates the flight safety risk of such an event. The responses to the ICAO questionnaire on upper age limits
 (State letter AN 5/16.1-03/110 refers) indicated that sixty-four States permitted airline operations by pilots over age
 60, which was estimated to represent at least 15 000 pilot-years of experience. Nine States indicated that they do
 not impose any upper age limit on pilots licensed in their State.

 IFALPA believes that the older pilot may be more affected by the physiological effects of jet lag, fatigue and
 circadian disruption in long-haul flying, but the Secretariat is of the view that this is adequately mitigated by the
 two-pilot environment, with, for very long flights, one or two additional pilots to permit in-flight seat, or bunk,
 rest.

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 IFALPA argues that the upper age limit of 60 is a safety requirement and therefore should not be changed for
 current economic, political or legal reasons. In principle, the Secretariat is in agreement with this position and
 considers that the age limit should not normally be changed, or maintained, for reasons other than technical
 reasons related to flight safety. However, if desirable for social, economic or other reasons and if possible without
 adverse effect on safety, a change may well be considered. It has been found 83 per cent of States believe that an
 international age limit above 60 years would be appropriate for airline pilots.

 The purpose of simulator checks, line flying checks and regulatory health examinations is to contain the risk of
 pilot ‘failure' during the period of validity of the rating or medical certificate; it appears from available evidence
 that such checks do ensure adequate protection of flight safety for those aged under 60 years. The Secretariat
 knows of no reason to believe that they will fail to do so for those aged 60 to 64 years. Moreover, as stated by
 AsMA in response to State letter AN 5/16.1-03/110, dated 31 December 2003, there is insufficient medical
 evidence to support any restrictions based on age alone.

 The comments from Venezuela are noted.

                                                     ACTION PROPOSED

   No change.

                                                          — END —
                                                     APPENDIX A   (72.67 KB)




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