When Medical Certification Stops Supporting Safety: A Growing Problem in Canadian Aviation
If you have read any of my previous articles, you will know that I usually write about mental health, or about how mental health issues affect pilots and aviation professionals.
This article is broader.
It addresses a troubling trend affecting a growing number of working pilots across Canada — a trend that has implications not only for pilot mental health, but for aviation safety itself.
Across multiple sectors of the industry, pilots are losing their medical privileges following a medical diagnosis, appropriately and in accordance with CAR 404. They receive treatment. Their condition stabilizes. They submit reports from qualified medical specialists stating that, in the specialist’s professional opinion, the pilot is fit to return to flight duties and would present a low risk to aviation safety.
And yet, despite meeting — and in some cases exceeding — the published medical standards, these pilots are repeatedly declared medically unfit.
Some have been unable to work for years.
In certain cases, options such as restricted medical certification — for example, two-crew operations with ongoing specialist follow-up — do not appear to be meaningfully considered at all.
This matters. And not just to the pilots affected.
What the Regulations Actually Say
Under CAR 404, a flight crew member must hold a valid medical certificate to exercise the privileges of their licence. When a pilot no longer meets the applicable medical standards, the regulator has both the authority and the responsibility to suspend or refuse a medical certificate.
That part is not controversial.
What is often overlooked is what comes next.
Standard 424 establishes that medical certification is not intended to be a permanent binary outcome. It is a risk-based system, designed to assess:
the nature and severity of a medical condition
response to treatment
functional impact
stability over time
and the actual risk posed to aviation safety
The Handbook for Civil Aviation Medical Examiners (TP 13312) reinforces this approach. It emphasizes that certification decisions are to be based on current functional capacity, supported by specialist assessment, and evaluated in operational context.
Where ongoing monitoring is appropriate, the framework allows for:
periodic follow-up reporting
operational limitations
and conditional or restricted certification where safety permits
In other words, the published system is designed to manage risk, not to eliminate it by default.
What Many Pilots Are Experiencing Instead
What many pilots report experiencing does not reflect that intent.
A pattern is emerging in which:
medical privileges are removed appropriately at the onset of illness
treatment is completed and stability achieved
specialist physicians provide clear, reasoned opinions supporting return to duty
and yet certification is not restored, often without transparent rationale or clearly articulated criteria for reversal
In practice, this results in prolonged or indefinite grounding, sometimes measured in years.
At that point, the distinction between “temporary medical unfitness” and “career-ending administrative outcome” becomes functionally meaningless.
Predictable Mental Health Consequences
Aviation has long carried stigma around health disclosure. A familiar expression in Canadian aviation goes:
“If you’re over 40 and you’re flying, you’re lying.”
It is dark humour — but it exists because the system has historically made honesty feel unsafe.
When pilots observe colleagues being grounded indefinitely despite following treatment plans and submitting appropriate medical evidence, the lesson learned is simple:
Disclosure carries unacceptable risk.
That belief:
discourages early reporting
delays treatment
increases concealment
and places pilots under prolonged psychological stress
This is not theoretical. It is a predictable human response to opaque and punitive outcomes.
And it directly reduces aviation safety.
The Overlooked Safety Cost: Loss of Experience
There is another consequence that receives far less attention.
Most pilots affected by this trend are mid-career or senior aviators. Collectively, they represent decades — and in some cases centuries — of operational experience.
When they are sidelined:
they are no longer mentoring junior first officers
they are not present for subtle decision-making during abnormal operations
they are not acting as informal error-catchers during routine line flying
Experience is not sentimental. It is a distributed safety asset.
Removing it does not remove risk.
It relocates risk elsewhere in the system.
In an era of increasing automation and reduced exposure to real-world edge cases, the loss of experienced pilots quietly erodes system resilience.
A Licensing Governance Issue, Not a Medical Dispute
Aviation medicine is often framed as a purely clinical matter. It is not.
Medical certification is part of the licensing system, and licensing is a governance function that must be:
consistent
transparent
auditable
and proportionate
Canada underwent an ICAO audit in 2023 that raised concerns related to personnel licensing oversight. While detailed medical findings are not publicly available, the audit reinforces that questions about licensing governance already exist.
This makes it even more important that medical certification decisions:
align with published standards
clearly explain deviations
and provide defined pathways for return to duty where safety permits
No Practical Legal Remedy for Individual Pilots
There is another uncomfortable reality.
Under Canadian law, individuals cannot sue Transport Canada for damages arising from regulatory decisions, even when those decisions result in loss of income or premature career termination.
For many pilots, the only remaining legal avenue is human rights litigation — a slow, adversarial, and psychologically costly process that few are positioned to pursue.
This imbalance further encourages silence rather than engagement.
Why This Should Concern Everyone in Aviation
This is not about lowering medical standards.
It is about ensuring that medical certification supports safety rather than undermines it.
A system that:
discourages disclosure
removes experience from the cockpit
increases stigma
and offers no predictable route back
…does not create safer aviation.
It creates quieter aviation.
A Call to Action
If you are a pilot, instructor, examiner, or aviation professional, please consider sharing this article with your colleagues. Open, informed discussion is one of the few tools available when systems become opaque.
If you are currently affected by this issue — if you have lost medical privileges, experienced prolonged delays despite meeting published standards, or been unable to return to duty after treatment and stabilization — you are welcome to contact me directly.
The purpose is not to single out individual cases or to pursue confrontation. It is to develop a clearer understanding of how widespread this issue may be across the industry.
Any communication will be treated with professional discretion and confidentiality. You are under no obligation to share identifying details, and no information will be published or shared without explicit consent.
If many pilots are experiencing similar outcomes, there may be strength in collective advocacy and coordinated lobbying, rather than individuals being left to navigate this alone. Systemic problems require systemic responses.
It would, of course, be far preferable for the regulator to address this internally — to realign practice with published standards, restore transparency, and rebuild trust in the medical certification process.
Aviation safety — and pilot mental health — depend on it.
