Flying with your head: what the new RAAC 67 says about mental health
In 1922, the minds of Argentine pilots were already being measured. One hundred and four years later, the new RAAC 67 regulates their mental health with more rules of exclusion than of care.
How to cite this work
Bentivegna, Leonel S. “Volar con la cabeza: qué dice la nueva RAAC 67 sobre salud mental” [Flying with your head: what the new RAAC 67 says about mental health], November 2026. https://www.leobentivegna.com/en/articles/volar-con-la-cabeza-raac-67
From El Palomar to RAAC 67
In January 1922, the Psychophysiological Unit opened at the Military Aviation School in El Palomar, directed by the physician Agesilao Milano. Using equipment brought from Italy, Milano measured applicants’ reaction times, attention and emotional control, convinced that for machines to fly safely one had to study the human being as much as the aircraft. According to local historians, it was the first unit of its kind in South America and the starting point of Argentine aviation psychology.
In January 2026, through Resolution 35/2026, ANAC (Argentina’s civil aviation authority) approved Edition V of Part 67 of the RAAC (the Argentine civil aviation regulations), the rule that defines who is psychophysically fit to obtain and keep an aviation licence. In this post I want to answer a specific question: what remains of that tradition of psychological assessment in the current rule, and how does Argentina compare with ICAO, Europe and the United States?
A clarification first. Selection is one thing (who has the profile to train as a pilot), psychophysical fitness is another (whether someone meets, at a given moment, the minimum requirements to fly), and mental health over the course of a career is a third (what happens when a condition appears with the licence already in hand). RAAC 67 regulates the second, but its rules end up affecting the other two.
What the rule says
The first relevant fact is where it comes from. Resolution 35/2026 states that it is appropriate to “adopt the text proposed by the SRVSOP”, that is, the regional regulation LAR 67 drawn up within the ICAO framework for South America. There was no public consultation: the resolution deemed the participatory rule-making procedure unnecessary.
On mental health, all four certificate classes share the same text (sections 67.205, 67.305, 67.405 and 67.505), organised into five clauses:
- History: the applicant must have no clinical history or diagnosis of eleven categories of disorder (mood, neurotic or stress-related, personality, substance-related, among others).
- Self-harm: a suicide attempt or self-inflicted injury “at any time in life”, clinically documented, is “disqualifying from the outset”.
- Depression: anyone being treated with antidepressants “must be considered psychophysically unfit”.
- Substances: the applicant must accept a screening test at all times.
- Follow-up: with a mental health history, periodic multidisciplinary assessment is required, with psychiatry and “technical support such as psychology”.
Reading the full rule reveals some nuances. On the one hand, there are ways back: lost fitness can be recovered “to the satisfaction of the medical assessor” (67.030), and anyone declared unfit can request reconsideration by ANAC’s medical board (67.200). On the other hand, the medical waiver is defined as applying “exclusively to physical requirements”, although the next sentence allows it to be considered for mental disorders that have already normalised (67.035), a contradiction the rule does not resolve.
And the psychologist? They appear as “support” for psychiatry. The rule requires medical centres to have equipment for the “psychological tests established in this regulation”, but it establishes none, and the only explicit periodic psychological assessment is for licence holders over 65. Paradoxically, the 2008 RAAC 67, still under the Air Force, included a cognitive, emotional, motivational and behavioural psychological assessment as part of the examination. Today, personality traits are left, according to the rule itself, to the “occupational psychology of the operator”: the El Palomar tradition has moved to the companies.
Argentina and the world
Comparing it with the major reference frameworks shows that RAAC 67 is more restrictive on mental health and did not incorporate the preventive tools the world adopted after the Germanwings accident (2015).
| Topic | RAAC 67 (2026) | ICAO | EASA (Europe) | FAA (USA) |
|---|---|---|---|---|
| Depression on antidepressants | Unfit; general reconsideration remains available | Unfit unless the assessor considers it unlikely to affect flying | Possible with psychiatric follow-up and limitations | Four antidepressants accepted since 2010, with special issuance |
| Psychological assessment | No dedicated step (except over 65) | No global standard | Comprehensive mental health assessment at initial Class 1 and psychological assessment by the operator | Not routine |
| Peer support | Not provided for | No mandatory standard | Mandatory for operators since 2018 | Recommended in 2024 |
Three differences stand out. The first is that ICAO, in Recommendation 6.3.2.2.1 of Annex 1, allows a person treated with antidepressants to be declared fit if the assessor considers it unlikely to interfere with flying. The RAAC takes the first half of that rule and omits the exception. This is no oversight: in 2009 the regional panel of experts refused to incorporate it because it regarded antidepressants as psychoactive substances, and although other panel members proposed revisiting this in 2012, the text that reached Argentina in 2026 looks more like the 2009 position.
The second is that, while ICAO applies the list of disorders insofar as they prevent safe flying, the RAAC places that condition only in the last item. Read literally, anxiety treated in adolescence could disqualify someone without any assessment of its current severity. The third is that Europe responded to Germanwings by combining more control with more support: a mental health assessment on entry and “proactive and non-punitive” peer support programmes at all airlines. Argentina adopted the control, but not the support.
The problem the rule does not see: avoidance
Every fitness rule changes the behaviour of those who will be assessed. In aviation this effect is well documented. In a survey of 3,765 US pilots, William Hoffman and his team found that 56% had avoided or delayed medical care for fear of losing their certificate, and around 46% had withheld information from their doctors. An anonymous Harvard study (Wu and colleagues, 2016) found that 12.6% of the airline pilots who responded met the criteria for depression and 4.1% had had suicidal thoughts in the previous two weeks, figures that rarely surface in a medical examination.
Germanwings is the extreme illustration: the co-pilot had consulted several doctors, none of them informed the airline and neither did he, partly for fear of losing his licence. That is why the final investigation report (BEA, 2016) recommended two things at once: clearer rules for lifting medical confidentiality when there is a risk to others, and confidential support programmes and loss-of-licence insurance so that reporting does not mean losing one’s livelihood.
RAAC 67 combines four features that, taken together, could feed avoidance in Argentina:
- disqualifying history with no time window (a suicide attempt documented at any age);
- unfitness due to antidepressant treatment, which may encourage people to stop an effective treatment;
- a waiver of ambiguous scope for mental health;
- and the treating physician’s obligation to pass relevant information to ANAC, which turns a psychological or psychiatric consultation into a space the pilot may not perceive as confidential.
On top of this there is a tension with our own law. Article 5 of Mental Health Law 26.657 states that a diagnosis “in no case authorises the presumption of risk of harm or incapacity”, something that can only emerge from an interdisciplinary assessment of the case. The RAAC, by contrast, presumes the risk from the history and places on the person the burden of proving otherwise. I am not a lawyer and I do not claim there is a legal contradiction, but there are two opposing logics that the resolution does not discuss.
The effect is paradoxical: those who stay silent are exposed to sanctions for omitting information from their sworn declaration, and those who speak up may be left out. Between these two extremes there is currently no confidential support of any kind. As far as I could establish, there is no data in Argentina on how many pilots or applicants avoid seeking help, and that absence is itself a finding.
To close
It would be unfair to read Edition V only as a step backwards: it brings order to a regime that had not been renewed for years, provides for multidisciplinary follow-up, keeps avenues for reconsideration and aligns with the region. The problem is that it aligns with the most conservative version of that regulation. From the El Palomar tradition it inherited the selective part, the idea that some profiles must be kept out, but not the part Milano considered central: studying the person in relation to the system, and preventing rather than excluding.
Some questions remain open that strike me as urgent:
- Should Argentina incorporate the ICAO exception for treated depression in remission?
- What psychological assessment, with what instruments and carried out by whom, should be required at all examination centres?
- Who should drive peer support programmes: ANAC, the airlines or the unions?
- How many Argentine pilots and applicants avoid seeking help or declaring a condition for fear of losing their fitness?
The last question frames the others. Until we have local data, any reform will keep debating the pilots who show up for the examination and not those who choose not to say what is happening to them.
Main sources
- ANAC, Resolution 35/2026 and RAAC 67, Edition V, January 2026 (sections 67.030, 67.035, 67.040, 67.055, 67.090, 67.200, 67.205 and Appendices B and C).
- Comando de Regiones Aéreas, RAAC 67, 3rd edition, 2008.
- Mental Health Law 26.657, 2010.
- ICAO-SRVSOP, study notes RPEL/5 (2009) and RPEL/8 (2012).
- ICAO, Annex 1, 6.3.2.2 and Recommendation 6.3.2.2.1 (presentation by A. Evans, 2009).
- EASA, new rules on aircrew mental fitness, 2018; FAA, mental health committee report, 2024.
- Baghino, D. et al., “Psicología aeronáutica: cien años velando por la seguridad operacional”, 2022.
- Hoffman, W., Bjerke, E. and Tvaryanas, A., “Breaking the pilot healthcare barrier”, 2022.
- Wu, A. C. et al., “Airplane pilot mental health and suicidal thoughts”, 2016.