Fatigue, alcohol, medication: the pilot's fitness
A single sentence of the regulation carries this whole subject, and the examination almost never asks about its first half. People remember alcohol; the text lists five other causes of unfitness right after it.
Key points
- Point UAS.OPEN.060(2)(a) prohibits the remote pilot from performing duties under the influence of psychoactive substances or alcohol, or when unfit to perform his tasks due to injury, fatigue, medication, sickness or other causes.
- No blood alcohol level is set by the European regulation. It is not a threshold not to be exceeded, it is a prohibition on performing duties: reasoning as you would behind the wheel means looking for a figure that does not exist.
- The second half of the sentence is the forgotten one: injury, fatigue, medication, sickness. An antihistamine that causes drowsiness falls squarely within it, even if you do not feel impaired.
- GM1 UAS.OPEN.060(2)(a) defines ‘other causes’ as any physical or mental disorder, or any functional limitation of a sensory organ, that would prevent the operation from being conducted safely.
- No medical certificate is required in the ‘open’ category: fitness rests entirely on self-assessment. It is one of the rare points where safety depends on being honest with yourself, and fatigue is precisely what impairs the judgement one makes of one's own fatigue.
- The prohibition targets the person performing the duties of remote pilot. It is delegated neither to an observer, nor to the team, nor to an automatic mode.
- The only response provided is a decision, not a setting: do not take off, or discontinue. Point UAS.OPEN.060(2)(b) indeed provides for discontinuing as soon as the operation poses a risk.
The trap. Any question offering a numerical blood alcohol level is offering a wrong answer: the European regulation contains none. It lays down a prohibition on performing duties, which the remote pilot himself has to assess.
Source
Implementing Regulation (EU) 2019/947 (CELEX 02019R0947, consolidated on 01/05/2025), Annex Part A, points UAS.OPEN.060(2)(a) and UAS.OPEN.060(2)(b); GM1 UAS.OPEN.060(2)(a) and UAS.SPEC.060(1)(a) (ED Decision 2019/021/R)