PPRuNe Forums - View Single Post - Reflections on the appointment of a new CASA PMO
Old 23rd Oct 2021, 06:21
  #10 (permalink)  
Clinton McKenzie
 
Join Date: Mar 2000
Location: Canberra ACT Australia
Posts: 721
Received 255 Likes on 125 Posts
Originally Posted by jonkster
There is a document on the ATSB site that addresses pilot incapacitation involved in accidents and incidents from 1975-2006
see: Pilot Incapacitation 1975-2006

...

Obviously CASA's strict medical policies make the risk of pilot incapacitation extremely small (0.19% of all accidents) because as we all know, pilots are 100% honest with CASA about their medical status and so CASA has been able to remove any pilot who is likely to be incapacitated, from the cockpit.

Imagine the carnage if they weren't so strict! Or heaven forbid, if pilots actually hid things about their medical status from their DAMEs! I know I tell them everything!

That is why every pilot uses their DAME as their GP so that nothing gets unreported.

Based on the paper, I think CASA's AVMED system would have a huge impact on flight safety if they regularly tested the standard of sandwiches served or snack machines used by flight crew given the largest % of incapacitation is from tummy upsets. This should be the next big area for CASA to be involved in.
I agree entirely, jonkster. Part of my submission to the CASA ‘Discussion Paper’ on ‘Medical Certification Standards’ in 2017, which submission is attached to my submission to the current Senate Committee inquiry, says:
An example of an absurd regulatory disparity caused by cognitive bias

The [Discussion Paper] notes an ATSB report which found that “[a]round 75 per cent of [pilot] incapacitation occurrences happened in high-capacity air transport operations … with the main cause being gastrointestinal illness…”. The related Table indicates that in around half of those cases the pilot discontinued duties for the remainder of the flight.

Let us assume that the referenced ATSB report was based on an analysis of a statistically significant number of incidents. Let us also assume that pilot incapacitation creates material risks to aviation safety.

So far as I am aware, this is not a single syllable in the ever-growing volumes of civil aviation regulations that regulates the service of food to pilots of high capacity aircraft, before and during flight time.

The regulatory position is therefore this: A pilot who cannot pass one of the ‘tiers’ of colour perception tests is too ‘dangerous’ to be in the left hand seat at the front of a high-capacity international aircraft, despite evidence to the contrary, but it is acceptably ‘safe’ for a pilot with normal vision to be in that seat and to have been fed and be fed in a way that is not regulated by the civil aviation regulations, despite evidence that the most likely cause of him or her becoming incapacitated is gastrointestinal illness, with about a 50/50 chance of him or her then having to be removed from further duty on the flight.

The explanation for this absurd regulatory disparity is, I suggest, intuition tainted by cognitive bias. To the public, a sandwich and a glass of fruit juice are, intuitively, completely harmless. Contemplating a sandwich and glass full of fruit juice does not evoke thoughts of dreadful consequences. In contrast, to the public a pilot with a ‘vision deficiency’ must surely be a risk. When the dreadful consequences of a pilot with a ‘vision deficiency’ are contemplated, cognitive bias results in an over-estimation of the probabilities of the event occurring. However, an objective analysis of the absolute and comparative risks and probabilities supports precisely the opposite conclusion. On an objective analysis, the regulatory regime should put substantial focus on what the pilots of high-capacity aircraft are eating and no focus on CVD.

I should stress that I am not advocating for yet more civil aviation regulations to deal with the service of food to pilots. Regulations on the subject are not justifiable, given that pilots and operators of high-capacity aircraft are perfectly capable of understanding and putting in place strategies to mitigate gastrointestinal illness risk on their own initiative, and given the remote probabilities of the event and the controls that are in place if the event occurs.

However, precisely the same logic should apply to other risks, including medical-related risks, which are less probable and have lesser potential consequences for safety than incapacitation of the pilot of high capacity aircraft through gastrointestinal illness. Given the frequency and consequences of high-capacity pilot aircraft incapacitation due to gastrointestinal illness compared to other causes, there are lots and lots of those other risks, yet some of those other risks are the subject of regulatory micro-management.
I anticipate that Avmed will claim that the aviation medical certification process causes the extremely low probabilities of sudden pilot incapacitation for other medical reasons. For the reasons you have identified, that’s like saying the traffic lights turning green causes cars to move.

Last edited by Clinton McKenzie; 23rd Oct 2021 at 06:42.
Clinton McKenzie is offline