Let’s assume there must be a POB and MTOW and other limits ‘linked’ with compliance with differing medical standards. The paradigm problem is that Avmed is not competent to make the decision as to where those limits are set. Avmed is competent only to express an opinion as to the risks and consequences, for an individual, of various medical conditions. For example, individuals who are blind are not able to… Individuals with this condition are at X% risk of sudden incapacitation.
It is axiomatic that, for example, the sudden incapacitation of a pilot will put at dire risk the 2 POB on board an aircraft with a maximum seating capacity of 2, the 4 POB on board an aircraft with a maximum seating capacity of 4, the 6 POB on board an aircraft with a maximum seating capacity of 6 and so on. Ditto for the potential damage done by steadily increasing MTOW of the aircraft being flown.
But there is no medical literature which ‘plots’ the varying levels of the risk of a pilot’s sudden incapacitation against the numbers of persons and the value of the property put at risk by that sudden incapacitation. CASA Avmed has no expertise and no qualifications to decide that 2 but not 4 people should be put at risk by medical condition X.
And let’s consider those very large trucks and buses the sudden incapacitation of the drivers of which will put ‘lots’ of people and property at risk. Strangely, they’re all sharing the highways in close proximity to vehicles whose drivers don’t meet the truck / bus driver medical standard and could bring the adjacent truck or bus undone with the next munch on a fat burger. And so it is aviation. Somehow it’s not ‘safe’ for a pilot without a CASA-issued medical certificate to fly an aircraft over 760kgs or with any passengers, but it is ‘safe’ for that pilot to share the circuit and the airspace in the vicinity of an aerodrome in 'G' with a 737 full of passengers.
The whole Part 67 ‘review’ and TWG process is fundamentally misguided. There’ll be a bunch of high-sounding rhetoric, the output of which will be the usual intuition-driven, cognitive bias-driven and interest group-influenced illogical mish-mash. That’s why there are substantially differing medical standards and operational limits applied in like aviation circumstances across the world. The worst examples are in countries whose governments leave their Avmed branches to their own devices.