It's worth emphasising that although NZ CAA led the way with the introduction of the OCVA in 2019, this was not as a result of their AvMed unit. In fact, their PMO diametrically opposed any form of practical testing and according to CASA, the NZ AvMed unit still disagrees with the OCVA. Rather, we can be fortunate that the NZ CAA Director at the time and the Panel that was tasked with reviewing all the submissions and presentations from various experts (including medically and operationally) took an unbiased view and considered the facts:
NZ CAA - Report of the Colour Vision Deficiency General Direction Assessment Panel
15. ...In answer to a question regarding the reasoning behind the flight restrictions for a pilot who is CVD, the PMO answered that the “restrictions are historical”. This is a key issue for the Panel’s deliberations particularly in relation to the risk posed by a pilot with CVD, the different operational environments pilots operate in, and who should be determining restrictions to which a pilot is to operate.
16. The PMO also commented that he thought practical flight tests are unreliable. In the Panel’s opinion a flight examination has the same status as a medical examination in ensuring that a pilot is not a threat to the public and renewing their privilege to fly.
51. A substantial theme to emerge from the body of submissions is that the current PMO is biased and prejudiced against CVD pilots (25, 50, 41, 51, 54). The GAA, in particular, is vehement in its opposition to the current PMO and his views: “The PMO appears to be mounting a crusade for global bureaucratic conformity from his office in New Zealand, while conveniently overlooking his previously published, strong desire for evidence-based decisions in aeromedical matters” (50).
53. The CVA likewise state that the stricter testing and restrictions appear to be based on the personal views of the PMO, rather than on evidence. It notes “the continued suitability of the PMO for his role in regulating clinical test methods and medical restrictions for CVD pilots is questioned” (25). It is also argued by the CVA that the PMO’s presentation at the Australian Society of Aerospace Medical Annual Scientific meeting in Brisbane in 2014 was prejudicial, unbalanced, objectionable, and factually inaccurate.
128. There is no strong link between the office-based examination of CVD and real world realities. Under the proposed GD, the assessment of interferes with or likely to interfere with is ascertained from office-based assessments only. This assessment cannot be made from office-based tests only and can only be determined by an in-flight practical test. While both aviation medicine and flight operations specialists will need to be involved in the development of protocols for in-flight testing, only a flight examiner or flight instructor will be in a position to assess the ability of a pilot with a CVD condition to operate an aircraft safely. Thus the effect that a CVD condition will have on the ability of a pilot to safely exercise the privileges of a licence is a flight operations issue, not a medical issue.
As highlighted by Arthur, it's also no surprise then that the former CAA Director and the Panel chose to give such little weight to their PMO's opinions, particularly when considering his obvious bias against CVD pilots - as evidenced in presentations that he delivered to several aviation medicine scientific conferences.
PMO Review Submission to NZ CAA
Despite the reasonably benign title, International Variation in the Assessment of Colour Vision Deficient Pilots, the presentation included a number of most disturbing slides including a plagiarized front page of The Times newspaper with a fabricated story which appears to be deliberately tailored to cast CVD pilots in a negative light.
Other slides containing false and misleading material in cartoon format were also displayed by the PMO, reflecting negatively on individuals with CVD. The public display of such humiliating and discriminatory material of this nature constitutes harassment of individuals with CVD.
The public display of similarly negative material about other minority groups would be unacceptable. It is particularly grave however that such material is being circulated publicly by the senior manager within CAA who is directly responsible for generating this GD, deciding the test and restrictions regimes that are applied to CVD pilots.
Aside from the use of misleading and falsified slides, the presentation contained factually incorrect text. It is not clear if this is due to a lack of knowledge on the part of the PMO or a deliberate intent to discredit CVD pilots.
Fortunately, the former CASA Director Shane Carmody also saw through this obvious bias from the AvMed zealots in both NZ and Australia at the time, when considering our position to adopt the OCVA here in 2020.
Lets hope that Ms Spence is also giving it the same consideration again currently.