Before every medical renewal I anticipate that something new and crazy will come out of ‘left field’ and, true to form, AvMed delivered again: The new question about the applicant’s ethnicity.
When CVDPA met with CASA to discuss AvMed’s return to the dark ages on colour vision deficiency, we touched on the unrelated issue of the ethnicity question. The PMO said that the question was about the assessment of the applicant’s cardio-vascular disease risk – ironically, another ‘CVD’ – and that the question was voluntary. When I asked what the consequences would be to the assessment if an applicant chose not to answer, I don’t recall getting a precise answer.
Last Tuesday I went to the DAME for my medical certificate renewal examination. At the point at which the DAME asked the new ethnicity question in the MRS, I said:
“I find that question offensive. What if I don’t answer it?”
The DAME said:
“Then we can’t finish the questionnaire and renew your certificate.”
There was nothing on the MRS screen stating or even hinting that the question is voluntary. And given that there was nothing on the MRS screen to that effect, it’s unsurprising that there was also nothing about the implications of not answering.
I am therefore not surprised at the DAME’s interpretation in the circumstances. The DAME proceeded to guess my ethnicity and answer the question for me.
The answer to the question, or a non-answer, must affect CASA’s assessment of the applicant’s cardio-vascular disease risk, otherwise asking the question would be a nonsense. In short, CASA will assess otherwise identical applicants (age, sex etc) as having different cardio-vascular risks on the basis of ethnicity alone. Therefore, the outcome must be that some applicants will, for example, be required to undergo tests that otherwise identical applicants would not be required to undergo, because of the applicant’s ethnicity.
My amateur research of Australian aviation accident and incident data does not indicate that pilots of particular ethnicities had a higher rate of accidents or incidents due to undetected cardio-vascular disease in the many decades before the ethnicity question was added to AvMed’s questionnaire. My amateur research of studies of cardio-vascular disease risk indicate that there are no biological differences between different ethnicities which cause different cardiovascular disease risk. There’s a correlation, because in many societies ethnic minorities end up in deprived socio-economic circumstances – unemployed, bad diet, substance abuse, inadequate or no medical care – which circumstances are the actual cause of cardiac disease. I’ll leave all that to the Australian Human Rights Commission to consider.
Meanwhile, my FOI request for access to documents recording how the different answers to the ethnicity question affect CASA’s assessment of applicants’ cardio-vascular disease risk returned no documents. Presumably the MRS was changed on ‘a nod and wink’, just like there’s no record of the decision - or of the implementation of the decision - to delete the offensive material from the appalling and now disappeared AvMed Form 420 about ASD and ADHD.
And just like there’s no record that CASA can find of the CAD ever having been determined as a ‘third tier’ colour vision test by someone with the power to do that, despite the CAD being used to destroy careers and career aspirations for years. The CAD has now been disappeared as a purported ‘third tier’ test, with no replacement, which means CASA is now preventing applicants with colour vision deficiency from complying with the CASRs which prescribe the means by which compliance with the colour vision criterion in the medical standard must be demonstrated. Read that twice: CASA is now preventing people from complying with CASR, by not doing its one job on CVD, which is to determine one or more tests that simulate an operational situation for the purposes of CASRs 67.150(6)(c) and 67.155(6)(c).
CASA’s response to my FOI request also revealed that the decision to add the ethnicity question was not made by any individual but was instead the “consensus” of senior medical officers at their annual group hug. There’s a novel approach to regulatory decision-making: Have a vote.
You couldn’t make this stuff up. But it’s what happens when regulatory authorities are left to their own devices for decades.