Here is what I have sent to Senators Fawcett and Xenophon, Warren Truss and my local member. In case any of you need any ideas of where to start...
Dear <MP of choice>
I am writing to express my dismay at the belligerent attitude of CASA to pilots with defective colour vision. As you are aware, CASA has been embroiled in a case before the Administrative Appeals Tribunal regarding the removal of privileges from a professional pilot on the basis of that pilot’s defective colour vision. There is no evidence to support the case made by CASA that pilots with defective colour vision pose a risk to safety, and indeed none has been presented to date by CASA. Despite reassuring the senate committee that there was no plan to change the rules regarding the way in which pilots with defective colour vision were to be treated, CASA has issued letters to all Air Operators’ Certificate (AOC) holders and all Designated Aviation Medical Examiners (DAMEs) this week that these pilots were potentially a threat to safe aviation operations, and their continued flying privileges should be scrutinised and re-considered. Additionally, they have now enforced rules which will deny pilots seeking an initial issue of a medical certificate appropriate privileges to operate under conditions other than Visual Flight Rules (VFR), by day only, if they fail the colour vision tests prescribed by CASA. This is despite decades of incident-free operations by hundreds of colour-defective pilots on Australian licences, and is a reversal of decisions made over 20 years ago that allowed Australian pilots with defective colour vision to fly with the same operational rights as their ’normal’ colour vision colleagues.
In the letters to DAMEs and AOC holders this week, CASA reports that ‘recent medical research’ indicates a risk to safe flight operations by pilots with defective colour vision, yet none of this evidence is presented by CASA in those letters, on its website, nor is it evident in the medical literature (I have searched). The only reference cited by Dr Pooshan Navathe (Principal Medical Officer, CASA) reports that there are differing standards for assessing colour vision amongst ICAO member countries (Watson DB. ‘Lack of international uniformity in assessing colour vision deficiency in professional pilots’ Aviat Space Environ Med 2014 Feb; 85(2):148-59). Hardly damning evidence of a risk to flight safety, more likely evidence of a risk to effective bureaucracy.
I am a pilot with defective colour vision. I have been operating aircraft under visual and instrument flight rules, day and night, in the UK and Australia since 1990 without any incidents related to my supposed inability to perceive colours in a ‘normal’ way. I am also a medical practitioner and understand the concept of ‘evidence based practice’. Under CASA’s new stance, colour vision-defective pilots will be (an indeed recently have been) stripped of the opportunity to earn a living, denied the opportunity to continue to fly as they have done for thousands of incident-free hours, without the presentation of any evidence that demonstrates a safety risk that needs to be addressed. AOC holders (the employers of these pilots) have been threatened in writing by CASA - "I write to you now, as the holder of an Air Operator’s Certificate (AOC) who may employ one or more affected pilots, to encourage you to consider whether it is safe to allow those pilots to continue to exercise flight crew privileges under your AOC, subject only to the existing condition, and what adjustments to those arrangements you may consider to be appropriate, in the interests of safety” - what exactly is the intent of this directive? What is CASA expecting of the AOC holders in response, and what is the consequence of not addressing the ‘problem’ - loss of the AOC?? This is a baffling attitude for CASA to take, is malicious in intent and typical of their bullying attitude towards the industry.
I, and many of my pilot colleagues, are outraged by the developments detailed above. If CASA continues with its drive to ground, or severely curtail, the operation of pilots with defective colour vision, without making a legitimate, evidence-based safety case, legal action is likely to be forthcoming from the pilot community on a large scale, leading to an enormous waste of tax-payers money. All over an issue for which there is no demonstrable safety benefit. None. Surely the regulator should be held to the same standard of ‘evidence-based practice’ for its decisions as the medical and other safety-orientated industries are.
I would like to give CASA the benefit of a doubt and assume that these recent changes are borne out of incompetence rather than malevolence, but unfortunately I don’t think I can. I would implore you to continue to pursue this issue in the parliament and hold CASA to account on its actions, stop this profligate waste of public money, and at the very least hold them to the standard of ‘evidence-based practice’ as the basis of their actions.
I thank you for your attention and for your work so far
Yours sincerely