My letter re: CVD, ASRR and "The letter"
Here is my letter to the MPs regarding the current issues, with a little help from my friends:-) Feel free to get ideas for your letters if you wish!
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As a Chief Pilot, I take seriously my responsibility for the safety of my passengers and crew. I also support the need for an appropriate, evidence-based regulatory environment for the Australian aviation industry to support economic development and a safe and prosperous society.
It is for this reason I write to you, asking that you would support the Minister for Transport, Hon Warren Truss MP, and Senator David Fawcett in their efforts to ensure fair and safe outcomes for pilots and the aviation industry.
I am 35 years of age and hold an Air Transport Pilots License (ATPL). I am our Company’s CASA approved Chief Pilot, and have over 15 years flying safe commercial operations in all weather conditions and at night. I also have a mild colour vision deficiency, which, although continuously being aware of it, has never become evident or a factor during operations I have conducted.
It therefore caused great concern to me, and many of my professional colleagues and their families, when the Civil Aviation Safety Authority (CASA) changed their policies and procedures last week – without any industry consultation or notification - affecting the treatment of Colour Vision Defective (CVD) pilots.
It should be noted
• CVD pilots have been operating safely in all levels of aviation in Australia for the past 25 years
• there has never been an accident attributed to Colour Vision Deficiency worldwide
However, CASA announced policy changes last week that will prevent many CVD pilots from having a career in Australia. This not only will affect a considerable number of current Airline pilots, but will also negatively affect many pilots serving regional and remote communities, including those providing valuable passenger and freight charter services, as well as life-saving aeromedical operations such as the Royal Flying Doctor Service. There is a particular wealth of experience in the General Aviation sector with CVD pilots who have not pursued the typical airline path due to their imposed restrictions. If these pilots were to lose their privileges it will only hinder the safety and experience level of GA in Australia.
CASA have announced they are changing from operational testing to laboratory-derived Colour Assessment and Diagnosis (CAD) testing for pilots. The rationale for CASA’s change has not been explained, nor any supporting evidence provided. However, this new policy will deny new CVD pilots who cannot pass CAD testing, as CASA will not grant them a Class 1 Medical, unnecessarily precluding them from employment as a pilot in any form, regardless of the nature of the operation.
If this change in standard is extended to current pilots, many will lose their entire career, despite an impeccable safety record.
Australia has led the rest of the world in giving CVD pilots a fair go since the landmark “Denison” case in the AAT in 1989, allowing CVD pilots to conduct commercial operations and earn a living in aviation. The tireless work of colour vision expert, Dr Arthur Pape, has paved the way for Australian pilots to have fulfilling and safe careers in the industry.
Over the last 25 years and tens of thousands of hours, CVD pilots have proven themselves to be equally safe in operating aircraft to colour normal pilots. Many competent and safe pilots fail the CAD test, but have proven by experience that they can accomplish the safe performance of duties and safely operate an aircraft. In fact, it is debatable if the new CAD test that CASA has suddenly introduced is sufficiently of an “operational nature” for the final level of testing as required by current law. Only 35% of CVD's pass the CAD test, eliminating many proven safe pilots.
The recently published Aviation Safety Regulation Review (ASRR), released by Minister of Transport, Warren Truss, found that CASA was failing the industry, the taxpayer and flying public, and choking the future growth of an industry that is vital to Australian society. It is also believed to have displayed unfair bullying tactics to the industry and that the industry had lost confidence in the regulator.
Consistent with these findings relating to the conduct of CASA, just last week CASA sent a letter to all Air Operators in Australia asking them to “consider whether it is safe to allow these (CVD) pilots to continue to exercise the privileges of their license”. Although citing “recent medical research”, it gave no evidence for substantiating such a claim. This letter is extremely disappointing and distressing as it could jeopardize the employment of many long-serving and dedicated pilots and is completely unjustified.
Senator David Fawcett has been an outstanding and faithful ambassador for the rights of CVD pilots in Australia to continue to fly safely. I urge you to support him in bringing a fair outcome for the CVD pilots who have dedicated their lives to safe flying operations in Australia.
I also encourage you to support the Minister for Transport, Hon Warren Truss MP, to ensure the appropriate changes are implemented within the regulator to ensure the continuing safety and prosperity of the aviation industry in Australia.
Last edited by CoftC; 9th Jun 2014 at 10:27.
Reason: Letter being continually refined