Many of the more pragmatic, sanguine submissions to the ASRR make polite, if pointed reference to the many issues surrounding the Avmed department. Personally I found the Maitland submission to be of great value, being balanced, succinct and very much grounded in experience. If for no other reason it is well worth a quiet read, the medical section (f) 4 sets out the issues and in part (between the lines) offers a solution.
Extract - EW. John Maitland. Part (f) Aviation medicine.
By far the most common complaint I receive regarding the processes and administration by CASA officials is in relation to Aviation Medicine.
Problems arise when a pilot fails to meet the requirements of the relevant table set out in CASR 67.150 (for class 1) or CASR 67.155 (for class 2). CASR
CASR 67.180 provides a mechanism by which a pilot who fails to meet the medical standards set out in CASR 67.150 or CASR 67.155 may still be issued with an aviation medical certificate if CASA is satisfied that issuing a medical certificate to the applicant would not endanger the safety of air navigation.
A dispute often arises in situations where the applicant may have suffered a medical condition which his or her medical specialist has determined will not affect his or her ability to safe! y operate an aeroplane, but notwithstanding the assessment by the medical specialist in the field, CASA aviation medicine will often ignore the specialists' expertise and advices; and refuse or cancel the applicant's aviation medical certificate.
The submission made by - Dr Rob Liddell – is directly related to the CVD issue and also worthy of a coffee and a quiet think. The second paragraph (IMO) nails down the really important issue. An incorrigible operator, such as Hempel could not be prevented, no matter what the 'regulations' say. The Hempel medical farce was simply a distraction from the underlying elements of the case. Even so, the regulator and the PMO were not embarrassed; they should have been. But the vast majority of pilots are mostly 'self regulating' as a matter of professional pride and operational maturity; it is grossly unfair that this ethos is suspected or dismissed. Trusted with many lives, over many miles to operate safely and legally; but not trusted to realise when they are too ill to fly. It's bollocks; actually it's real Pony Pooh; Shambollic style.
Extract - The dangerous result of CASA’s draconian regulatory measures is that now many pilots tell CASA as little as possible about any medical problems in order to protect themselves from expensive and repetitive investigations or possible loss of certification . Most pilots are responsible people and they have no desire to be in charge of an aircraft if their risk of incapacity is unacceptable. When their DAME and their specialist believe they meet the risk target for certification without endless further testing demanded by CASA and the advice of their own specialist is ignored by the regulator then the pilot’s lose confidence in the regulator.
In medical certification CASA appears to have lost sight of the fact that all pilots self-certify themselves fit to fly every day they take control of an aircraft. The only day in the year when a doctor has any control over their fitness to fly is the day that they have their medical examination.
The RAAA submission touches on the frustration of operators; I'd like to see the figures on how many roster changes are made due to a medical revalidation expiring before the new certificate reaches to applicant. I know it's not just me chasing down a certificate close to deadline – can't fly without it.
Extract - The medical certification seems to involve a large amount of second guessing the Designated Medical Examiners (DMEs) and demanding more expensive additional tests and re-examinations. Is there any good reason why DMEs in Australia cannot be authorised to actually issue the Medical Certificate as UK Authorised Medical Examiners are – even to the extent of issuing a UK/JAA medical here in Australia? It is the opinion of many in the industry that the medical section of CASA needs a complete overhaul.
Anyway, for what it's worth, it is clear that Avmed need to be revamped and taken forward to the twentieth century and not regress any further toward the nineteenth style of bureaucracy, made infamous by colonial administrators, before the damage being inflicted becomes irreparable without huge amounts of time, trouble and money being wasted.
It's not just CVD, no siree; hair loss and flatulence are next; after 'funny turns' that is....High priority, big ticket items so don't say I didn't warn you.
Toot toot.