7th July 2014
Mr. Peter Fereday
Executive Manager
Industry Permissions
Avmed Branch
Civil Aviation Safety Authority
GPO Box 2005
CANBERRA ACT 2601
Re: Colour Vision Deficiency
Dear Mr. Fereday,
As we are sure that you are aware the issue of Aeromedical safety in colour deficient pilots was examined very thoroughly at two Administrative Appeals Tribunal hearings about 25 years ago. To the best of our knowledge this examination of the Pape and Denison appeals was the most comprehensive carried out anywhere in the world and lasted for over 30 days.The AAT overturned CASA's ruling about colour deficient pilots not being able to fly at night. To the best of AOPA's knowledge this examination still remains the most comprehensive carried out anywhere. Pilots have been able to fly at night and undertake IFR operations in Australia for 25 years. More recently they have been using modern "glass cockpit instrumentation", again without incident. AOPA strongly supported these appeals at the time and we continue to support the current rules pertaining to colour deficient pilots.
To the best of AOPA's knowledge there has never been an aviation accident or incident in Australia directly attributable to a pilot being colour deficient. AOPA agrees with the use of evidence based procedures in evaluating aeromedical disposition but in this case where is the evidence that colour deficient pilots may be unsafe?! With now 25 years of safe operations utilizing these pilots the evidence surely indicates the opposite situation.
This is why we and many of our members are distressed by a letter sent out under your name on 6th June 2014 to all colour deficient pilots and to their employers asking them to reconsider their current flight crew privileges and for pilots to seek the advice of their DAME and/or their personal physician. This letter was apparently based on some alleged medical research which reportedly indicated that the safety implications of colour vision deficiency were greater than first thought.
The aviation industry has been kept ignorant of this evidence. If it is so important then why has it not been released for proper evaluation?
AOPA is aware of a further letter from you stating that any changes could be far down the track and would only occur after proper evaluation and consultation, however the first letter has already placed seeds of doubts in the minds of aviation employers and pilots could well be overlooked for promotion and progression to more complex aircraft due to possible implications of employing colour deficient pilots.
To our mind this initial letter should never have been sent without proper evaluation of this alleged new evidence. It most certainly should not have been sent to aviation employers.
AOPA respectfully requests your Department to write again to all of the affected pilots and their employers stating that CASA does not intend to proceed with any action in relation to colour deficient pilots unless genuine strong evidence emerges of a safety issue and, if that does become the case, then the evidence is thoroughly examined by expert ophthalmologists and that proper consultation is conducted with the aviation industry.
Yours Sincerely,
Aaron Stephenson
CEO
CC: Mr John McCormick
GPO BOX 2005
CANBERRA ACT 2601
Minister Warren Truss
PO Box 283
MARYBOROUGH QLD 4650