Redix,
For a good read on the scientific flaws with the ICAO colour perception standard, check out this peer reviewed article written by Dr Pape a few years ago which was published in an aviation medicine journal:
Colour Perception Standards in Aviation: Some implications of the AAT decisions regarding colour perception and aviation
On another note, DAS Skidmore has just announced a review of the CASA AvMed department:
CASA Briefing - March 2015
The management of aviation medical certificates is an issue of interest to many pilots and air traffic controllers. I recognise some people have strong views about CASA’s aviation medical system, the decision making processes and medical rulings. This is not surprising as we process more than 25,000 medical applications each year. But the debate about CASA’s medical system needs to be put in context – in 2014 we refused 102 applications out of 25,855 and in the second half of the year there were 13 official complaints. Despite this low level of complaints and medical refusals I believe we can do better and the relatively small number of complaints we receive can be reduced. That is why I have initiated a full review of CASA’s AvMed capabilities. This review is now underway and I expect it will be completed in the second half of 2015. It is looking at our strategic approach to aviation medicine policy standards and clinical practice development, options for the better delivery of medical services in the future and the recruitment and retention of qualified and experienced aviation medicine doctors. Our bottom line is to find ways to improve medical service delivery,
ensure our decision making processes are transparent and evidence-based, as well as improving the management of complex medical matters.
In addition to the broad review of aviation medicine CASA will undertake a review of the arrangements that currently allow approved Designated Aviation Medical Examiners to issue and renew class 2 medicals. The results of this review will facilitate an examination of the potential for DAMEs to renew class 1 and class 3 medical certificates in the future.
I will ensure CASA consults widely and effectively with the aviation community during the course of these aviation medical reviews. Where criticism is warranted I will make sure the causes of problems are identified and addressed as quickly as possible.
I believe the aviation community and CASA need to build a closer working relationship based on our mutual interest in achieving the best safety outcomes. This relationship must be based on respect and trust. CASA is open and committed to an appropriate ‘safety partnership’ with the aviation community and I am devoting a good deal of time and energy towards working to the achievement of this goal. Of course a closer relationship between the aviation community and the regulator does not mean CASA can agree to every proposal or view put to us. Not everyone will get what they want and consensus may not always be possible.
However, I will make sure we are listening to your views and criticisms and we respond in a considered and respectful way to your comments, questions, concerns and complaints.
You can read my speech on the
way forward in aviation medicine which was recently delivered to the aviation Medical Society of Victoria.
Safe flying
Mark Skidmore AM
If the new DAS is truly serious about making sure AvMed decisions are "evidence based", he would be well placed to look at Australia's 25 year history of CVD pilots operating safely and to take notice of the AAT's findings in CASA's three CVD losses (Pape, Denison & O'Brien) at the tribunal.
If he is serious about "consulting" with the aviation industry, a good starting point would also be for him to actually meet with Dr Pape and some of the many CVD professional pilots operating in this country to hear first hand "real life evidence" of their experience and career histories.
Maybe he could then explain why new CVD pilot entrants into the industry are now being denied medicals or having them severely restricted to Day VFR only, when their fellow pilots have been operating safely for decades.
In the speech referred to in his article above, Skidmore makes the following comments on the CVD issue:
My speech won’t be complete if I don’t touch on the delicate subject of CVD. Australia does differ from other countries in relation to the requirements surrounding CVD. Australia is more flexible in allowing applicants to sit multiple sequential tests for CVD where they record a fail and can issue a medical certificate if at any stage any of the three-level tests are passed. Most overseas regulators do not allow this level of flexibility. For example the UK does not allow for any second chances if an applicant fails their only test, the CAD test. They do not receive a Class 1 medical certificate.
In mid-2014, it was determined that the handling of pilots with CVD had not been in strict accordance with Civil Aviation Safety Regulation Part 67 (Medical). CASA advised industry of its new process relating to the regulations in June 2014. This was done to provide industry with information to assist in understanding their obligations in relation to the regulations. The new processes related to new applicants only and there were no impacts on existing pilots. In response to some of the correspondence received, CASA updated the CVD information on its website.
In February 2015, CASA had 134 Class 1 medical certificate holders and 252 Class 2 medical certificate holders who have failed the Ishihara test.
CASA is considering the Colour Assessment and Diagnosis (CAD) test as a third-level test. CASA has determined the CAD test is suitable as an aviation specific test for detecting CVD. It is used by the UK and is also available in the US as an option for testing for CVD. CAD provides for colour and diagnostic testing, which can determine the degree of colour deficiency, which is something that is currently not able to be determined by the Ishihara or Farnsworth tests.
Whilst I am not considering further changes to policy or standards at this time, any proposed changes will be consulted through the SCC Medical sub-committee. Pilots with existing CVD restrictions will require no other tests related to CVD, unless other medical reasons determine a need to do so.
Mr Skidmore, everyone agrees that the CAD is a brilliant CVD test. However, it doesn't remotely come close to fulfilling the requirements of the third level test under CASR 67.150 (6)(c). CASA still cannot answer the question - "what operational situation does the CAD simulate?" It's a fairly basic and fundamental question...
He also states that they are "considering" using the CAD test as the third level test. This is also a blatant lie, as AvMed are already using it for the third level test.
Here's just one example from Bill Smith's post last year:
CASA has determined the Colour Assessment and Diagnosis (CAD) to be an appropriate test for the purposes of regulation 67.150(6)(c).
In the O'Brien AAT hearings, evidence was also heard that the former PMO wrote to Mr O'Brien prior to his medical renewal last year, refusing to re-issue his Class 1 medical at all, unless he undertook the CAD test. This was despite his medical being renewed repeatedly for the previous 15 years without issue.
Mr Skidmore needs to stop blindly following the advice of the AvMed zealots on their crusade to save the world from CVD pilots. He needs to actually take the time to listen to the other side of the story from pilots with the operational expertise to see what they think should be an appropriate test of an operational situation for the purposes of CASR 67.150 (6)(c). Maybe he might be able to hear first hand examples of why colour useage in aviation is not as important as the AvMed zealots would have him believe.
Perhaps then we can then start leading the world at an ICAO level with our "evidence" on CVD issues, rather than following it based on the "assumptions" of other countries like the UK!
