AOPA Supports SAAA call for private pilot medical reform

[aviationadvertiser]

29th July 2016


Mr Mark Skidmore
Director of Aviation Safety (CASA)
Civil Aviation Safety Authority
GPO Box 2005
Canberra ACT 2601
Australia

The Hon Darren Chester MP
Minister for Infrastructure and Transport
House of Representatives
Parliament House
Canberra ACT 2600
Australia.

- Members of the Aircraft Owners and Pilots Association
- Users of the Aviation Advertiser – Australia network
- Government Ministers and Senators
- Industry media


Aircraft Owners and Pilots Association supports the
Sport Aircraft Association of Australia call for PPL medical reform.

Mr Mark Skidmore,

I am writing to you as the Executive Director of the Aircraft Owners and Pilots Association (AOPA) in support of the request submitted by the Sport Aircraft Association of Australia (SAAA), calling on the Civil Aviation Safety Authority (CASA) to reform private pilot medicals.

Australia’s general aviation industry is being negatively impacted by excessive aviation medical assessments and approval requirements on private pilots license holders. The result has been the broad discrimination of a large number of experienced and healthy pilots, removing them from active flying and forcing them from our industry.

Over the past 9 years, a significant number of general aviation pilots have been forced to side-step into RAAus membership, to avoid the aviation medical bureaucratic red-tape. This transference of pilots has played an enormous role in pushing our general aviation industries into serious decline and toward bankruptcy.

AOPA estimates that the current CASA medical assessment and approval process is unnecessarily burdening general aviation pilots in excess of $10 million per annum. An unnecessary financial impost that is now recognised by leading aviation regulators as having no measurable value on aviation safety whilst negatively impacting industry economic performance and sustainability.

AOPA calls on CASA to take immediate action to harmonise private pilot aviation medical requirements, benchmarking both the United Kingdom and the Unites States of America, to provide all Australian private pilots – regardless of aircraft type flown – a level playing field.

As you are aware, the Civil Aviation Administration of the United Kingdom on the 9th May 2016 announced significant changes to medical requirements for private pilots. These changes were a result of extensive industry consultation, which found that 96% of industry respondents supported reducing medical requirements for private pilots to that of a drivers license standard.

The UK CAA determined that existing PPL medical requirements were disproportionate, costing private pilots both time and money unnecessarily, when compared to the benefit they provide.

The UK CAA consultation process considered the potential risks incurred by introducing changes, these included;

a) GA fatal accidents with potential medical causes

Over a 10 year period 151 GA fatal accidents of which only 20 could have been possible medical causes. These included factors such as hypoxia, fatigue, dehydration, alcohol and suicide. The UK CAA determined that there was a significant degree of uncertainty with regard to the actual cause of these accidents, with the medical cause only suspected. As a result, it was decided to focus the risk analysis on serious incapacitation in flight.

b) Third party risk

UK CAA historical records demonstrated that the probability of a GA accident causing injury to people on the ground is extremely low. Over a 10 year period from 2004-2013, out of the 151 GA fatal accidents, there were a total of six (6) accidents involving third parties on the ground. Only two (2) of these accidents resulted in fatalities and both involved third parties involved in aviation activities. The UK CAA determined that there were no fatalities to a third party as a result of serious incapacitation of the pilot. It was therefore determined by the UK CAA that there is no significant increased risk to third parties identified.

c) Risk of incapacitation in flight

The UK CAA gave consideration to the risk of incapacitation in flight by looking at the likelihood of different medical conditions occurring which could result in pilot incapacitation. The focus was on conditions which could result in sudden incapacitation (e.g. heart attack, seizure) where the pilot may be unaware of symptoms at the start of the flight. The considered risk profile was based from consultation, where 99% of respondents stated that private pilots do not generally take part in flying if they feel unwell. The UK CAA determined that there could be a total of approximately two (2) acute medical incapacitations events in-flight per year, compared with approximately one (1) at present. The UK CAA determined that whilst the risk of pilot medical incapacitation is increased, the absolute risk of a medically caused accident was assessed to be very low.


As a result of their extensive industry consultation and assessment of risks, the UK CAA have updated their regulation so as to reduce the medical requirements for private pilots, accepting an ordinary drivers license medical standard with no routine requirement to attend for a medical examination. The UK CAA clarified that pilots will be required to complete an on-line form once prior to the age of 70 years (and every three years after the age of 70) to make a legally binding statement that they meet this standard.

The UK CAA demonstrated that the drivers license medical was a more proportionate approach and would reduce both the amount of time and money spent on medical examinations and tests by private pilots, whilst having little to no impact on overall safety standards.

Attached to this email is a copy of the UK CAA CAP 1397 APR16 – Click here to view (http://publicapps.caa.co.uk/docs/33/CAP%201397%20APR16.pdf)

AOPA calls on you Mr Skidmore to take immediate action and to demonstrate your support for general aviation by removing the unnecessary private pilot medical assessment and approval red tape. If you would like to discuss this matter further, please contact me directly. AOPA stands ready to work with CASA on this important issue.

Best regards,

BENJAMIN MORGAN
Executive Director - Aircraft Owners and Pilots Association
Chief Executive - Aviation Advertiser - Australia

[LexAir]

Let's get rid of the stupid distinction between a CPL and ATPL medical validity while we are about it!

[no_one]

For completeness here is the link to the SAAA letter.

http://saaa.com/Portals/0/Medical%20Exemption/Letter%20to%20CASA%20re%20Medical%20Certification%200%206-signed.pdf

[triadic]

hear hear !!

[Lead Balloon]

It's pointless writing to CASA about this stuff. CASA's return to the Dark Ages approach to CVD, ratified by Mr Skidmore, demonstrates that CASA rhetoric about evidence-based and risk-based regulation is just that: rhetoric.

Lots of people have realised that a very comfy living can be made out of the busy work of mining the rich vein of public fear created by the mystique of aviation. The primary motivation of those people is to find something - anything - to justify further intrusion into and increased power over as much as they can. They are not about to let inconveniences like objective evidence and objective risk get in the way of their personal financial interests and egos. (The scarier ones are the ones who actually believe their crusade makes a positive contribution.)

All in the name of 'aviation safety' of course.

[aviationadvertiser]

Thank you for your response and support for AOPA's call for medical reform. I can assure you that AOPA are determined to achieve a positive result for Australian private pilots.

In my view there is no greater issue affecting aviation. Over the 9 years I have been involved in this industry I have received countless letters and documents pertaining to excessive medical assessments and approval processes - all of which are costing Australian pilots money and time.

A myriad of examples can be found where CASA AVMED have subjected pilots to extreme delays and stress in approving pilot medicals. The evidence has been piling up and the facts are our industry needs immediate relief.

Just a couple of days ago, I received a telephone call from a distressed pilot whom had undertaken his medical assessment and indicated that he socially drinks beer and that he could consume up to three (3) drinks per week. As a result, AVMED have subjected the pilot to unnecessary additional liver function tests. The consequence of which is increased medical assessment costs and lengthy delays.

The result of this madness is too many Australian pilots no longer flying and fewer aircraft hours flown!

Because of the above, thousands of general aviation private pilots across Australia have had no other option, than to move across to recreational sport flying to continue. The absurdity of course is that CASA AVMED deem these pilots unfit to fly, then in the same breath CASA approves them to fly with a recreational license! Go figure.

As more and more general aviation pilots are medically forced out by AVMED stupidity, general aviation will continue to suffer economic collapse, as fewer and fewer general aviation aircraft are being purchased and operated.

This situation is having a catastrophic impact on our aircraft engineering support industries, as businesses struggle to pay their rent and staff costs due to reduced customer inflow.

The result of this has been increases in operating costs for all commercial general aviation businesses, as they now struggle to cover their overheads. Pushing those that remain towards closure.

Be under no illusions, CASA have created the industry crisis that is enveloping general aviation.

Please do not take my comments as negative towards RAAus or recreational flying. I am fully supportive of the continued growth and development of this fantastic market segment. As recreational flying matures, this will be an incredibly valuable and influential component of our aviation industry without any doubt. More and more youth will be introduced to aviation through this exciting market segment, which has lead the charge on reducing costs to aviators.

That said, I feel it is important to protect the rights of all Australian private pilots, so that they may be free to fly whatever aircraft type they desire, without discrimination by CASA AVMED.

Best regards,

BENJAMIN MORGAN
Executive Director – Aircraft Owners and Pilots Association
Chief Executive – Aviation Advertiser - Australia.

[gerry111]

Ben, I really appreciate and applaud your enthusiasm to tackle CASA for the benefit of G.A. in Australia.

But do you really believe that the decision makers in Canberra are really impressed by your grandiose titles?

(For example: "Executive Director- Aircraft Owners and Pilots Association." And not to mention: "Chief Executive- Aviation Advertiser-Australia.")

I'm a self employed small business proprietor. Just like you.

Perhaps the powers that be, recognise that you (like me) are insignificant in their schemes of more important things?

[josephfeatherweight]

Just a couple of days ago, I received a telephone call from a distressed pilot whom had undertaken his medical assessment and indicated that he socially drinks beer and that he could consume up to three (3) drinks per week. As a result, AVMED have subjected the pilot to unnecessary additional liver function tests.
Are you sure it wasn't three (3) drinks in a single session?
Surely 3 drinks per week won't ring alarm bells with AVMed??

[spinex]

Actually the average Canberra bureaucrat has its head so far into the fundamental orifice that any lesser title runs the risk of being ignored. That aside, is it really necessary to take cheap shots at one of the few blokes who is actually taking a full blown swing at getting something done? That sort of thing may explain why we end up with such a maladjusted tribe of pollies, any normal person would say fuggit and go drink - or be up for assault.

[Old Akro]

Ben, I really appreciate and applaud your enthusiasm to tackle CASA for the benefit of G.A. in Australia.

Here here.

I believe that Darren Chester is a good, ambitious, up & coming minister who may actually try and make a difference. Its worth a go trying to educate him about major frustrations that industry has with his key departments.


When I first read this, I thought that finally the AOPA must have grown a pair.

But reading the detail they are only endorsing something the SAAA has already done, which doesn't go halfway far enough. Why wouldn't we AT LEAST want what the US has just adopted for 3rd class medicals? Instead of 2,000 kg the US limit is a shade under 3,000 kg. Instead of one passenger, the US is five passengers. Instead of VFR only, the US is IFR & VFR.

So, please AOPA, don't forget about IFR pilots and pilots who fly 4 & 6 seat aircraft. Display more of this spirit representing all of GA and I'll become a member again.

[aviationadvertiser]

Gerry111, thank you for the support.

You will note that my username and my posts all very clearly identify who I am. I have nothing to hide or anyone to hide from, I stand by what I say. Yes, I use my business titles on formal communications, are you suggesting I sign off to politicians and regulators just with my name?

With regard to your concern of feeling insignificant to CASA. Instead of being fearful, try being fearless, it may give you an entirely different perspective on the challenges that lay in front of you.

Contrary to your view, CASA is in fact listening. They may not be acting yet, but they are listening to what industry is saying. Without doubt, the next three years will be significant for general aviation.

Old Akro, with regard to your concerns. I can assure you that AOPA does view the importance of pilot medical reform for 'all pilots' of all aircraft types. The association is currently preparing a formal policy paper with regard to pilot medical reform, to which we will be submitting to CASA, the Minister and industry.

With regard to your AOPA membership, Gerry111 and Old Akro I would encourage you both to not wait - rejoin today. Support the effort to bring about reform.

If either of you wish to make contact and speak to me in person, please feel free to call on (02) 9791 9099

[Lead Balloon]

CASA always listens, Ben. The people who run CASA have always employed patsies who earnestly believe their job is to listen to and act on what they've heard from industry.

Please don't confuse realism for fear.

I'm sure you've been to lots of meetings that involved lots of nodding and smiling. How did the outcomes of those meetings go, from a substantive action perspective?

Examples of CASA meetings with lots of nodding and smiling but no substantive action are many. Let's choose just one.

The CVD Pilots Association had a meeting with Mr Skidmore and his handlers, who listened and nodded and smiled. And then they got on with the nice little earner that is discrimination against pilots with CVD.

If CASA is so lacking in corporate integrity that it can unblushingly defend the rejuvination of the discriminatIon against pilots with CVD, the rest is just fluff.

The reason this is important is that valuable and finite energy like yours needs to be focused where it's most likely to have some effect. Please don't waste it on talking to CASA in the naive belief that it will produce any substantive change.

[YPJT]

In relation to the new medical questionnaire. Mate of mine was told by his DAME "tell them nothing".

[Lead Balloon]

Hardly surprising.

Back in the Liddell and previous years, AVMED understood not only the medical issues that impact on aviation safety, but also, and more importantly, how the AVMED system integrated into and contributed practically and positively to the overall system of aviation safety in the real world.

It seems that AVMED is now labouring under the misconception that it's 'helping' by trying to find out and intrude into anything and everything that could, in its opinion, remotely possibly be relevant to aviation safety, uniformed by the objective and comparative risks that have substantial impacts in the real world, and untroubled by what AVMED's approach is actually doing to the overall system of aviation safety.

By far the most stressful aspect of my life these days is the recurrent prospect of having to face the capricious consequences of the bureaucratic stupidity that is the CASA AVMED system. I'm no longer surprised at the number of people who tell me they simply withhold information from their DAME.

The irony is that because the risks arising from the covered up 'conditions' are so remote, there's no substantial consequence in the real world. But it would be nice not to have to pay for the busy work of all those bureaucrats, and it would be nice not to have to endure the stress.

[aroa]

g 111 Cantberra not impressed by grandiose titles. Que ??

Why then do they give themselves grandiose titles like ...Managing Director of Compliance and Enforcement...and cant even follow there own rule book
Or Senior Airworthiness Inspectors and they dont even know what they are looking at.
CAsA has lots of "chiefs" ( sick...very sick) but not many real indians.

Ask former CMO Poonshie, more acronyms than you could poke a syringe at and look where that lot got him.
And us.

I had M. I B. B after my name on the letter head....and after a decade or so, someone actually asked what it meant.
Its a philosophy that very difficult to achieve these days. Minimal Involvement with Bureaucratic Bull****.

Because unfortunately Oz is drowning in it.

[gerry111]

I agree with you, aroa.

But the grandiose titles within the bureaucracy allow incompetents to earn far more than they could anywhere else. Particularly in the private sector and definitely within small business.