Empire Strikes Back! on Colour Defective Pilots... Again.
Here’s just one snippet from the Clark and Gordon document linked in Arthur’s post:
(My underlining.)
With colour-coded systems, the principal effect of lens scattering is the reduction of the colour differences between the signals. For instance, in a red-white coding scheme, the white signal becomes reddened and the red becomes desaturated, i.e. pink. Because the scattering is angle-dependent, the greatest effect is adjacent to the direction of the transition between the colours. The magnitude and angular variation of the effect depends on the cause of the scattering, viz. lens surface reflections, or dust-water deposits, and in the case of particulate scattering, on the size distribution and optical properties of the particles. Hald (1980) reported water condensation on both sides of the objective lenses in trial PAPI installations. The resultant scattering '. . . totally destroyed the signal, so that the light received over a certain distance happened to be only white with no red sector. In an operational system this will mean that the PAPI system would only give a full "fly down" signal at all angles.' Electrical heating elements have been installed near the lenses in some PAPI boxes in an attempt to overcome the condensation problem. The heaters will not overcome the dust problem: if anything they will exacerbate it because of the extra airflow over the lenses as a result of convection currents.
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The Clark and Gordon document above was not the only instance of highlighting short-comings of PAPI.
In April1983, the FAA produced a report "Evaluation of Precision Approach Path Indicator (PAPI)
It stated "It was found that during certain weather conditions, condensation could form on the PAPI lenses and produce transient false pink signals which must be eliminated by some means."
Here is the link to the full document, to enable further reading. Evaluation of PAPI by FAA 1983
I'm harping on the Fedex crash because it still today is quoted by the zealots (private and official) as THE example of a serious accident CAUSED BY A PILOT'S DEFECTIVE COLOUR VISION.
The NTSB report into this crash was fatally flawed because:
Offers to provide them with copies of the Clark and Gordon Paper amd tje FAA evaluation are rejected as unnecessary.
Watch this space
In April1983, the FAA produced a report "Evaluation of Precision Approach Path Indicator (PAPI)
It stated "It was found that during certain weather conditions, condensation could form on the PAPI lenses and produce transient false pink signals which must be eliminated by some means."
Here is the link to the full document, to enable further reading. Evaluation of PAPI by FAA 1983
I'm harping on the Fedex crash because it still today is quoted by the zealots (private and official) as THE example of a serious accident CAUSED BY A PILOT'S DEFECTIVE COLOUR VISION.
The NTSB report into this crash was fatally flawed because:
- the only medical evidence requested by the Board was from an individual whose zealous promotion and protection of rigorous colour perception standards is widely known.. This person introduced evidence far beyond what was require for the forensic inquiry into the crash.
- The NTSB's conclusions failed to consider the evidence from both the FAA's document (posted above) and the Clark ad Gordon Paper that had been circulated to the FAA.
- The testing of the PAPI post accident was carried out in broad daylight with none of the meteorological conditions that were present at the time of the crash.
Offers to provide them with copies of the Clark and Gordon Paper amd tje FAA evaluation are rejected as unnecessary.
Watch this space
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Today’s SITREP broadcast has been postponed from 2pm AEDT to 2:15pm, due to some last minute availability issues. Apologies for any inconvenience.
Apologies for the slowing down of the posts on the thread: A lot is happening in the direct communication space between the CVDPA directors and the CASA hierarchy, in particular the Director, Pip Spence.
I am working through the material that has come to me from the FOI section of CASA. It is disgracefully inadequate in that the lead players who were invited by CASA to help formulate their crusade, the identities of these individuals, as well as their qualifications that one would expect to be told, have been totally redacted (blacked out!).
In due course, we will be publishing the entire response obtained through FOI, but in the meantime, I intend to highlight some of the perverse logic promulgated by CASA to justify its equally perverse conclusions.
Example 1. CASA states: "There is a proposition that the absence of air accidents among CVD pilots could well be due to the fact that there ARE restrictions by way of the Colour Vision Standard.
Then there appears this gem, copied verbatim:
"Safety concerns:
For colour vision deficient pilots, while able to pass OCVA, the colour cues within and outside the cockpit (or flight deck) are vital during the critical phases of flight. During an emergency, with heightened stress levels, the reaction time can become the determining factor between safety and accident. This human factor aspect cannot solely be defined by medical certification, instead has a direct bearing on safe operations, in turn safety of air navigation.
1.
Deutan or Protan CVD defect is a lifelong disability with potential safety impacts:
i.
Reduced or absent ability to assess glide slope by reference to colour cues
Reduced or absent ability to identify and interpret colour cure as used in instrument landing such as PAPI and VASIS and where no redundancy systems can be employed
Reduced or absent ability to identify and interpret colour cues used at airports, including but not limited to, aerodrome markings, holding points runway lighting, marked obstructions, rotating beacons on ground vehicles and precision guidance systems
Reduced or absent ability to identify and interpret colour cues used in cockpit instrument including but not limited to electronic weather displays, indicator and warning systems" End of Quote
I offer you this. There have been three landmark AAT cases since the mid-1980s, and between them, each and every point made in the preceding paragraphs was rejected by the AAT. It is nothing more than pure sophistry, intended to deceive and blind the gullible observers of the debate. We have records of hundreds of pilots with severe colour vision defects that pass and keep on passing every operational test put to them, and I mean BIG TIME! These folk fly every conceivable modern RPT aircraft, and that's just the Aussie part of the sample. In the USA, no one cares to keep the exact figures, but there are thousands of severe CVD pilots representing many thousands of accumulated flight hours performed in safety, and thousands of check and training examinations.
More in a day or two.
I am working through the material that has come to me from the FOI section of CASA. It is disgracefully inadequate in that the lead players who were invited by CASA to help formulate their crusade, the identities of these individuals, as well as their qualifications that one would expect to be told, have been totally redacted (blacked out!).
In due course, we will be publishing the entire response obtained through FOI, but in the meantime, I intend to highlight some of the perverse logic promulgated by CASA to justify its equally perverse conclusions.
Example 1. CASA states: "There is a proposition that the absence of air accidents among CVD pilots could well be due to the fact that there ARE restrictions by way of the Colour Vision Standard.
Then there appears this gem, copied verbatim:
"Safety concerns:
For colour vision deficient pilots, while able to pass OCVA, the colour cues within and outside the cockpit (or flight deck) are vital during the critical phases of flight. During an emergency, with heightened stress levels, the reaction time can become the determining factor between safety and accident. This human factor aspect cannot solely be defined by medical certification, instead has a direct bearing on safe operations, in turn safety of air navigation.
1.
Deutan or Protan CVD defect is a lifelong disability with potential safety impacts:
i.
Reduced or absent ability to assess glide slope by reference to colour cues
Reduced or absent ability to identify and interpret colour cure as used in instrument landing such as PAPI and VASIS and where no redundancy systems can be employed
Reduced or absent ability to identify and interpret colour cues used at airports, including but not limited to, aerodrome markings, holding points runway lighting, marked obstructions, rotating beacons on ground vehicles and precision guidance systems
Reduced or absent ability to identify and interpret colour cues used in cockpit instrument including but not limited to electronic weather displays, indicator and warning systems" End of Quote
I offer you this. There have been three landmark AAT cases since the mid-1980s, and between them, each and every point made in the preceding paragraphs was rejected by the AAT. It is nothing more than pure sophistry, intended to deceive and blind the gullible observers of the debate. We have records of hundreds of pilots with severe colour vision defects that pass and keep on passing every operational test put to them, and I mean BIG TIME! These folk fly every conceivable modern RPT aircraft, and that's just the Aussie part of the sample. In the USA, no one cares to keep the exact figures, but there are thousands of severe CVD pilots representing many thousands of accumulated flight hours performed in safety, and thousands of check and training examinations.
More in a day or two.
Last edited by Arthur Pape; 28th Nov 2023 at 00:14. Reason: grammatical
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CVD guinea pigs will be aware that the expensive CAD test is inflicted on them as a means to destroy their career aspirations and careers.
I submitted an FOI request for access to: “the current instrument determining the test commonly known as the Colour Assessment and Diagnosis for the purposes of either or both of CASR 67.150(6)(c) and CASR 67.155(6)(c)”. It's taken a while, including an internal review, but here is the outcome with bolding added:
Pause to consider the expense and mayhem caused by the CAD, and the fact that CASA can find no written evidence of the exercise of the power to determine the CAD as a ‘third tier’ test, by a person with the power to do so. (There is of course another minor point: The CAD simulates no operational situation known to aviation.)
I anticipate the insouciantly arrogant response of the crusaders in AvMed: We say it, so it is done!
I submitted an FOI request for access to: “the current instrument determining the test commonly known as the Colour Assessment and Diagnosis for the purposes of either or both of CASR 67.150(6)(c) and CASR 67.155(6)(c)”. It's taken a while, including an internal review, but here is the outcome with bolding added:
I refuse your request for access as I am satisfied the document you are seeking does not exist.
Through searches of CASA’s registry files and liaison with the relevant CASA business areas, there is no record of a document relevant to the scope of your access request.
Through searches of CASA’s registry files and liaison with the relevant CASA business areas, there is no record of a document relevant to the scope of your access request.
I anticipate the insouciantly arrogant response of the crusaders in AvMed: We say it, so it is done!
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The CASA Board has responsibility
It’s really extraordinary that the CASA Board has allowed the CEO Ms P. Spence and AVMED to perpetrate its scheme to deny the facts and dislocate the lives of many pilots.
To the casual observer CASA can put to the uneducated that the sun revolves around Earth and achieve 100% agreement.
Flagrantly disregarding the law and logical practice is self serving and the Board should take action and restore the previously accepted standard. As usual the Board sits there taking the money and kudos but no action.
I wonder whether there could be a class action against the Board of CASA in order to compensate all those who have been put through the AVMED wringer? The media spotlight would concentrate some minds.
To the casual observer CASA can put to the uneducated that the sun revolves around Earth and achieve 100% agreement.
Flagrantly disregarding the law and logical practice is self serving and the Board should take action and restore the previously accepted standard. As usual the Board sits there taking the money and kudos but no action.
I wonder whether there could be a class action against the Board of CASA in order to compensate all those who have been put through the AVMED wringer? The media spotlight would concentrate some minds.
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The thing you have to remember about Avmed is that they are not there to help pilots continue/start a career, quite the opposite. Unless it's changed over the past 10 years they are a bunch of has been military doctors who couldn't make it in the private sector so gummint is their saviour. In the past most of them were from foreign military and would struggle to attain English level 4.. Combine all this with the fact they have nobody to question their often questionable judgements (other than the AAT at great expense to the plaintiff) and you have what most regard as the most toxic waste of taxpayer dollars in Australia, and not only that, you could be mistaken for thinking this pack of sea hunts actually enjoy inflicting misery on Aviators
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Interestingly, the CVD debate has a focus (at least from what I can read here) on interpretation (or more accurately failure of interpretation) of slope guidance from a PAPI.
Whilst the simplest view might be that a PAPI is a colour based device and therefore a CVD pilot may be “less safe” than a non CVD pilot, it is a distorted view, in my opinion.
Visual slope guidance is only one of many means of identifying slope. GPS can derive a distance and the old 3 times tables can be used, many approaches have a coded 3 deg slope to the threshold, in short there are multiple clues that any pilot (CVD or otherwise) can use to determine whether they are on slope, including the old Mark 1 eyeball as used in many strips that are, for example, dirt or don’t have any visual slope indicator. Looking out the window and judging the sight picture and acting accordingly is what many people did for years before we became children of the magenta.
I myself suffer from CASA surveillance that my urologist gets quite grumpy about as he has to subject me to annual probes to identify a non issue - but that is a story for another time and place.
Suffice it to say I would have no issues flying with a CVD pilot.
Whilst the simplest view might be that a PAPI is a colour based device and therefore a CVD pilot may be “less safe” than a non CVD pilot, it is a distorted view, in my opinion.
Visual slope guidance is only one of many means of identifying slope. GPS can derive a distance and the old 3 times tables can be used, many approaches have a coded 3 deg slope to the threshold, in short there are multiple clues that any pilot (CVD or otherwise) can use to determine whether they are on slope, including the old Mark 1 eyeball as used in many strips that are, for example, dirt or don’t have any visual slope indicator. Looking out the window and judging the sight picture and acting accordingly is what many people did for years before we became children of the magenta.
I myself suffer from CASA surveillance that my urologist gets quite grumpy about as he has to subject me to annual probes to identify a non issue - but that is a story for another time and place.
Suffice it to say I would have no issues flying with a CVD pilot.
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CASA's masterpiece ACVA is merely a day VMC exercise, involving flying at various fixed heights towards a PAPI during which the candidate has to identify the transitions in indications.
My (educated) guess is that the zealots' obsession with PAPI arises from the Tallahassee 727 NTSB report. They cling to conclusion 13 of 16 conclusions of the report, which conclusion is that: “The first officer suffered from a severe color vision deficiency that made it difficult for him to correctly identify the color of the precision approach path indicator signal during the below-glidepath, nighttime, visual approach to runway 9 at Tallahassee Regional Airport.”
Your refence to multiple clues remined me that the Tallahassee 727 had some sources of useful information: among other equipment, serviceable altimeters and RADALT. The latter is a particularly good indicator of height and should have been indicating 'not much' immediately prior to the impact with the ground short of the runway.
The simplest explanation for the incident, supported by the objective evidence, is that all of the crew were fooled by false 'too high'/'fly down' indications from the PAPI due to contamination from the prevailing atmospheric conditions. Up until the incident, the airport had never maintained or operated the PAPI in accordance with the manufacturer's instructions. The disagreement between NACTA and NTSB as to the condition of the PAPI at the time of the incident remains a mystery, as a result of which I'm trying to contact the author of the NACTA submission to the investigation. The submission contains some remarkable information including this: "According to Air Traffic Control Specialist Mike Peymann when he entered the TLH ATCT there was such an unusual accumulation of dew on the tower cab windows that he had to use the tower window wash system before he could see outside.”
Fact is that thousands of commercial pilots with CVD have racked up thousands of hours in command of transport category aircraft, day/night, IMC VMC and whatever, world-wide. Some countries remain in the dark ages on the issue of CVD. The current crop of CASA AvMed zealots is trying to drag Australia back there.
(AvMed's demands in relation to matters urological are typical AvMed overreach in response to catastrophised risks, despite the weight of qualified specialist opinion to the contrary. I've said it many times: Any idiot with access to the internet can do what they do. Find the most terrible potential consequence of a condition. Extrapolate that into an aviation catastrophe. Find the 'Rolls Royce' means of testing and managing the condition and, most importantly, ignore the weight of qualified specialist opinion and instead prefer the outcomes of an internal echo chamber 'complex case management meeting' because 'the safety of air navigation' is something that only they understand.)
My (educated) guess is that the zealots' obsession with PAPI arises from the Tallahassee 727 NTSB report. They cling to conclusion 13 of 16 conclusions of the report, which conclusion is that: “The first officer suffered from a severe color vision deficiency that made it difficult for him to correctly identify the color of the precision approach path indicator signal during the below-glidepath, nighttime, visual approach to runway 9 at Tallahassee Regional Airport.”
Your refence to multiple clues remined me that the Tallahassee 727 had some sources of useful information: among other equipment, serviceable altimeters and RADALT. The latter is a particularly good indicator of height and should have been indicating 'not much' immediately prior to the impact with the ground short of the runway.
The simplest explanation for the incident, supported by the objective evidence, is that all of the crew were fooled by false 'too high'/'fly down' indications from the PAPI due to contamination from the prevailing atmospheric conditions. Up until the incident, the airport had never maintained or operated the PAPI in accordance with the manufacturer's instructions. The disagreement between NACTA and NTSB as to the condition of the PAPI at the time of the incident remains a mystery, as a result of which I'm trying to contact the author of the NACTA submission to the investigation. The submission contains some remarkable information including this: "According to Air Traffic Control Specialist Mike Peymann when he entered the TLH ATCT there was such an unusual accumulation of dew on the tower cab windows that he had to use the tower window wash system before he could see outside.”
Fact is that thousands of commercial pilots with CVD have racked up thousands of hours in command of transport category aircraft, day/night, IMC VMC and whatever, world-wide. Some countries remain in the dark ages on the issue of CVD. The current crop of CASA AvMed zealots is trying to drag Australia back there.
(AvMed's demands in relation to matters urological are typical AvMed overreach in response to catastrophised risks, despite the weight of qualified specialist opinion to the contrary. I've said it many times: Any idiot with access to the internet can do what they do. Find the most terrible potential consequence of a condition. Extrapolate that into an aviation catastrophe. Find the 'Rolls Royce' means of testing and managing the condition and, most importantly, ignore the weight of qualified specialist opinion and instead prefer the outcomes of an internal echo chamber 'complex case management meeting' because 'the safety of air navigation' is something that only they understand.)
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My (educated) guess is that the zealots' obsession with PAPI arises from the Tallahassee 727 NTSB report. They cling to conclusion 13 of 16 conclusions of the report, which conclusion is that: “The first officer suffered from a severe colour vision deficiency that made it difficult for him to correctly identify the colour of the precision approach path indicator signal during the below-glidepath, nighttime, visual approach to runway 9 at Tallahassee Regional Airport.”
What went wrong?
Does anyone have CVD?
Find a link to CVD
seems to be the method of investigation.
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The extent to which the NTSB went to try to refute any potential problem with the particular PAPI during the particular approach in the particular conditions, is very puzzling to me. The objective evidence of the patent defect in PAPI had been around for decades. This, too, from the NACTA submission to the NSTB:
That's why the manufacturer's instructions included that: "The PAPI system must operate continuously when the runway is in service." The Tallahassee PAPI was instead linked to the PAL. The pilots activated the PAL mere minutes before arrival.
The aircraft was on approach near dawn when the temperature and dew point were the same and the PAPI had only been activated for minutes. Yet the NSTB report makes a conclusive statement as to what the PAPI was indicating at the time.
I have to say it, because I see it so often in relation to pilot CVD: I believe the NTSB's conclusive statement to be intellectually dishonest.
Testing of the same brand and model of PAPI lights by Transport Canada, as per Aerodrome Safety Circular No. 98~002 (Attachment #3) revealed that:
- Contaminants such as ice, dew or frost on the PAPI front lens surface does affect the projected signal.
- the testing concluded that false slope indication produced as a result of contamination on the lens is a design problem.
- Contaminants such as ice, dew or frost on the PAPI front lens surface does affect the projected signal.
- the testing concluded that false slope indication produced as a result of contamination on the lens is a design problem.
The aircraft was on approach near dawn when the temperature and dew point were the same and the PAPI had only been activated for minutes. Yet the NSTB report makes a conclusive statement as to what the PAPI was indicating at the time.
I have to say it, because I see it so often in relation to pilot CVD: I believe the NTSB's conclusive statement to be intellectually dishonest.
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Lots of news to report. There will be a CVDPA webcast on Wednesday 13 December from 1830 AEDT:
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Forgive me if any of this has been asked before.
Is there any way around doing the CAD test? I live in Brisbane and can't afford to go to Sydney or Melbourne to do the test; however, the ACVA is offered in Brisbane, and I would much prefer to do that. The optometrist who did my lantern test said, "There's no point doing the CAD; you're just going to fail it."
Also, is there any way CASA will issue a restricted Class 1 if the applicant cannot afford to go and do these other tests? Will they consider issuing a Class 1 with the night flight restrictions for someone if they have completed the Ishihara and the lantern test?
Additionally, what are the requirements around maintenance of the lantern test equipment, and can anything be done to improve the standard of the test? I did it at QUT here in Brisbane, and the machine didn't work until it got a solid thump, and then the white was more of a brownish-yellow rather than the white light I was expecting. The lights also were flickering as if the bulbs were close to failure, or the power source was being interrupted.
Is there any way around doing the CAD test? I live in Brisbane and can't afford to go to Sydney or Melbourne to do the test; however, the ACVA is offered in Brisbane, and I would much prefer to do that. The optometrist who did my lantern test said, "There's no point doing the CAD; you're just going to fail it."
Also, is there any way CASA will issue a restricted Class 1 if the applicant cannot afford to go and do these other tests? Will they consider issuing a Class 1 with the night flight restrictions for someone if they have completed the Ishihara and the lantern test?
Additionally, what are the requirements around maintenance of the lantern test equipment, and can anything be done to improve the standard of the test? I did it at QUT here in Brisbane, and the machine didn't work until it got a solid thump, and then the white was more of a brownish-yellow rather than the white light I was expecting. The lights also were flickering as if the bulbs were close to failure, or the power source was being interrupted.
Don’t bank on any help from AVMAD
Missing Aileron - “Forgive me if any of this has been asked before.”
Sorry can’t help with specific answers but the only real hope of changing CASA’s capricious disregard for its own regulation, that third option specifying an operational test, is by creating political and media pressure. It would seem beyond belief that having at long last achieved a proven operational test, and written same into its regulations, that CASA has negated this and is causing unnecessary grief to so many pilots. I personally have good colour vision but watch with dismay how CASA’s irresponsible decisions have done such harm to GA in particular and so many individuals in the aviation community.
The independent corporate regulator, a concept that flies in the face of the Westminster system, is a failed model of governance. The main arms of government should be within Departments with a responsible Minister at head. If we want real improvements we must engage with our Representative MPs, if they don’t know what is happening then how does democracy work?
Sorry can’t help with specific answers but the only real hope of changing CASA’s capricious disregard for its own regulation, that third option specifying an operational test, is by creating political and media pressure. It would seem beyond belief that having at long last achieved a proven operational test, and written same into its regulations, that CASA has negated this and is causing unnecessary grief to so many pilots. I personally have good colour vision but watch with dismay how CASA’s irresponsible decisions have done such harm to GA in particular and so many individuals in the aviation community.
The independent corporate regulator, a concept that flies in the face of the Westminster system, is a failed model of governance. The main arms of government should be within Departments with a responsible Minister at head. If we want real improvements we must engage with our Representative MPs, if they don’t know what is happening then how does democracy work?
Missing aileron
The news is not good in the short term, but lots of work is being done behind the scenes to restore the OCVA as a – hopefully the – third tier test. The following is based upon what CASA has been doing rather than what it’s been saying.
At the moment, there is no way of doing the ACVA instead of the CAD as a third tier test, because the zealots have a ‘policy’ of not taking into consideration the results of the ACVA until the candidate has failed the CAD and, therefore, the candidate has already been assessed by the zealots as not meeting the colour perception criterion.
I know this won’t help much, but you confirm an important point I made in recent correspondence.
As background to what I’m about to say, CASA recently sent the CVDPA a document described as an outline of “the process taken to review the CASA operational colour vision assessment (OCVA) and develop a proposal for a replacement.” One of the very telling parts of that document is under the heading “Validation and Future Work” at page 19, with my italics added:
It's worth reading all that quoted text twice and the italicised text a third time. The suggestion is that the ACVA results data will eventually be used as a validation and justification for using CAD results alone! That is not ‘strengthening’ the OCVA. That’s putting whitewash over a test that does not simulate an operational situation in accordance with the ‘third tier’ test provision in the law.
And I cannot help but point out what I assume is the unintended irony in the author’s comment about the ACVA being “an expensive and time-consuming test” as if the CAD – available at only two locations in Australia at around $500 a pop on top of travel time and expenses - isn’t expensive and time consuming. That kind of comment is the understandable product of a process in which those whose interests are directly affected have been completely ignored. If one were to ask the guinea pigs in this experiment – e.g. you, Missing aileron - what they would prefer as a ‘third tier’ test: the time and expense of an OCVA or the time and expense of the CAD; the entirely predictable outcome will not be overwhelming support for the CAD. Indeed, that has already been proven during the brief period of enlightenment during which CASA treated the OCVA as a ‘third tier’ test.
You go on to say:
And that demonstrates how the zealots have perverted the legislated process for demonstration of compliance with the colour perception criterion in the legislated medical standard. Instead of the third tier test being a simulated operational situation the results of which test demonstrate compliance or non-compliance with the colour perception criterion, the third tier test imposed by the zealots is a diagnostic test used to assess compliance with their personal interpretation of chapter 6 of Annex 1 of the ICAO Convention.
I’d suggest that you write to CASA and ask. If the zealots were left to their own devices, I’d anticipate that the answer would be a categorical NO! But there has been and continues to be a flurry of activity in the wake of the exposure of the fact that the zealots had no intention of ‘strengthening’ the OCVA as a ‘third tier’ test.
In my opinion, any professional purporting to administer a test the results of which can be used to ‘make or break’ someone’s career is under a duty to ensure the equipment used in the test has been maintained (and calibrated if necessary) and is functioning properly during the test. I’d be asking the QUT whether it is satisfied the equipment has been maintained (and calibrated if necessary) and is functioning properly. Is there any other administrator of the test within practicable reach?
All of that said: The best outcome for you and every other pilot and aspiring pilot with CVD would be the restoration of the OCVA as a – hopefully the – third tier test. So please write to all your Senators and your MHR and explain what you’re being put through, and support the CVDPA in its endeavours in your interests.
The news is not good in the short term, but lots of work is being done behind the scenes to restore the OCVA as a – hopefully the – third tier test. The following is based upon what CASA has been doing rather than what it’s been saying.
Is there any way around doing the CAD test?
I live in Brisbane and can't afford to go to Sydney or Melbourne to do the test; however, the ACVA is offered in Brisbane, and I would much prefer to do that.
As background to what I’m about to say, CASA recently sent the CVDPA a document described as an outline of “the process taken to review the CASA operational colour vision assessment (OCVA) and develop a proposal for a replacement.” One of the very telling parts of that document is under the heading “Validation and Future Work” at page 19, with my italics added:
It would be ideal, prior to making the ACVA available for use, to validate its performance by building up a data set of test results flown with colour normal pilots and colour vision deficient pilots. Unfortunately, this is beyond the scope of Phase I of this project.
If the ACVA is made available for use, this validation work could be included in the evaluation of the test at some point in the future. Of most use would be the ability to compare applicant CAD results with their ACVA test results. A large enough data set would allow determination at what CAD score an applicant is certain to fail the ACVA. The ideal outcome from this work would allow the ACVA (an expensive and time-consuming test) to be retired as a known pass/fail threshold using a lab-based test would have been determined.
If the ACVA is made available for use, this validation work could be included in the evaluation of the test at some point in the future. Of most use would be the ability to compare applicant CAD results with their ACVA test results. A large enough data set would allow determination at what CAD score an applicant is certain to fail the ACVA. The ideal outcome from this work would allow the ACVA (an expensive and time-consuming test) to be retired as a known pass/fail threshold using a lab-based test would have been determined.
And I cannot help but point out what I assume is the unintended irony in the author’s comment about the ACVA being “an expensive and time-consuming test” as if the CAD – available at only two locations in Australia at around $500 a pop on top of travel time and expenses - isn’t expensive and time consuming. That kind of comment is the understandable product of a process in which those whose interests are directly affected have been completely ignored. If one were to ask the guinea pigs in this experiment – e.g. you, Missing aileron - what they would prefer as a ‘third tier’ test: the time and expense of an OCVA or the time and expense of the CAD; the entirely predictable outcome will not be overwhelming support for the CAD. Indeed, that has already been proven during the brief period of enlightenment during which CASA treated the OCVA as a ‘third tier’ test.
You go on to say:
The optometrist who did my lantern test said, "There's no point doing the CAD; you're just going to fail it."
Also, is there any way CASA will issue a restricted Class 1 if the applicant cannot afford to go and do these other tests? Will they consider issuing a Class 1 with the night flight restrictions for someone if they have completed the Ishihara and the lantern test?
Additionally, what are the requirements around maintenance of the lantern test equipment, and can anything be done to improve the standard of the test? I did it at QUT here in Brisbane, and the machine didn't work until it got a solid thump, and then the white was more of a brownish-yellow rather than the white light I was expecting. The lights also were flickering as if the bulbs were close to failure, or the power source was being interrupted.
All of that said: The best outcome for you and every other pilot and aspiring pilot with CVD would be the restoration of the OCVA as a – hopefully the – third tier test. So please write to all your Senators and your MHR and explain what you’re being put through, and support the CVDPA in its endeavours in your interests.
Last edited by Clinton McKenzie; 3rd Jan 2024 at 21:13.
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I can't thank CVDPA enough for the continued efforts to challenge the completely outdated CV standard. I'm one of the lucky ones who, due top previous AAT decisions, has managed to have a fulfilling career at all levels of Aviation from GA to high capacity international RPT. Without Arthur and others paving the way this would not have been possible. Anyone that has doubts can PM me. Get behind these amazing people and give them some support
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The standard isn't the problem, Bill. The colour perception criterion in each of the legislated medical standards (in Part 67 of CASR) and the legislated means of demonstration of compliance with the criterion (also in Part 67 of CASR) have not changed in decades. All that's changed is the people and their personal opinions in CASA.
CASA seems adept at leaving AvMed to its own devices to implement the personal opinions of the staff, rather than explaining to them that they are public officials with duties to, among other things, administer the law in its terms, whether or not the staff personally agree with the policy already given effect to in the law. In short, there's inadequate governance around them.
The latest crusade against CVD was mounted on a pretext and has cost a couple of years and hundreds of thousands of dollars to produce an outcome that bears no semblance to what outsiders were told was going on. Rather, it bears an uncanny semblance to the outcome sought to be achieved by mercifully long-gone zealots like Navathe and Drane (whom, I understand, are erstwhile colleagues of none other than Hochberg). (Our Kiwi cousins must laugh - diplomatically - each time CASA takes one of these people off the Kiwis' hands.) They haven't been working on strengthening to OCVA. They've ditched it. We're back to the CAD as a weapon to cull candidates who don't meet the zealots' personal interpretation of chapter 6 of annex 1 to the ICAO convention. Apparently, no one in a position of authority has tapped them on the shoulder to point out that the people actually responsible for deciding on how Australia gives effect to chapter 6 of annex 1 - including the colour perception criterion - have already done that in the form of a thing called "the law". That's what Part 67 is.
Apparently, Ms Spence was unaware of what was going on. Hence my point about governance.
One of the reasons for CASA AvMed's abysmal 'service delivery' metrics is the amount of time (and money) it wastes - to pick up on an earlier metaphor - dying on stupid hills like CVD. If they'd just concentrate on doing their jobs - administering the legislated medical standards in accordance with the legislation - rather than mounting crusades to save the world through implementation of their own personal opinions, the metrics might be less abysmal:
Class 1 medical certificate (target 20 days) – 56% (down from 61%)
Class 2 medical certificate (target 20 days) – 47% (down from 53%)
Class 3 medical certificate (target 20 days) – 43% (down from 59%)
CASA seems adept at leaving AvMed to its own devices to implement the personal opinions of the staff, rather than explaining to them that they are public officials with duties to, among other things, administer the law in its terms, whether or not the staff personally agree with the policy already given effect to in the law. In short, there's inadequate governance around them.
The latest crusade against CVD was mounted on a pretext and has cost a couple of years and hundreds of thousands of dollars to produce an outcome that bears no semblance to what outsiders were told was going on. Rather, it bears an uncanny semblance to the outcome sought to be achieved by mercifully long-gone zealots like Navathe and Drane (whom, I understand, are erstwhile colleagues of none other than Hochberg). (Our Kiwi cousins must laugh - diplomatically - each time CASA takes one of these people off the Kiwis' hands.) They haven't been working on strengthening to OCVA. They've ditched it. We're back to the CAD as a weapon to cull candidates who don't meet the zealots' personal interpretation of chapter 6 of annex 1 to the ICAO convention. Apparently, no one in a position of authority has tapped them on the shoulder to point out that the people actually responsible for deciding on how Australia gives effect to chapter 6 of annex 1 - including the colour perception criterion - have already done that in the form of a thing called "the law". That's what Part 67 is.
Apparently, Ms Spence was unaware of what was going on. Hence my point about governance.
One of the reasons for CASA AvMed's abysmal 'service delivery' metrics is the amount of time (and money) it wastes - to pick up on an earlier metaphor - dying on stupid hills like CVD. If they'd just concentrate on doing their jobs - administering the legislated medical standards in accordance with the legislation - rather than mounting crusades to save the world through implementation of their own personal opinions, the metrics might be less abysmal:
Class 1 medical certificate (target 20 days) – 56% (down from 61%)
Class 2 medical certificate (target 20 days) – 47% (down from 53%)
Class 3 medical certificate (target 20 days) – 43% (down from 59%)
The following 2 users liked this post by Clinton McKenzie:
Thank you for your response, Clinton. That's all very valuable information. The work you guys are doing is fantastic, and I truly do hope CASA wakes up and implements some more modern medical standards. I am still a fairly new pilot (95ish hours). However, I've had the opportunity to fly all over the country in a variety of different aircraft from single pistons to multi-jets (most as a passenger). While doing that, though, I've been exposed to IFR and VFR conditions both day and night, and neither myself nor the pilot have found anything I can't see in an operational environment. When the ACVA becomes available as the next step, I am confident I will pass it.
In part 67, subpart 67.150 of the CASR, it says the following:
I'm just a dumb pilot, not a lawyer, but I don't see any mention of the CAD test in there... Is there a way to argue that the CAD test is not simulating an operational situation? In the video you posted above, you mentioned that the inventor of the CAD test has even stated in court that it does not simulate an operational situation. Again, I'm no lawyer, but to me, it seems like CASA is ignoring their own regulations to prohibit people from obtaining their medical, despite the fact that we can safely operate an aircraft... If I am right, shouldn't the law overrule the CASA policy?
I will contact QUT about their equipment; currently, to my knowledge, the only other place in QLD that offers the lantern test is Townsville. I will also contact CASA about issuing a restricted Class 1 medical and see what they say.
In part 67, subpart 67.150 of the CASR, it says the following:
(6) A person must demonstrate that he or she meets the criterion in item 1.39 of table 67.150 by:
(a) in daylight, or artificial light of similar luminosity, readily identifying a series of pseudo‑isochromatic plates of the Ishihara 24‑plate type, making no more than 2 errors; or
(b) for somebody who makes more than 2 errors in a test mentioned in paragraph (a), readily identifying aviation coloured lights displayed by means of a Farnsworth colour‑perception lantern, making:
(i) no errors on 1 run of 9 pairs of lights; or
(ii) no more than 2 errors on a sequence of 2 runs of 9 pairs of lights; or
(c) for somebody who does not satisfy paragraph (a) or (b), correctly identifying all relevant coloured lights in a test, determined by CASA, that simulates an operational situation.
(a) in daylight, or artificial light of similar luminosity, readily identifying a series of pseudo‑isochromatic plates of the Ishihara 24‑plate type, making no more than 2 errors; or
(b) for somebody who makes more than 2 errors in a test mentioned in paragraph (a), readily identifying aviation coloured lights displayed by means of a Farnsworth colour‑perception lantern, making:
(i) no errors on 1 run of 9 pairs of lights; or
(ii) no more than 2 errors on a sequence of 2 runs of 9 pairs of lights; or
(c) for somebody who does not satisfy paragraph (a) or (b), correctly identifying all relevant coloured lights in a test, determined by CASA, that simulates an operational situation.
I will contact QUT about their equipment; currently, to my knowledge, the only other place in QLD that offers the lantern test is Townsville. I will also contact CASA about issuing a restricted Class 1 medical and see what they say.
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As I’ve noted before, MI, the medical standards haven’t changed in years. All that changes is the people and their personal opinions in CASA.
There was a brief period of enlightenment during which CASA administered the OCVA as a ‘third tier’ test. That occurred because there was a critical mass of people who understood their job was to implement the legislated means of demonstration of compliance with the legislated medical standards. Now there’s (again) a critical mass of people who believe their job is to implement their personal opinions on the colour vision requirements of the ICAO convention.
The CAD does not simulate an operational situation in fact. Everybody knows it.
Why do the zealots nonetheless pretend it does? Because they can. They know how prohibitively stressful and expensive it is for individuals to challenge them. And the zealots will die on the stupid hill of defending the CAD when that challenge comes. (This is one of the reasons the AvMed ‘service’ metrics are abysmal. They spend so much time on their personal crusades rather than their jobs.)
Don’t be fooled into believing the ACVA is some panacea. The zealots will only take the results of the ACVA into account after the candidate has already failed the CAD and therefore been assessed as not meeting the colour perception criterion. The ACVA is just an exercise in data gathering and justification for the restrictions that will be placed on you.
The zealots’ plan is that you will have to endure the expense and inconvenience of the CAD and the ACVA. You will then be extraordinarily lucky to get a medical certificate allowing you to fly at night.
CVDPA member Simon Choice passed the OCVA and the ACVA but AvMed still imposed a CVD-related ‘restriction’ on his medical certificate. Please read that sentence as many times as is necessary to convince you that you need to start fighting for yourself along with CVDPA.
There was a brief period of enlightenment during which CASA administered the OCVA as a ‘third tier’ test. That occurred because there was a critical mass of people who understood their job was to implement the legislated means of demonstration of compliance with the legislated medical standards. Now there’s (again) a critical mass of people who believe their job is to implement their personal opinions on the colour vision requirements of the ICAO convention.
The CAD does not simulate an operational situation in fact. Everybody knows it.
Why do the zealots nonetheless pretend it does? Because they can. They know how prohibitively stressful and expensive it is for individuals to challenge them. And the zealots will die on the stupid hill of defending the CAD when that challenge comes. (This is one of the reasons the AvMed ‘service’ metrics are abysmal. They spend so much time on their personal crusades rather than their jobs.)
Don’t be fooled into believing the ACVA is some panacea. The zealots will only take the results of the ACVA into account after the candidate has already failed the CAD and therefore been assessed as not meeting the colour perception criterion. The ACVA is just an exercise in data gathering and justification for the restrictions that will be placed on you.
The zealots’ plan is that you will have to endure the expense and inconvenience of the CAD and the ACVA. You will then be extraordinarily lucky to get a medical certificate allowing you to fly at night.
CVDPA member Simon Choice passed the OCVA and the ACVA but AvMed still imposed a CVD-related ‘restriction’ on his medical certificate. Please read that sentence as many times as is necessary to convince you that you need to start fighting for yourself along with CVDPA.
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Thread Starter
Update following meeting with CASA
Last week CVDPA directors Dr Arthur Pape, Clinton McKenzie and myself met with CASA CEO Pip Spence and some of her senior managers in Canberra to discuss this ongoing CVD debacle.. During this meeting we made our views very clear that we will accept nothing less than the removal of the CAD test as a 'third tier' test and the reinstatement of a valid operational test in its place, which once passed will result in a full unrestricted medical insofar as colour vision is concerned.
CVDPA intends to host another live web broadcast on around the 14th February (TBC) by which time we expect to have more to report, but for now we can advise the following as a result of our recent meeting and confirmed in a follow up email from Ms Spence. Stay tuned for more details regarding our next web broadcast over the coming week.
Current Status:
CVDPA ADVICE TO ALL CVD PILOTS:
One of the remarkable statements by Ms Spence during her follow up email to us is that "no test is currently being applied as a 'third tier' test under CASR 67.150 (6)(c)."
Could anyone anyone who has received recent correspondence from CASA (within the last two months) describing the CAD as a 'third tier' or 'third level' test that must be undertaken and passed in order to be assessed as meeting the colour perception criterion, please contact CVDPA? Feel free to email me at [email protected].
In the meantime, we would advise:
John O'Brien
CVDPA intends to host another live web broadcast on around the 14th February (TBC) by which time we expect to have more to report, but for now we can advise the following as a result of our recent meeting and confirmed in a follow up email from Ms Spence. Stay tuned for more details regarding our next web broadcast over the coming week.
Current Status:
- CASA are considering our input and and are currently preparing to present a recommendation for sign-off at an upcoming Aviation Safety Committee (ASC) meeting in the first week of Feb
- NO test is currently being applied as a 'third tier' test under CASR 67.150 (6)(c)
- CASA purport to be considering each new applicant on a case-by-case basis and have not changed existing conditions for any pilots who renewed
- CASA advise that they will engage with CVDPA again to confirm what they propose to do
- CASA's (non) answers to Senator Fawcett's questions on notice from the October Estimates hearings were recently published:
- CASA is next scheduled to appear before Senate Estimates again on 12/13 February during which it is possible that CVD issues will again be raised
CVDPA ADVICE TO ALL CVD PILOTS:
One of the remarkable statements by Ms Spence during her follow up email to us is that "no test is currently being applied as a 'third tier' test under CASR 67.150 (6)(c)."
Could anyone anyone who has received recent correspondence from CASA (within the last two months) describing the CAD as a 'third tier' or 'third level' test that must be undertaken and passed in order to be assessed as meeting the colour perception criterion, please contact CVDPA? Feel free to email me at [email protected].
In the meantime, we would advise:
- Do not do any test other than Ishihara and Farnsworth, unless CASA has represented to you, in writing, that: (1) the other test has been determined as a third tier test in accordance with CASRs 67.150(6)(c) and 67.155(6)(c); and (2) if you pass the test you will be issued with a ‘clean’ certificate so far as colour vision is concerned (that’s what the law requires CASA to do). Any other test will merely be a waste of your time and money and be used by AvMed to decide how much to restrict you, having already decided you don’t meet the standard.
- Prior to doing the Ishihara test using the paper book, confirm with the DAME that the book has not passed its ‘use by’ date (this is not a joke!) and ensure the the lighting conditions are adequate.
- Before you do Farnsworth, confirm, with the administrator of the test, that the equipment is functioning properly.
- Unless and until CASA has again determined a proper test simulating an operational situation in terms of CASRs 67.150(6)(c) and 67.155(6)(c) - such as the previously-administered OCVA - candidates with CVD are better off going to New Zealand or the USA to obtain/maintain their qualifications and medical certification
John O'Brien
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