TelBoy

Thank you 2close for that post, it is VERY interesting.
I have noted below the general requirements from that specific document, and really these read totally differently to the specifics, which are as you say JAA FCL3. In fact the General Requirements I do believe are ICAO Air Navigation Order requirements?? And we know how the JAA bastardised them!

MED.B.070 paragraph c is the killer for us with restricted class 1 CAA medicals. It does seem from this that we will loose them!

As this is a draft document I feel that it is time for us all to stand up and be counted. The reality is that CVD pilots and colour vision testing/requirements make up such a small part of the job the EASA has ahead it will easily get swept aside. We ALL need to make are feelings known to the EASA now so that it gets noticed. Those earning a living from their restricted class 1 need to make it known that they will bring legal action and indeed should they loose their medicals through a needless change in regulation. There is a human rights issue for taking a livelihood away from a person who has successfully completed training and is working without problems in that environment.

GENERAL REQUIREMENTS

MED.A.010 (on page 3)
For the purposes of this part, the following definitions apply:
‘Colour safe’ means the ability of an applicant to readily distinguish the colours used in air navigation and correctly identify aviation coloured lights.

MED.B.070 Colour Vision (on page 16)
(a) Applicants shall be required to demonstrate the ability to perceive readily the colours that are necessary for the safe performance of duties.
(b) Examination
(1) Applicants shall pass the ishihara test for initial issue of a medical certificate.
(2) Applicants who fail to obtain a satisfactory result in the ishihara test shall undergo further colour perception testing to establish whether they are colour safe.
(c) In the case of class 1 medical certificates, applicants shall have normal perception of colours, or be colour safe. Applicants who fail further colour perception testing shall be assessed as unfit.
(d) In the case of class 2 medical certificates, when the applicant does not have satisfactory perception of colours, their flying privileges shall be limited to daytime only.

Section 1 Specific requirements are as 2close post

2close

Hi troops,

I've extracted all of the relevant sections of the NPA below.

I leave it to you to interpret those sections as you wish but I think I would agree with Telboy - the end of deviations for Class 1 medicals is now upon us.

2close



NOTICE OF PROPOSED AMENDMENT 2008-17

C. DRAFT OPINION AND DECISION PART MEDICAL

I Draft Opinion Part Medical

Annex II to the Implementing Regulation

PART MEDICAL

SUBPART A - GENERAL REQUIREMENTS

Section 1 - General

MED.A.010 Definitions

For the purposes of this Part, the following definitions apply:

‘Colour safe’ means the ability of an applicant to readily distinguish the colours used in air navigation and correctly identify aviation coloured lights.



MED.A.020 Medical certification

(c) Applicants for and holders of a private pilot licence (PPL) shall hold a valid class 2 medical certificate.

(e) If a night flying qualification is added to a PPL or LPL, the pilot shall be colour safe.

(f) Applicants for and holders of a commercial pilot licence (CPL), a multicrew pilot licence (MPL), or an airline transport pilot licence (ATPL) shall hold a valid class 1 medical certificate.

(h) A pilot shall not hold more than one valid medical certificate at any time.

MED.A.045 Limitations to medical certificates

(a) Limitations to class 1 and class 2 medical certificates

(1) When, in accordance with the aeromedical examinations and assessments, the applicant does not fully comply with the requirements for the relevant class of medical certificate but is considered to be not likely to jeopardise flight safety the AeMC or AME shall:

(i) in the case of applicants for a class 1 medical certificate refer the decision on fitness of the applicant to the licensing authority as indicated in Subpart B, except those requiring a limitation related only to the use of corrective lenses;

(ii) in the case of applicants for a class 2 medical certificate, evaluate whether the applicant is able to perform their duties safely when complying with one or more limitations endorsed on the medical certificate, and issue the medical certificate with limitation(s) as necessary.

(2) When assessing whether a limitation is necessary, particular consideration shall be given to:

(i) whether accredited medical opinion indicates that in special circumstances the applicant’s failure to meet any requirement, whether numerical or otherwise, is such that exercise of the privileges of the licence applied for is not likely to jeopardise flight safety;

(ii) the applicant’s ability, skill and experience relevant to the operation to be performed.


(c) Limitation codes

(1) Operational multipilot limitation (OML)

(2) Operational Safety Pilot Limitation (OSL).

(3) Other limitations may consist of:

(vi) a restriction to operate only without passengers (OPL) in the case of PPL or LPL;

(viii) a restriction to operate during day only (VCL); or

(4) Any other limitation may be imposed on the holder of a medical certificate if required to ensure flight safety.

(d) Any limitation imposed on the holder of a medical certificate shall be specified therein.

Subpart B - REQUIREMENTS FOR MEDICAL CERTIFICATES

Section 1 - General

MED.B.070 Colour vision

(a) Applicants shall be required to demonstrate the ability to perceive readily the colours that are necessary for the safe performance of duties.

(b) Examination

(1) Applicants shall pass the Ishihara test for the initial issue of a medical certificate.

(2) Applicants who fail to obtain a satisfactory result in the Ishihara test shall undergo further colour perception testing to establish whether they are colour safe.

(c) In the case of class 1 medical certificates, applicants shall have normal perception of colours or be colour safe. Applicants who fail further colour perception testing shall be assessed as unfit.

(d) In the case of class 2 medical certificates, when the applicant does not have satisfactory perception of colours, their flying privileges shall be limited to daytime only.



II Draft Decision AMC and GM for PartMedical

AMC / GM to PARTMEDICAL

SUBPART A - GENERAL REQUIREMENTS

Section 1 - General

AMC to MED.A.045

Limitations to class 1, class 2 and LPL medical certificates

(a) An AeMC or AME may refer the decision on fitness of the applicant to the licensing authority in borderline cases or where fitness is in doubt.

(b) In cases where a fit assessment can only be considered with a limitation, the AeMC, AME or the licensing authority should evaluate the medical condition of the applicant in consultation with flight operations and other experts if necessary.


Subpart B - REQUIREMENTS FOR MEDICAL CERTIFICATES

Section 1 - Specific requirements for class 1 and class 2 medical certificates

Chapter A - AMC for Class 1 medical certificates

AMC A to MED B.070

COLOUR VISION class 1 medical certificates

1. At revalidation colour vision should be tested on clinical indication.

2. The Ishihara test (24 plate version) is considered passed if the first 15 plates, presented in a random order, are identified without error.

3. Those failing the Ishihara test should be examined either by:

(i) Anomaloscopy (Nagel or equivalent). This test is considered passed if the clour match is trichromatic and the matching range is 4 scale units or less, or by

(ii) Lantern testing. This test is considered passed if the applicant passes without error a test with accepted lanterns.

Chapter B - AMC for Class 2 medical certificates

AMC B to MED B.070

COLOUR VISION class 2 medical certificates

1. At revalidation colour vision should be tested on clinical indication.

2. The Ishihara test (24 plate version) is considered passed if the first 15 plates, presented in a random order, are identified without error.

Neo_RS14

Blinkz: I would of thought the standard JAR lanterns only (Beynes, HW, Spectrolux). But, I imagine these regulations are drafted to include the results from CAD testing, and probably the anomaloscope too.

A big thanks to 2close and Telboy for their input on this, I'd be inclined to agree with you both in that if there ever was a time to be prepared to stand up and have your say, now would be it. I would also agree that this could be a human rights issue, at times like this, we cannot forget how things are elsewhere in the world for people with our dreaded infliction...because after drawing that comparison, we really begin to realise how (ahem) 'messed up' things are for us

‘Colour safe’ means the ability of an applicant to readily distinguish the colours used in air navigation and correctly identify aviation coloured lights

Hmmm, well I guess the FAA must have thought something similar to this when they devised the very fair, practical and succesful system of Tower Signal Light testing...afterall, what actual air navigation or aviation coloured lights are we tested on in JAA colour perception tests? Surely that is the ONLY way to assess whether a candidate is fit/unfit, to see whether he can succesfully identify actual aviation lights, rather than via largely academic tests. Sure, use the tests for screening and assessment, fair enough....but to put the final stamp (colour unsafe) on an individual based SOLELY on these tests, without giving the person an opportunity to decipher real aviation signals, especially when this takes place everyday elsewhere in the world, seems grossly unfair to me. In fact I'd say it even goes beyond being merely unfair now, and that it actually constitutes discrimination.

I mean what is it about the air over the US and Australia that differs from our Euro air, where in theirs CVDs are able to fly professionally quite safely, and without any accidents solely casued by CVD, yet in Europe, the air is different and it's not safe for us to do so....I've never been able to work this one out.

The fun continues

Back to flying

Hi all..

Does anybody knows what JAA exactly means by the next phrase?

"At revalidation colour vision should be tested on clinical indication."

clinical indication?? what´s that?


Also, who has an answer for my next two questions:

If you do not pass Ishihara´s but passed an approved JAA lantern "x" (as colour safe), will they make you pass that lantern test again or any other test every time they decide to test you on colour vision?

Next one:

If you passed an approved JAA lantern "x" and the mentioned new testing comes over (i.e CAD). If you do not pass new "CAD" but passed an approved JAA lantern "x" at your initial medical check, will they make you colour unsafe?

Thanks
BTF

TelBoy

BTF

You only (usually) need to pass an approved colour vision test at the initial medical and will never have to take another.

It is seen that CVD is an inherited trait that does not change with age. In fact colour vision for everyone can change with age, but that bit is ignored and as it is usually a yellow deficiency, would not show at ishihara or probably the lanterns. Interestingley, it would in the new CAD test!!

If the examiner feels there are clinical grounds that you might have diminished colour vision say because of disease or poisining etc then they will retest you, but I think it is very rare.

If you have passed the colour vision of your initial class 1 then you will not have to take any more tests when the CAD is introduced. If you failed all the CV tests, you should be allowed to try the CAD when it comes in which if you pass will remove colour vision restrictions.

I did touch upon yellow dficiencies. These are not screened by ishihara or lanterns so someone with a yellow or blue problem can pass - at the moment! The new CAD test will show these as well as red/green. In fact the CAA have told me that they are looking to replace ishihara with a shortened version on the CAD. The CAA do however not see yellow or blue as critical in aviation! humm taxiway lights??

PPRuNeUser0161

Neo
The number of CVD pilots flying in the states would be in the thousands. I personally don't think that ICAO can apply enough pressure to force the FAA to change its stance on CV testing. Australia is similar, I think we only need one other ICAO member state on board and the pressure will be firmly on the UK CAA and ICAO to stop discriminating against those who have a very common disadvantage. We need to make sure that the design of aircraft and aviation infrastructure is such that colour perception is taken out of the equasion. If you think about it we are very close to that situation now.

Colour vision varies under ambient conditions even for those with "normal" colour vision. The manufacturers should be given criteria that the design of aircraft instrumentation must comply with. If they want to see the misreading of colour causing accidents then colour code the flight-deck and take out the raw data. See what happens then.

Overdrive

I tell you what would kill the landing light problem stone dead for ever. The green lights (or when showing green)... stick a cheap, semi-circular dark blue filter over half of the green lamp, or a just wedge of coloured self-adhesive cellophane. to make a turquoisey blue. Then both the red-green area guys, and those with the very rare blue trouble would be proveably 100% fine. In fact a 120 degree filter would be enough.

In discussions years back, the idea of changing lamp colours was raised. The CAA didn't mention cost, but did say words to the effect that the instinctive perception and understanding of the meaning of red and green is so entrenched as to be unopen to question, which has some validity.

On a global or even country scale this would seem a huge undertaking, but in fact would be no more than a few quid per lamp. The bureaucracy, communication and attendant faffing is another matter.

It's very difficult to explain to many colour-normal people that in most situations, colour deficiency is not a problem. Glass cockpits are such a situation I believe, but that's a discussion for later... 'cos I am about to eat!

TelBoy

Yep - we even buy colour TV's

PPRuNeUser0161

Overdrive
The meaning of Red and Green generally is entrenched. But this is aviation and we are professionals. Rules change all the time. I can tell you that to research and justify to ICAO a CAD based colour vision test that is not going to fix the problem and will be very expensive. The fact that the Papi is red and white is an example that we are adaptable, easy just change the rules and send a letter to every pilot, done. The light signals are used so often that most pilots have forgotten what they mean and the lamps in the towers are covered with dust.

If they were serious about red and green the Papi system would have been designed to show 4 greens when "on-slope". But the designers knew that green and red are easily mixed up even for colour normal’s under some conditions and therefore the approach would not be fool-proof, which it isn’t anyway. They have designed the Papi to show both colours together so that you can see which is which even in dusty conditions and this reduces the risk of a mix up. If you see all one colour then you better check the radalt because you screwed it up before you got to the Papi. Remember the Papi is for within 5nm unless you've got an ILS (7nm).

Better still get rid of the Papi and stick with the Vasi, it's a far better system, more expensive but very reliable and does not discriminate. I see we provide wheel chair access to toilets for those who cannot walk and subsidise dogs for those who cannot see, why not make the workplace colour vision friendly?

Neo_RS14

Some very good points you've raised there guys. Sadly they are highly unlikely (at this point in time imo) to even consider changing the colours of any approach lighting systems. I take your point about equality in the workplace too Soup Nazi, you are quite right. The thing is, despite what the academic tests deem us, we are (probably 99% of the time) fit for work on a professional flight deck anyway (statement based on the thousands of pilots passing the tower signal test). Now I know that ŁŁŁŁ's have been spent to research this area and to ultimately engineer a new colour perception testing method which will be more fair than previous contraptions...and I'm sure in light of this, many medical professionals in the industry are probably thinking "Christ! What more do they want?"...But if they were to look at it from our point of view, a study uncovered several core areas which are vital, in terms of the pilot being able to correctly discern the colours presented to them...Surely it is only right then, for the CVD candidate to be assessed for fitness by sitting some test which is based on these core areas (physically), and thus is directly relevant to/and reflective of "the tasks of an airman".

The test should basically replicate the pilot on the flight deck, perceiving these lights as they appear in reality, not in the form of little flashing lights on a screen, or tiny lights at a distance which have had the wavelengths altered. The emphasis should be on real world testing, we should be moving away from academic testing for practical tasks. Esepcially if the costs of implementing such a system are going to be high anyway, why not get our heads together and re-think the best way to do this for good. Ha, I wrote that as if I have a say in the matter, I wish I did.

I know it could be done, a practical solution to this lies out there waiting to be discovered, something convenient for all involved. Its just a matter of a willingness to find the solution.

Soup Nazi, coming back to the first point you made there, where you approximated that we only need one more ICAO state to come on board with a more positive approach to CVD before the new understanding of the condition can spread globally...How certain are you of this? I hope I haven't misinterpreted what you wrote.

The UK could potentially be that nation, if that is the case. I mean we're currently the only state in JAA land allowing CVD deviations right? And if it were up to the UK alone, we would probably keep those deviations for good. Surely this demonstrates some understanding of the reality of the condition, and that it's actually not really a flight safety hazard. If only we could show them that many of us are safe to fly at night too. A new test/practical demonstration would be the answer, but is that likely to come into fruition after all the endeavours to bring out the CAD Well who cares what is likely, it's what is RIGHT that is important.

tarmac-

Hi guys..Sorry to jump right into the middle of a pritty interesting session going on here, however I myself have been noted CVD over here in New Zealand.. However I know myself I am only just colour blind, seeing as I can read 12-13 isihara plates no worries from the 15 they test. I think now that I have found the online plates, I can see where I've gone wrong

My question;

I have been to 2 different optomerists, both only just ruling me out. Now , do they generally hold onto your eye record, or foward this to the CAA, bearing in mind that I have not done a full medical as yet, just the Medical eye test and have not given them any doctors contact details etc.

Secondly, how often will I need to get this Colour Vision test done, seeing as I am keen to go get yet another test, and get the peice of paper I need.

Thanky-you


**edit**

Oh and also, do you think it is wise to call the CAA, give them my details, request if they have received any details from my "doctor" which I havnt seen obviously, or the optomitrist, and will they give this information out to me without to much of a drama...... Im really wanting to give this whole flying career a good shot, so need to get this stuff sorted first seeing as it could also be the end.


....continue

Overdrive

You would have to check with the NZ CAA regs, can't say I know for sure if/how they vary from the UK, but...

I doubt general optometrists would send records of results anywhere of their own volition, why would they? The CAA will want things done in their own way, which would mean Ishihara testing by an Aviation Medical Examiner or other approved facility (as part of a medical or separately). If this is failed, then lantern or other tests are done as required by level of licence sought, once only (almost certainly at CAA medical HQ). The result from this stands throughout your career. For this reason, arm yourself fully and thoroughly before undertaking any officially recorded testing. Read this long and comprehensive thread through too.

I wouldn't tell the CAA about anything that's occured in your testing so far, it's irrelevant to their process, but I would go online to their website for the details and info. If you have to speak to them by phone, just ask for the help you need in a general way, no personal details required...

tarmac-

Cheers bud..

As far as i know over here, the holmes wright lattern test does not give you a Unrestricted Class 1 Med, instead a Class 2 only for VFR, which is no good, hence if I can pass these Ishihara's, im pritty much sorted... Over in your country, is a eye test required yearly as apart of the full medical?(a standard eye test for eye sight including the Ishihara's) I really dont want to pass one year, then after completeing my CPL get stung by failling the Ishihara's rendering the whole process a waste... I guess if it did come down to that, I could always try get a Medical Converted from another country as other guys seem to be doing

Neo_RS14

Hi Tarmac,

What you've expressed there is a common fear of a CVD individual, as some countries do require some kind of colour assessment at renewals, which really does suck! (yes that is a technical term lol) Currently in the UK, we are not re-tested at renewals, as sensibly our deficiencies are deemed to be congenital and with us for life, which obviously is the case. In the States, they test at renewals, but if you have been succesful, you will have evidence of your success to present to the AME. I'm sorry but i really don't know the regulations in NZ, but I understand they are one of the less tolerant countries in this area. Best of luck with it mate.

tarmac-

Yeah, its not really a nice feeling to have it constantly lingering around in the back of my mind...

Anyway, i've decided to go for a retest this Friday, Get a medical done, and fire it off to the CAA.. If all CAA testing agencies use a 24 slide Ishihara, then I think I may just memorise the ones which are borderline for me, and be done with it, as any future test *should* be the same.. Worst case, move to australia, complete my CPL there, fly to which every country has a lattern test that I can pass, get my medical coverted and hopefully that will sort any problems ; lets hope it doesnt come down to it.

Will keep ya'll posted.

zacokeeffe

Hi all

I have an appointment on Tuesday in Holland to do the nagel anomaloscope. Just wondering has anyone done one of these and what is involved. Is there anyway to prepare for it? Also if I was within the allowed range would this mean I would be entitled to an unrestricted Class One?

Thanks

Zac

2close

Hi Zac,

The Nagel is by far the most difficult test to pass and many colour normal persons fail to reach the JAA Pass Standard.

There is nothing you can do to prepare for it.

You look through an eyepiece at a split field circle and the objective is to match the top and bottom semi-circles.

Even when you've matched them, you only have to move your eye a fraction and the semi-circles look different, in exactly the same way as an image on a computer monitor looks different when you view it from different angles. So, unles you know exactly where your eye is supposed to be in the first place you are immediately disadvantaged.

Sorry to be the bearer of such negative information.

2close

Overdrive

.


No, It's all good info 2close.

The Nagel test sounds to be almost irrelevant to most humans if it's as you say, except for finding people for the World Exceptional Vision Championships....

TelBoy

I have personally taken the Nagel twice at two different places using two different devices. Both are as said matching the top and bottom semi-circles.

The first device was like a microscope on its own. There are two knobs on each side to twist to get the colours to match. I found it VERY difficult to operate. The second was a computer controled scope. The computer gives you choices and you have an appropriate button to press. After the test the operator set the computer to show me what a "colour normal" would see. To ME it was a distinct red top and green bottom, but this is MY view of it - others will see it differently.

Hope this helps, but it is a very hard test.

Good luck for Tuesday and all the best for your future flying.

Neo_RS14

LOL Overdrive.

Yep, I've had a go on the 'scope too, may as well state my experience of it.

To be honest, I found it impossible. I'll explain...What happens when you look directly at a light bulb? yes that's right, you immediately get an after image, a blurry type thing in your field of vision...What happens when you look into a scope type device which inside is brightly illuminated, and you are situated in a dark room...hey, that's right...you get an after image. For me, this after image I incurred when looking into the anolaloscope made it impossible for me to give any good responses, as the blur tainted my view of the semi circles...the examiner was actually intrigued enough to invite me back for a re-test whenever I'm next in the area...I hope to take them up on this, but I'm not really looking forward to it, as unlike many other people, i found the test quite pointless, as I found the after image caused by the scope, caused me to give a grossly inaccurate response...as to how this can be the flagship of colour vision testing, I have no clue...doesn't say a lot for the area really, and that's not to discredit the individuals working in this area, I know they're well qualified and experienced individuals...I just find the tests are somewhat inappropriate.