The Empire Strikes Back! on Colour Defective Pilots
I fly a plane full of white, and some blue and amber switch lights on the overhead panel. The colours are supposed to indicate something...but really its the fact of illumination more than the colour.
On a few of ours, some lights that are supposed to be white are amber, three that are supposed to be blue are green. CASA is aware of this, and they are ok with it. So much for colours...
On a few of ours, some lights that are supposed to be white are amber, three that are supposed to be blue are green. CASA is aware of this, and they are ok with it. So much for colours...
Hang on, we're not making the point here that colours don't matter, are we?
What matters is a whether a person has the ability to perceive readily the meanings of the real-life signals, symbols and indications that are coloured, or depend on the differences between colours, and are necessary for the safe performance of duties.
Don't the focus on the means; focus on the ends.
The conga line of medical zealots and experts with their snout in the CVD industry trough focus on the means: There are coloured lights with meanings. Therefore a pilot with an inability to perceive the colours of those lights is scary-dangerous.
Objective people focus on the ends: Does a pilot perceive readily the meaning of real-life signals, symbols and indications that are coloured, or depend on the differences between colours, and are necessary for the safe performance of duties. If a candidate with CVD perceives, as efficiently and effectively as candidates without CVD, the meaning of those real-life signals, symbols and indications, there is no objective safey basis on which to discriminate against the candidate with CVD.
And we know what the first-hand, real-life evidence shows.
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CVD people may see what we know as green as being brown. However they know it's green because it's the same color as grass which everyone knows is green. It's a matter of perception being reality. Oh, and somebody told them that when they were kids.
ASI's are coded with both color and numbers. That argument doesn't count.
The CAsA stance is flawed in both science and common sense. It's a crock.
ASI's are coded with both color and numbers. That argument doesn't count.
The CAsA stance is flawed in both science and common sense. It's a crock.
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DAS announces AvMed review
Redix,
For a good read on the scientific flaws with the ICAO colour perception standard, check out this peer reviewed article written by Dr Pape a few years ago which was published in an aviation medicine journal:
Colour Perception Standards in Aviation: Some implications of the AAT decisions regarding colour perception and aviation
On another note, DAS Skidmore has just announced a review of the CASA AvMed department:
CASA Briefing - March 2015
If the new DAS is truly serious about making sure AvMed decisions are "evidence based", he would be well placed to look at Australia's 25 year history of CVD pilots operating safely and to take notice of the AAT's findings in CASA's three CVD losses (Pape, Denison & O'Brien) at the tribunal.
If he is serious about "consulting" with the aviation industry, a good starting point would also be for him to actually meet with Dr Pape and some of the many CVD professional pilots operating in this country to hear first hand "real life evidence" of their experience and career histories.
Maybe he could then explain why new CVD pilot entrants into the industry are now being denied medicals or having them severely restricted to Day VFR only, when their fellow pilots have been operating safely for decades.
In the speech referred to in his article above, Skidmore makes the following comments on the CVD issue:
Mr Skidmore, everyone agrees that the CAD is a brilliant CVD test. However, it doesn't remotely come close to fulfilling the requirements of the third level test under CASR 67.150 (6)(c). CASA still cannot answer the question - "what operational situation does the CAD simulate?" It's a fairly basic and fundamental question...
He also states that they are "considering" using the CAD test as the third level test. This is also a blatant lie, as AvMed are already using it for the third level test. Here's just one example from Bill Smith's post last year:
In the O'Brien AAT hearings, evidence was also heard that the former PMO wrote to Mr O'Brien prior to his medical renewal last year, refusing to re-issue his Class 1 medical at all, unless he undertook the CAD test. This was despite his medical being renewed repeatedly for the previous 15 years without issue.
Mr Skidmore needs to stop blindly following the advice of the AvMed zealots on their crusade to save the world from CVD pilots. He needs to actually take the time to listen to the other side of the story from pilots with the operational expertise to see what they think should be an appropriate test of an operational situation for the purposes of CASR 67.150 (6)(c). Maybe he might be able to hear first hand examples of why colour useage in aviation is not as important as the AvMed zealots would have him believe.
Perhaps then we can then start leading the world at an ICAO level with our "evidence" on CVD issues, rather than following it based on the "assumptions" of other countries like the UK!
For a good read on the scientific flaws with the ICAO colour perception standard, check out this peer reviewed article written by Dr Pape a few years ago which was published in an aviation medicine journal:
Colour Perception Standards in Aviation: Some implications of the AAT decisions regarding colour perception and aviation
On another note, DAS Skidmore has just announced a review of the CASA AvMed department:
CASA Briefing - March 2015
The management of aviation medical certificates is an issue of interest to many pilots and air traffic controllers. I recognise some people have strong views about CASA’s aviation medical system, the decision making processes and medical rulings. This is not surprising as we process more than 25,000 medical applications each year. But the debate about CASA’s medical system needs to be put in context – in 2014 we refused 102 applications out of 25,855 and in the second half of the year there were 13 official complaints. Despite this low level of complaints and medical refusals I believe we can do better and the relatively small number of complaints we receive can be reduced. That is why I have initiated a full review of CASA’s AvMed capabilities. This review is now underway and I expect it will be completed in the second half of 2015. It is looking at our strategic approach to aviation medicine policy standards and clinical practice development, options for the better delivery of medical services in the future and the recruitment and retention of qualified and experienced aviation medicine doctors. Our bottom line is to find ways to improve medical service delivery, ensure our decision making processes are transparent and evidence-based, as well as improving the management of complex medical matters.
In addition to the broad review of aviation medicine CASA will undertake a review of the arrangements that currently allow approved Designated Aviation Medical Examiners to issue and renew class 2 medicals. The results of this review will facilitate an examination of the potential for DAMEs to renew class 1 and class 3 medical certificates in the future. I will ensure CASA consults widely and effectively with the aviation community during the course of these aviation medical reviews. Where criticism is warranted I will make sure the causes of problems are identified and addressed as quickly as possible.
I believe the aviation community and CASA need to build a closer working relationship based on our mutual interest in achieving the best safety outcomes. This relationship must be based on respect and trust. CASA is open and committed to an appropriate ‘safety partnership’ with the aviation community and I am devoting a good deal of time and energy towards working to the achievement of this goal. Of course a closer relationship between the aviation community and the regulator does not mean CASA can agree to every proposal or view put to us. Not everyone will get what they want and consensus may not always be possible. However, I will make sure we are listening to your views and criticisms and we respond in a considered and respectful way to your comments, questions, concerns and complaints.
You can read my speech on the way forward in aviation medicine which was recently delivered to the aviation Medical Society of Victoria.
Safe flying
Mark Skidmore AM
In addition to the broad review of aviation medicine CASA will undertake a review of the arrangements that currently allow approved Designated Aviation Medical Examiners to issue and renew class 2 medicals. The results of this review will facilitate an examination of the potential for DAMEs to renew class 1 and class 3 medical certificates in the future. I will ensure CASA consults widely and effectively with the aviation community during the course of these aviation medical reviews. Where criticism is warranted I will make sure the causes of problems are identified and addressed as quickly as possible.
I believe the aviation community and CASA need to build a closer working relationship based on our mutual interest in achieving the best safety outcomes. This relationship must be based on respect and trust. CASA is open and committed to an appropriate ‘safety partnership’ with the aviation community and I am devoting a good deal of time and energy towards working to the achievement of this goal. Of course a closer relationship between the aviation community and the regulator does not mean CASA can agree to every proposal or view put to us. Not everyone will get what they want and consensus may not always be possible. However, I will make sure we are listening to your views and criticisms and we respond in a considered and respectful way to your comments, questions, concerns and complaints.
You can read my speech on the way forward in aviation medicine which was recently delivered to the aviation Medical Society of Victoria.
Safe flying
Mark Skidmore AM
If he is serious about "consulting" with the aviation industry, a good starting point would also be for him to actually meet with Dr Pape and some of the many CVD professional pilots operating in this country to hear first hand "real life evidence" of their experience and career histories.
Maybe he could then explain why new CVD pilot entrants into the industry are now being denied medicals or having them severely restricted to Day VFR only, when their fellow pilots have been operating safely for decades.
In the speech referred to in his article above, Skidmore makes the following comments on the CVD issue:
My speech won’t be complete if I don’t touch on the delicate subject of CVD. Australia does differ from other countries in relation to the requirements surrounding CVD. Australia is more flexible in allowing applicants to sit multiple sequential tests for CVD where they record a fail and can issue a medical certificate if at any stage any of the three-level tests are passed. Most overseas regulators do not allow this level of flexibility. For example the UK does not allow for any second chances if an applicant fails their only test, the CAD test. They do not receive a Class 1 medical certificate.
In mid-2014, it was determined that the handling of pilots with CVD had not been in strict accordance with Civil Aviation Safety Regulation Part 67 (Medical). CASA advised industry of its new process relating to the regulations in June 2014. This was done to provide industry with information to assist in understanding their obligations in relation to the regulations. The new processes related to new applicants only and there were no impacts on existing pilots. In response to some of the correspondence received, CASA updated the CVD information on its website.
In February 2015, CASA had 134 Class 1 medical certificate holders and 252 Class 2 medical certificate holders who have failed the Ishihara test.
CASA is considering the Colour Assessment and Diagnosis (CAD) test as a third-level test. CASA has determined the CAD test is suitable as an aviation specific test for detecting CVD. It is used by the UK and is also available in the US as an option for testing for CVD. CAD provides for colour and diagnostic testing, which can determine the degree of colour deficiency, which is something that is currently not able to be determined by the Ishihara or Farnsworth tests.
Whilst I am not considering further changes to policy or standards at this time, any proposed changes will be consulted through the SCC Medical sub-committee. Pilots with existing CVD restrictions will require no other tests related to CVD, unless other medical reasons determine a need to do so.
In mid-2014, it was determined that the handling of pilots with CVD had not been in strict accordance with Civil Aviation Safety Regulation Part 67 (Medical). CASA advised industry of its new process relating to the regulations in June 2014. This was done to provide industry with information to assist in understanding their obligations in relation to the regulations. The new processes related to new applicants only and there were no impacts on existing pilots. In response to some of the correspondence received, CASA updated the CVD information on its website.
In February 2015, CASA had 134 Class 1 medical certificate holders and 252 Class 2 medical certificate holders who have failed the Ishihara test.
CASA is considering the Colour Assessment and Diagnosis (CAD) test as a third-level test. CASA has determined the CAD test is suitable as an aviation specific test for detecting CVD. It is used by the UK and is also available in the US as an option for testing for CVD. CAD provides for colour and diagnostic testing, which can determine the degree of colour deficiency, which is something that is currently not able to be determined by the Ishihara or Farnsworth tests.
Whilst I am not considering further changes to policy or standards at this time, any proposed changes will be consulted through the SCC Medical sub-committee. Pilots with existing CVD restrictions will require no other tests related to CVD, unless other medical reasons determine a need to do so.
He also states that they are "considering" using the CAD test as the third level test. This is also a blatant lie, as AvMed are already using it for the third level test. Here's just one example from Bill Smith's post last year:
CASA has determined the Colour Assessment and Diagnosis (CAD) to be an appropriate test for the purposes of regulation 67.150(6)(c).
Mr Skidmore needs to stop blindly following the advice of the AvMed zealots on their crusade to save the world from CVD pilots. He needs to actually take the time to listen to the other side of the story from pilots with the operational expertise to see what they think should be an appropriate test of an operational situation for the purposes of CASR 67.150 (6)(c). Maybe he might be able to hear first hand examples of why colour useage in aviation is not as important as the AvMed zealots would have him believe.
Perhaps then we can then start leading the world at an ICAO level with our "evidence" on CVD issues, rather than following it based on the "assumptions" of other countries like the UK!
Last edited by brissypilot; 27th Mar 2015 at 11:42.
in 2014 we refused 102 applications out of 25,855 and in the second half of the year there were 13 official complaints. Despite this low level of complaints and medical refusals I believe we can do better and the relatively small number of complaints we receive can be reduced.
What is an "official" "complaint", Mr Skidmore?
What about all the people who weren't "refused" certificates, but were f*cked around with delays and operational conditions that had to be appealed and overturned through AAT review, Mr Skidmore?
Have you read the submissions to the Forsyth Review, Mr Skidmore? What did AOPA say was the single biggest complaint of its members? What did some of the professional pilot associations' submissions say about Avmed? Do those submissions constitute just one "complaint" each, or no complaints at all?
What about all the people who signed up to the petition on CVD, and wrote letters to the Deputy Prime Minister and local members of parliament, Mr Skidmore?
I'm quickly coming to the conclusion that you've joined the long line of people who are part of the problem.
Last edited by Creampuff; 29th Mar 2015 at 07:34.
In case Mr Skidmore hasn't read the submissions to and report of the Aviation Safety Regulatory Review, here are some quotes.
From pages 10-11 of the submission by that hot-bed of aviation fringe dwellers and risk-takers, the Australian and International Pilots’ Association (AIPA):
Paragraph 13 of the submission by the aviation equivalent of base-jumpers, the Australian Federation of Air Pilots (AFAP):
From page 7 of the submission by a representative of notoriously inexperienced aviators, the Aerial Agricultural Association of Australia:
AOPA's submission, paragraph 9:
From pages 10-11 of the submission by that hot-bed of aviation fringe dwellers and risk-takers, the Australian and International Pilots’ Association (AIPA):
AIPA’s most frequent and often most frustrating interaction with CASA is through the Aviation Medicine Branch. The frustrations arise due to the inconsistent administration of medical clearances and certificates, the near impossibility of being able to talk to anyone about the administration processes and, most critically, what most members report as the CASA-unique approach of disregarding practicing medical specialists’ advice in favour of “riskbased” decisions made by non-practicing medical bureaucrats.
...
AIPA is most concerned about the immediate uncertainty caused to a member when the often expensive advice and tests are considered to be acceptable by DAMES and specialists but not by the Principal Medical Officer (PMO). Where else are they to turn? The problem is often exacerbated by the turnaround times, the best of which is 28 days, but as the applicant you will rarely be made aware that the clock has not started because some component of the required information is “missing”, at least until you can break through the communication firewall to ask as to what point your certificate has progressed in the administrative sequence.
...
AIPA is most concerned about the immediate uncertainty caused to a member when the often expensive advice and tests are considered to be acceptable by DAMES and specialists but not by the Principal Medical Officer (PMO). Where else are they to turn? The problem is often exacerbated by the turnaround times, the best of which is 28 days, but as the applicant you will rarely be made aware that the clock has not started because some component of the required information is “missing”, at least until you can break through the communication firewall to ask as to what point your certificate has progressed in the administrative sequence.
13. The Aviation Medicine section of CASA in particular appears to act without due regard for the impact its decisions have on individual pilots and the industry. There is little or no communication about delays in the medical certificate renewal process or transparency about the reasons for delays occurring. Certificate holders are obliged to follow up with the section to find out why their certificates have not been renewed only to receive requests for additional medical reports and tests. The Federation has received numerous complaints from members as to the apparently arbitrary nature of decisions and the bureaucratic and incompetent processing of renewals. These delays threaten the livelihood of our members, and undermine the productivity of the businesses for whom they work. We have previously surveyed members and written to the former Minister on this issue1. An overhaul of the Aviation Medicine section of CASA should be a priority. This would include additional resources, clearer processes, specified service standards and improved training of staff.
One area in particular that struggles with continuous improvement is CASA’s aviation medicine branch. Examples are plentiful of questionable rulings on pilot medicals that fly in the face of genuine expert opinion (for example in cardiology) and result in the trashing of careers for no safety purpose. The ability of the branch to hide behind the facade of medical qualifications is well known in industry and under current systems, is an almost unassailable position that has drifted far from actual safety issues, or the leading non-CASA advice on medical issues.
9. Medicals. This is probably the single biggest continuous issue that causes acrimony between GA pilots and CASA. Problems with Avmed include delays in dealing with medical assessments, rejection of DAMEs opinions, demands for ever more complex specialist reports that many would consider unnecessary, and which are then frequently ignored by Avmed itself. Avmed has unique medical opinions which sometimes do not agree with overseas experience, eg; FAA. Communication between CASA, AVMED and pilots has often been poor.
For what purpose? Most GA pilots intend to fly themselves and perhaps a few associates, mostly in VFR during daylight. Motor vehicle licencing is nothing like this, yet driving is only slightly less stressful.
CASA should rely on its own DAMEs for issue of class 2 medicals, and where specialist opinion is required, CASA should at least listen to specialist opinion.
For what purpose? Most GA pilots intend to fly themselves and perhaps a few associates, mostly in VFR during daylight. Motor vehicle licencing is nothing like this, yet driving is only slightly less stressful.
CASA should rely on its own DAMEs for issue of class 2 medicals, and where specialist opinion is required, CASA should at least listen to specialist opinion.
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Creamie, that is all too true!
CASA should not have the right, nor the power to blatantly disregard the expert medical opinions obtained by the applicants treating doctor.
It is absurd to have a glorified GP in Cantberra destroying careers & livelihood due to this loophole.
CASA should not have the right, nor the power to blatantly disregard the expert medical opinions obtained by the applicants treating doctor.
It is absurd to have a glorified GP in Cantberra destroying careers & livelihood due to this loophole.
Of course does color matter as it is an extra (independent) set of information to interpret information. Imagine a cockpit with lights all colours of the rainbow and one time Yellow meant OK another Red meant OK another Blue meant OK...
An aircraft I fly regularly has a red up and locked light for the undercarriage, a blue flashing light (as well as varying audio tones) for the systems malfunction warning system, an orange alternator failure light and a yellow low battery voltage light on the volt/ammeter. None of those colours, or the differences between them, has any intuitive connection to the meaning or relative importance of the issue annunciated.
I think the safety of NVG operations is the 'lay down misere' answer to the reincarnation of this CVD nonsense, even if we set aside the first-hand evidence of the operational history of pilots with CVD.
Thread Starter
brief cvd update
We are appraising the current situation in detail, and here is a précis:
Cheers!
- Current CVDmedical certificate holders, we are asked to believe, will be left alone, at least for now. It would appear that the political fallout that would follow a continuation of the madness that befell AVMED in June of last year would be suicidal for that elite body.
- New CVD candidates for medical certificates are to be dealt with in a manner that can only be described as "pre-historic". Not in living memory have new CVD pilots in Australia been confined to PPL, VFR and daytime only conditions.
- CASA appears hell-bent on pressing on with the use of the CAD test in Australia (as well as the sneaky introduction of the Holmes Wright Lantern) in response to the clear requirements of CASR 67. 150. 6 (c) which demands that "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".
- Currently, we are making in-depth inquiries into the possibility of challenging the lawfulness of the CAD test in the Federal Court. So far, it appears that such a challenge would carry a healthy prospect of success, but that the cost is likely to be over $200,000, which to me is not a piffling sum of money. We are exploring several ways of raising the money. The maths are not overwhelming. One thousand pilots with or without CVD make a contribution of $200, and we are in the game. The trick is to get a thousand donors to cough up $200 each.
- Next, we would need a candidate to figurehead the challenge, and without going into much detail, that candidate would need to be a pilot or wanna-be pilot, who needs to refuse to take the CAD test on the grounds that it is an unlawful test, in the terms in which CASR 67. 150.6(c) is written. In other words, that no reasonable person could view the CAD as a test that simulates any operational situation that any pilot will ever find him/herself in.
Cheers!
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Great to hear. As someone without any CVD issues, I would still be prepared to stump up $200 when the time comes just to help shut down this madness of a rule and organisation.
Dollars 200
Would be happy to contribute to the cause to bring sanity into safety, and help put this issue to bed once and for all.
Not CVD myself but getting it.... CAsA induced by the bastardry of other issues...its called Creating Violent Disposition.
Not CVD myself but getting it.... CAsA induced by the bastardry of other issues...its called Creating Violent Disposition.
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I'm with you gc. Despite the rhetoric contained in the latest DAS statement, his response to Senator Fawcetts CVD question at Senate Estimates shows his true colours (pardon the pun) on the matter. Why CASA and avmed cannot/will not see reason on this matter is beyond me. If the CVD guys are willing to take the fight to them, then I believe it is in all our best interests to contribute to the cause, whether you're CVD or not. As others have said previously, this could be the thin edge of the wedge. What's the next target after CVD..? I shudder to think. 
Count me in for the $200.
If the CVD guys are willing to take the fight to them, then I believe it is in all our best interests to contribute to the cause, whether you're CVD or not. As others have said previously, this could be the thin edge of the wedge. What's the next target after CVD..? I shudder to think. Count me in for the $200.
What's the next target after CVD..?
If you’re ordinary, you’re next. Ordinary now justifies intrusion and requires confession and absolution, at the whim and to the satisfaction of a beneficent, all-knowing regulator.