ADHD/ASD and CASA medicals

[43Inches]

It’s lucky that many pilots are able to, and do, maintain their fitness while evading Avmed’s damaging overreactions to the objective risks of “medical problems” that are not reported to DAMEs or CASA. The real safety problem arises when a person does not seek expert advice ‘when in doubt’ about something, for fear that it will get back to Avmed somehow. I have had numerous conversations with individuals in those circumstances, all of whom hold medical certificates. But CASA evidently believes or would prefer to pretend they don’t exist.

This was the point of my comment regarding weeding out individuals rather than dealing with the problems. Having been through the hoops for many years now and having a medical application that has more 'yes' than 'no's on it I can really add that the system is broken and does not achieve what it's meant to. Not one of my conditions has been caught by the medical system before it manifested and I self reported it. And I can say the same for a number of other pilots who have suffered heart/brain/disease related incapacitation. I know pilots that have suffered significant heart attacks weeks after a medical with ECG. By the time CASA/AvMed are aware a pilot has a problem the individual has probably been fixed by modern medicine and their specialist are most likely, "yep good to go in a month or two". But the now 'fixed' human is required to jump through massive flaming hoops to prove they are fixed while 50% of pilots flying around still have the same issue undiagnosed and with walk in/out medicals. Thankfully by luck, and really modern life, pilots really don't just drop dead or incapacitate at any frequent rate, even the unhealthy ones.

This is why I firmly believe your own specialists should be making the call on your ability to fly/drive/walk down the street. CASA and AvMed are simply an unnecessary impediment in the works.

One common thing I hear from specialists is 'why are they even asking that question, it's irrelevant to your condition...'

PS I still think DAMEs should be a thing with regular visits as is, just to ensure pilots are sticking to their plans and health requirements.

[MalcolmReynolds]

It is simple. There are two little rules with AVMED.

Rule No 1. Tell CASA Avmed NOTHING.
Rule No 2. See rule No 1.

Shiny!

[tossbag]

You're missing the point, tossbag.

Your expertise is in assessing whether a person meets the competence standards or not. You can and should be doing that, whether or not the person presents with CASA's thought bubble form. As you say, if you thought he had problems you would have assessed it that way. As soon as you are part of a process through which a medical issue is identified as being the cause of the problems, you are at risk of finding yourself in the middle of a time consuming and stressful controversy. But it is your choice.

Just in case I wasn't clear, the assessment form I filled out for this chap had no medical questions on it, it was assessment of competency standards regarding tasks to be undertaken on a flight. The fellow held a CPL at the time and was since diagnosed with a spectrum condition. I saw it as CASA guarding their arse, I'm tipping they can't just say "Bloggs has just been diagnosed with a disorder but it should be ok." Perhaps I was foolish in taking part in an exercise like this but at the time I was comfortable with what was being asked on that assessment form and that it didn't ask me to do any sort of medical judgement.

I guess I'm in a severe minority here and that the majority of instructors would say to this fellow, "yeah/nah" ?

[Clinton McKenzie]

Originally Posted by tossbag

Just in case I wasn't clear, the assessment form I filled out for this chap had no medical questions on it, it was assessment of competency standards regarding tasks to be undertaken on a flight. The fellow held a CPL at the time and was since diagnosed with a spectrum condition. I saw it as CASA guarding their arse, I'm tipping they can't just say "Bloggs has just been diagnosed with a disorder but it should be ok." Perhaps I was foolish in taking part in an exercise like this but at the time I was comfortable with what was being asked on that assessment form and that it didn't ask me to do any sort of medical judgement.

I guess I'm in a severe minority here and that the majority of instructors would say to this fellow, "yeah/nah" ?

Ah. I see the 'disconnect'.

I might have missed the bit where you said you were not asked to fill out Form 420 - the form discussed at length in this thread - and were instead asked to fill out a different form. If I did miss that, my apologies.

[Clare Prop]

420 may not be medical, but I would call it clinical.
It is sent after the student has already been diagnosed by a medical professional and ticked the "yes" box, but IMO it is still beyond what we are qualified to do, which is to train, assess and examine students with reference to the Part 61 Manual of Standards, nothing else.
Occasionally as a CFI I have been asked to assess whether people over a certain BMI can safely enter, exit, do up seat belt and have full and free control movement, but those are things that are easily measurable and not subject to any bias

[compressor stall]

I happened to be in social conversation with a leading specialist in the ASD space a few years ago. We were in discussion about the prevalence of ASD these days. He remarked that it was interesting that a not insignificant number of parents come in with a child referred to him and, as he was engaging with the parents, he could see clear ASD signs in one of the parents that had never been diagnosed. He then laughed that many of them were pilots. At that point in the conversation, he didn't know I was a pilot or connected to aviation in any way...

[Sunfish]

Clinton, the lady concerned in noticing the ‘problematic” behaviour was a teacher of some forty years experience who was highly respected by her peers and students. She was a great judge of character who only made one error of judgment- hooking up with me. Her wisdom is greatly missed by all who knew her.

‘’The lackadaisical student that was the subject of my comment is a good example of why CASA should not be in the business of diagnosing ADHD. The kid must have grown out of it by the time he was accepted by QF. Furthermore the entire field of “personality diagnostics” is a minefield full of frauds.

‘’As for Spence, she must know what is really going on.

Judging by the AAT appeals transcripts and at least one consultation submission, I would characterize the relationship between Avmed and the pilot community as legalistic and adversarial. For the avoidance of doubt, pilots are regarded as liars potentially concealing a multitude of safety critical medical conditions. Needless to say, this is not a good starting point for useful discussion.

[Clare Prop]

Best of luck to this young man...CASA won't give him a medical because of an "unacceptable risk" so he is flying an ultralight round Australia to show them. ABC features stories for, by and about Australians living with disability | Mirage News
Good luck Hayden!

[Clinton McKenzie]

As stated at post #45, I submitted this FOI request to CASA on 24 November 2022 in the following terms:

All documents containing, in whole or part, information about or recording any one or more or all of:

• the catalyst for the decision to remove the sentence: “Hopefully does not get out of seat in flight!” from CASA Form 420
• the process through which that decision was made
• the individuals involved in that process, including the individual who made the decision
• the matters taken into consideration or discussed, or both, by those individuals in the course of the process and in making the decision
• the implementation of the decision after it was made, including the process through which the Form 420 without the sentence: “Hopefully does not get out of seat in flight!” replaced the version of the Form with that sentence on CASA’s website.

Subject to one exception, I do not request access to the name, work email address or work or mobile phone number or other personal information of any official. The exception is that I seek access to the names of the individuals involved in the decision making process and the decision the subject of this request. I do not request access to any personal information of individuals who are not officials. For the purposes of this request “official” has the same meaning as in the Public Governance, Performance and Accountability Act 2013.

In short, I am trying to find out how the words were airbrushed out of history.

Today I received the response to my request:

I have conducted a thorough search of our records, including CASAs records management system, a vault search of our email records and consulted with the relevant business areas. I have concluded there is no relevant documentation available to provide in relation to the removal of the sentence “Hopefully does not get out of seat in flight!” from CASA Form 420.

Following my conversations with the business areas and the relevant staff involved in the form revision, it appears to me it is likely this change was made as a result of a verbal discussion that was not documented.

The lack of records of the decision-making and administrative processes through which changes are made to forms published by a government authority and relied on in decision-making is a manifestation of an organisation lacking corporate integrity. The words have simply been airbrushed out of history. That's "transparency" and "accountability" in 21st century CASA.

I intend to submit another FOI request to CASA today in the following terms:

All documents containing, in whole or part, information about or recording any one or more or all of:

• the provenance of any version of CASA Form 420
• the drafting of any of the content of any version of CASA Form 420
• the approval of the content of any version of CASA Form 420, and
• the authorisation for publication of any version of CASA Form 420.

I request access to the names of officials appearing in the above documents but I do not request access to their work email address or work or mobile phone number or other personal information other than their name. For the purposes of this request “official” has the same meaning as in the Public Governance, Performance and Accountability Act 2013.

[Clinton McKenzie]

Does anyone have a 'ballpark' recollection of when the Form 420 thought bubble first came out of Avmed? An approximate year would be helpful as it makes FOI processes quicker if I can narrow down the time bracket in which the documents sought were created.

[Clare Prop]

Originally Posted by Clinton McKenzie

Does anyone have a 'ballpark' recollection of when the Form 420 thought bubble first came out of Avmed? An approximate year would be helpful as it makes FOI processes quicker if I can narrow down the time bracket in which the documents sought were created.

I first encountered it in 2018

[Clinton McKenzie]

Thanks Clare.

[mikewil]

Not sure if it has already been pointed out in this thread, but anyone notice how the number of this CASA form (420) is also a very common term that stoners use when procuring cannabis from their dealer? For those who don't - type 420 into google and see what comes up, it isn't the piece of toilet paper dreamed up by the geniuses at CASA AvMed.

Maybe someone was taking the piss when numbering this form, or maybe someone was too busy thinking about something else (or already high on it).

[Clinton McKenzie]

That would be consistent with the mindset of whoever came up with the words that have now been airbrushed out of history.

It will be interesting to see if CASA has any records of the provenance of the Form and its contents, and its authorisation for publication and use.

[Chris the Robot]

As a PPL holder in the UK diagnosed with ASD in early childhood, CASA's approach does seem somewhat dystopian.

My first aviation medical experience was to get a glider pilot medical signed off by my GP. There were no problems (having a stable office career at the time helped) and I had a chat with the CFI of the gliding club about it and he was fine with it too. PPL flying was beyond my budget at the time.

After finding the training cost associated with a career as a pilot to be prohibitive, I decided to pursue a career as a train driver. I passed the psychometric tests and after trying interviews at a few companies (I'm not great at competency-based interviews) was offered a job. At the medical, I put ASD on the form and had a chat with the doctor about it at the end of the medical. We had a chat about aviation (he had a lapsed PPL), he compared the traits required of a safe train driver with traits commonly found in ASD. His conclusion was that I was quite rare because I had a medical condition which would make me better at my job.

About a year after qualifying as a train driver, I went to get a CAA Class 2. I mentioned ASD on the form and the AME's view was that it shouldn't be much of a problem, after all I'm a train driver. He had a chat with the CAA and a letter from my GP confirming no recent adverse history was enough. The flying club I did my PPL at was fine with it, the Skills Test examiner asked after issuing a pass if I'd thought about becoming an instructor.

Shortly afterwards, with just over three years as a train driver (my PPL took a while due to the pandemic), I became a train driver instructor. I've been doing that for just over a year now but I'm due to move from a suburban operator to an intercity one in the new year which means I'll go back to being a regular driver.

It's a bit academic since I'm in the UK but I wonder what CASA would expect a PPL instructor to write about me on Form 420?

[personwithadhd]

Very interested in any FOI releases you receive on this, as I find the wording on that form (even the revised one) insulting, and I'd love to know how they came up with the content in form 420. The sudden disappearance and then silent modification of that form seems like "take it down and and hope nobody noticed it" levels of sus. Plus the quip wasn't even funny.

Alas I was given notice of intention to refuse my Class 2 medical today, due to a recent diagnosis of ADHD so am considering my options, because I love flying:
- Basic Class 2. Not sure if it's possible after having a class 2 certification refused. Have asked DAME.
- Apply again after condition resolves and then get instructor to try and do form 420 with me (is it back or not? I see conflicting information on their site)
- Get a second opinion, disagreeing with the ADHD diagnoses as ASD instead, reapply; possibly hit the same refusal but this time on a condition that doesn't resolve?
- Give up on dreams of piloting an aircraft (even for fun)
- Dual forever (at least I'll never get lonely)

If anyone can think of any other options I might not have considered, I'd love to hear them.

For background, I am 8 hours into training for RPL, flying is all I really think about now, read taits RPL books cover to cover multiple times since starting, pass all of the quizzes at my flight school, and have been flying circuits for a few hours now. I've so far had no problems raised by instructors around managing workload, following checklists, remembering procedures, mnemonics, callsigns, anything. No difficulty with the theory at all. By all accounts on track without incident[1]. In fact the only advice they really pushed me on was to go get my medical and ASIC because all the competencies have been just fine and I'm only a handful of lessons away from my first solo circuit. I've never done anything that I enjoy this much before.

So while I understand the reasoning for CASA's policy, especially for commercial pilots who are flying tonnes of metal and fuel and hundreds of people around, I'm now haunted by a conversation I had with my GP while we were filling out the AVMED history together; we'd joked about just filling it out like I'd never even had a cold before, but he thought that it would be very surprising if any medical practitioner would deny a recreational pilot's a license to someone who is otherwise healthy but has ADHD. Especially someone with a good academic and professional history, not a single traffic violation, no criminal record or any other record of adverse history, and when the condition is being managed. And especially given that there's also a theory and competency based assessment to the licensing, and a background check.

On reflection now, I wish I'd known Rules 1 and 2 about AVMED!

[1] We did have one incident I guess - I was unable to sight traffic behind us. Traffic behind us was also doing circuits albeit in a plane much faster than the C152 we were in, and had requested and been cleared to cut short on xwind and overtake us. We got to the end of our crosswind leg and still couldn't see them. Asked tower where they were, and they'd decided not to overtake after all. But I don't think that was related to my ADHD.

[KRviator]

Fairly sure you can continue under RAAus if you just want to fly for fun. The other thing to consider is ADHD isn't specifically called out in the AustRoads standards so you may be able to hold a C2 Basic as the neurological questions are if they have a significant impact, yadda yadda - but bear in mind CAsA has, in their infinitive wisdom, added additional questions above and beyond the AustRoads standards

Finally, you may be able to obtain a Rec Aviation Medical Certificate, but again, you can't do endo's and the rest, it's strictly Day-VFR, <1500Kgs etc, but that's enough to fly for fun.

[Capt Fathom]

Originally Posted by personwithadhd

I was given notice of intention to refuse my Class 2 medical today, due to a recent diagnosis of ADHD so am considering my options

Usually AVMED will state why your medical has been refused, and more importantly, what you have to do to progress it.

[Clinton McKenzie]

I have now received documents in response to my second FOI request about CASA Form 420. I will try to provide a link to the documents. I am doing a forensic review of the content, but note the following preliminary matters that have already become obvious.

The footer of the currently published version of Form 420 says this:

ADHD Instructors Questionnaire │V 1│CASA-04-1896│03/2022

The “V 1” represents that it is the first and only version of the Form. That is a misrepresentation. As we know, at least the sick joke was airbrushed out of it, with no trace as to who decided to do that and who did it. I can see other versions in the disclosed documents, which versions were evidently used because ‘outsiders’ have commented on or complained about them. There is nothing in the Form to indicate the differences between different versions. (It evidently remains beyond CASA’s current corporate competence to understand the difference between “impatient” and “inpatient”.)

More fundamentally, given the circumstances in which CASA Avmed has required the Form to be completed and the implications if the requirement is not complied with, ASD has now been deleted from the heading. As we will see, someone in CASA Avmed finally decided that the questions in the Form were aimed at behaviours typical of ADHD rather than ASD and – guess what - ASD and ADHD are apparently two quite distinct conditions.

CASA’s quality control is so poor that when the deletion of ASD from the heading of the Form was going through the approval process, nobody bothered to review the rest of the Form. The Form continues to say, under the heading “Purpose of this form”:

This behavioural questionnaire is for Flight Instructors of individuals with ASD and/or ADHD.

But rewind to 2018, when an applicant for a medical certificate made a complaint to the CASA ICC about the requirement, imposed by CASA Avmed, for the applicant to provide a completed Form 420 (plus Medicare consultation and prescription records for the past five years; academic and employment history; copies of any special reports (such as QEEG or neuropsychological testing); previous specialists reports). The applicant had low level ASD and complained that the Form related to ADHD, with which the applicant had never been diagnosed.

The ICC’s letter to the applicant, dated 17 July 2018, contains a chronology, 27 dot points long, spanning the period 4 October 2017 (when the applicant’s application was submitted to the MRS) through to 27 June 2018, at which point the applicant had still not been issued a medical certificate, because CASA was “currently waiting for you to return the Authority to Release Medical’in-confidence Information’ form before it can complete your certificate application”.

The events in between were the usual mixture of Avmed overreach and pedantry. The penultimate paragraph in the ICC’s chronology says in part:

Avmed also advised the instructor’s name wasn’t on the Form 420 you’d submitted and you clarified it was. AvMed agreed it was, stating ’the instructor name is…where it would have expected to see (your) name.’

It’s hard to imagine the extent of the stress caused to Avmed by the instructor’s name having been put on the Form where Avmed expected to see the applicant’s name, much less the extent of the consequential risks to the safety of air navigation.

The ICC’s findings included;

I agree Form 420 is confusing. It’s clearly states it relates to ADHD and is an extract from that condition’s assessment protocol. …

Form 420 contains no instructions for the level of detail it seeks from the flying instructor who is completing it. It asks a closed question (‘normal?’) and then seeks comments. …

As we know, that entirely inappropriate question has also been disappeared from the Form.

The ICC also found that CASA Avmed created an expectation in the applicant’s mind and then acted contrary to the expectation created:

In my view, AvMed created an expectation the information you’d provided would reviewed at the point it was received, rather than cumulatively. In reaching that conclusion, I note when you asked if you were to ’start sending through information … to help the transition go faster.’ AvMed replied on 10 January [2018] that ’it would be very helpful if you could send through anything you have available.’

Contrary to your expectation, it’s apparent the information wasn’t reviewed by a Doctor until all the information it’d sought had been received. …

Fast forward to 12 October 2021 – more than 3 years after the ICC’s findings. Some bloke named Tony Hochberg sent a string of emails to Nathan Sullivan, Kelsey Kadam and Angela Pearman, all of whom appear to be CASA folk. Mr Hochberg’s string of emails say, among other things:

I have a problem with the combined intent of the ASD/ADHD questionnaire as the behavioural aspects of ADHD and Autism are like opposite ends of the spectrum. …

ADHD questions predominate, however autistic individuals are often socially withdrawn and apprehensive when being looked at and like to be left alone in a corner away from everyone, not near doors or passageways etc. in class.

…

Decision made – please call this questionnaire ADHD instructors questionnaire form and problem solved.

…

The problem is the title includes autism spectrum disorder and if we remove that then the questionnaire is specific to ADHD. Not sure why it was combined into one questionnaire as they are two quite distinct conditions.

…

I note the usual insouciant indifference to the stress, delay, cost and confusion caused by CASA Avmed’s pedantry and flawed forms, none of which contributed anything positive to safety of air navigation. Who cares if people with low level ASD were put through the ADHD process.

At this point I will reiterate advice I have given before: Beware of putting yourself in circumstances in which you can be diagnosed with something. Be extraordinarily careful in answering what appear to be innocuous questions. Ditto anyone of your loved ones who may aspire to any aviation-related activities in circumstances in which CASA’s anachronistic medical certificate requirement applies.

Once diagnosed with something and CASA Avmed becomes aware of it, you are their guinea pig. CASA Avmed will spin almost anything into an ‘aero-medically relevant condition’, will exaggerate the risks arising from the ‘condition’ and will then impose the most intrusive, expensive and potentially dangerous-to-you requirements in order to ‘satisfy’ them, assuming they don’t just refuse to issue a certificate to you. It does not matter if the weight of qualified expert opinion is contrary to Avmed’s. They have a noble cause and they believe that, but for their crusade in the interests of that cause, it would be raining aluminium. They only back down if there’s a risk they’ll be embarrassed, and that will cost you a lot of time and money to make happen.

[personwithadhd]

Did you get given a reason for them not providing the previous version of form 420 that you requested?

In case they lost their backups, I have one. Form version 420-08/2018, titled ASD & ADHD INFORMATION REQUIRED (EXTRACT FROM ASSESSMENT PROTOCOL) including offensive quip, sans airbrushing. I'm not yet allowed to include URLs in my posts, and attachment upload isn't working, but you can get it here:

http s://1drv.ms/b/s!AsZLxChtR3Zwj-EA9aCLPXqEBY0M5A?e=YhEXFu

(copy into address bar, remove the space after the "http")

I took the liberty of extracting the metadata from it, maybe you'll get a name to request more info about. The relevant stuff from that PDF:

Author: Senior Medical Officer - Michael Drane
Company: Civil Aviation Safety Authority
Create Date: 2018:08:23 10:50:30+10:00
Modify Date: 2018:08:23 10:59:17+10:00
Source Modified: D:20180823004425
Language: EN-AU
XMP Toolkit: Adobe XMP Core 5.6-c015 84.159810, 2016/09/10-02:41:30
Metadata Date: 2018:08:23 10:59:17+10:00
Creator Tool: Acrobat PDFMaker 18 for Word
Document Id: uuid:31520ef9-e90b-4d0a-8f73-f5f1dcd592c4
Instance Id: uuid:31520ef9-e90b-4d0a-8f73-f5f1dcd592c4
Subject: 16
Title: Form 420
Creator: Senior Medical Officer - Michael Drane
State: 1
Version: 1.1
CreationDate: Thu Aug 23 02:50:30 2018 CEST
ModDate: Thu Aug 23 02:59:17 2018 CEST

Continuing my training tomorrow morning, looking forward to it, weather looks good for flapless circuits.