Deja Vu - Avmed Statistics
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Deja Vu - Avmed Statistics
During CASA’s appearance in front of the Estimates hearing on 13 February 2023, Ms Spence said:
I got an immediate giddy-spin of déjà vu. That’s because on 20 November 2020, Mr Carmody said this to the General Aviation Inquiry:
Simply astonishing that the number is so neatly round and consistent. As a consequence of Mr Carmody’s assertion and that old saying about statistics, I made a supplementary submission to the Committee (available here) which says, among other things:
The lovely round statistics disguise the extent of the costs and damage caused by Avmed overreach in the process of applicants trying to get a certificate.
Back to the 13 February 2023 hearing. A chap by the name of Andreas Marcelja - I think I have the spelling correct, and my apologies to him if I haven’t - said this in response to the Committee’s first question:
No they’re not. Not all pilots are required to have a medical certificate. You’d think CASA would know that. That’s why there’s been an exodus of pilots to flying activities out of Avmed’s reach.
The same Mr Marcelja proceeded to express views about the aeromedical significance of a pilot’s minor kidney stones which remained after medical procedures that were already in excess of what the treating specialist considered necessary. I googled Mr Marcela’s name. I can’t find any reference to his specialist qualifications as a nephrologist or urologist, or even as a medical doctor. Nor did he express any opinion as to the probabilities of the minor kidney stones causing the terrible consequences that are always conjured up to scare people. Those probabilities are the important bit, because any risk can be conjured into a disaster.
And then CASA repeated its the denial of the existence of any perverse incentive for people to withhold information from Avmed. CASA officials might do themselves (and others) a favour by watching the proceedings of the ‘Robodebt’ Royal Commission to see the response to officials ‘in the witness box’ who steadfastly deny the existence of the bleeding obvious.
We process around 25,000 medical applications a year. We refuse a hundred.
In the last 12 months we approved 25,000 aviation medicals and rejected 84.
As a preliminary point, I note that despite my deep understanding of Part 67 of the Civil Aviation Safety Regulations 1998, I am not sure what an “aviation medical” “approval” is. For the purpose of this submission, I assume that the CEO of CASA’s assertion was about the number of times CASA issued a medical certificate or equivalent in the specified period. However, as is often the case when raw statistics are cited without further definition (and in this case “25,000” seems a remarkably round figure) my assumption could be wrong.
I submit, based on my first-hand knowledge and discussions with medical professionals and flying colleagues, that CASA Avmed now demands tests and examinations, and imposes conditions and restrictions on medical certificates, many of which are not justified on objective evidence, risk and medical grounds. The assertion that CASA “approved 25,000 aviation medicals” provides no insight into the conditions and restrictions imposed on those certificates [nor what tests Avmed demanded before the certificate would be issued].
I respectfully urge the Committee to ask CASA these questions:
1. In respect of the “25,000 aviation medicals” to which reference was made on 20 November 2020:
(a) How many of the holders of or applicants for “aviation medicals” were required to undergo tests or examinations that could not ordinarily be done by the DAME or DAO in his or her premises?
(b) How many of those tests and examinations were considered necessary by the DAME/DAO and qualified specialists with knowledge of the holder’s/applicant’s particular circumstances?
(c) What is CASA's estimate of the dollar cost of those tests and examinations?
(d) How many conditions/restrictions, other than conditions/restrictions relating to vision correction, were imposed on the “aviation medicals”?
(e) How many of those conditions/restrictions were considered necessary by the DAME/DAO and qualified specialists with knowledge of the holder’s/applicant’s particular circumstances?
2. On how many occasions has a pilot with a ‘safety pilot’ condition/restriction on his or her medical certificate by CASA Avmed suffered an episode requiring the intervention of the ‘safety pilot’ (noting that circumstances of that kinds must be reported to the ATSB and ATSB would routinely disclose the circumstances to CASA)?
I submit, based on my first-hand knowledge and discussions with medical professionals and flying colleagues, that CASA Avmed now demands tests and examinations, and imposes conditions and restrictions on medical certificates, many of which are not justified on objective evidence, risk and medical grounds. The assertion that CASA “approved 25,000 aviation medicals” provides no insight into the conditions and restrictions imposed on those certificates [nor what tests Avmed demanded before the certificate would be issued].
I respectfully urge the Committee to ask CASA these questions:
1. In respect of the “25,000 aviation medicals” to which reference was made on 20 November 2020:
(a) How many of the holders of or applicants for “aviation medicals” were required to undergo tests or examinations that could not ordinarily be done by the DAME or DAO in his or her premises?
(b) How many of those tests and examinations were considered necessary by the DAME/DAO and qualified specialists with knowledge of the holder’s/applicant’s particular circumstances?
(c) What is CASA's estimate of the dollar cost of those tests and examinations?
(d) How many conditions/restrictions, other than conditions/restrictions relating to vision correction, were imposed on the “aviation medicals”?
(e) How many of those conditions/restrictions were considered necessary by the DAME/DAO and qualified specialists with knowledge of the holder’s/applicant’s particular circumstances?
2. On how many occasions has a pilot with a ‘safety pilot’ condition/restriction on his or her medical certificate by CASA Avmed suffered an episode requiring the intervention of the ‘safety pilot’ (noting that circumstances of that kinds must be reported to the ATSB and ATSB would routinely disclose the circumstances to CASA)?
Back to the 13 February 2023 hearing. A chap by the name of Andreas Marcelja - I think I have the spelling correct, and my apologies to him if I haven’t - said this in response to the Committee’s first question:
All pilots are required to have a medical certificate.
The same Mr Marcelja proceeded to express views about the aeromedical significance of a pilot’s minor kidney stones which remained after medical procedures that were already in excess of what the treating specialist considered necessary. I googled Mr Marcela’s name. I can’t find any reference to his specialist qualifications as a nephrologist or urologist, or even as a medical doctor. Nor did he express any opinion as to the probabilities of the minor kidney stones causing the terrible consequences that are always conjured up to scare people. Those probabilities are the important bit, because any risk can be conjured into a disaster.
And then CASA repeated its the denial of the existence of any perverse incentive for people to withhold information from Avmed. CASA officials might do themselves (and others) a favour by watching the proceedings of the ‘Robodebt’ Royal Commission to see the response to officials ‘in the witness box’ who steadfastly deny the existence of the bleeding obvious.
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I wonder if they will ever release how many of those not rejected are required to have a babysitter, ie fly with or as co-pilot and have safety pilots for single pilots ops. And then how many of those have actually been incapacitated in flight needing said babysitter to take over in the last 10 years. I mean a few must be falling over in flight regularly to justify this condition of issue right? Or are you just placing undue costs and needs on people for no actual reason other than they are not normal.
How many pilots who made application for an initial medical certificate or renewal, abandoned their application for a medical certificate or did not proceed with its renewal after receiving a request from Avmed for further testing or additional information?
I suspect from my experience, people just give up.
I suspect from my experience, people just give up.
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How many pilots who made application for an initial medical certificate or renewal, abandoned their application for a medical certificate or did not proceed with its renewal after receiving a request from Avmed for further testing or additional information?
I suspect from my experience, people just give up.
I suspect from my experience, people just give up.
I can just go drive a 12 seater around UBERing with no medical requirements, claim my car on tax, receive profitable payment, have any medical conditions known to man, be a convicted whatever, can walk up to my car with no high vis vest or security card in heavy traffic and no one gives a stuff as long as you have some free water. Why on earth has GA been picked on so ridiculously.
Was I just dreaming or was there a point maybe only 20 years ago I could just walk out to my plane, not walk through a security minefield, no vests, no strange locks, just jump in and go flying, not too differently to how I would go for a drive in my car.
Does anyone else see how stupidly regulated Aviation has become for no real reason? I wont even say its just over regulated as the regulations for light aircraft especially make no sense, it's just randomly regulated in all the wrong ways.
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Only in some airport owners condition of use of the airfield. I try and make a point of forgetting mine, still haven’t been hit by an aircraft!
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Here’s an extract from the typical terms of use of an aerodrome whose operator is renowned for aggressive enforcement of those terms:
Bolding added.
Some have a condition requiring USD35 million in public liability insurance, noting the airport's interest.
It's about safety.
SECURITY AND SAFETY
10.3.1 You and your employees, agents and contractors must display a current ASIC above the waist in a visible location on the person at all times whilst on official business at our Airport, and it must be produced for inspection by us or any other lawful authority at any time.
10.3.2 You shall not operate Airside:
10.3.2.1 Without the appropriate current ASIC card; and
10.3.2.2 Without reflective safety clothing; and
10.3.2.3 Without approved hearing protection.
10.3.1 You and your employees, agents and contractors must display a current ASIC above the waist in a visible location on the person at all times whilst on official business at our Airport, and it must be produced for inspection by us or any other lawful authority at any time.
10.3.2 You shall not operate Airside:
10.3.2.1 Without the appropriate current ASIC card; and
10.3.2.2 Without reflective safety clothing; and
10.3.2.3 Without approved hearing protection.
Some have a condition requiring USD35 million in public liability insurance, noting the airport's interest.
It's about safety.
Only one I’ve noticed was Longreach - who wanted a photo of my Asic in exchange for the gate code.
‘’I’m waiting for the real PITA which I suspect will one day arrive: no fueling from containers;, although I have a workaround for that.
‘’I’m waiting for the real PITA which I suspect will one day arrive: no fueling from containers;, although I have a workaround for that.
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You're lucky you weren't asked for evidence of your USD35million public liability cover. That's one of the conditions of use of Longreach.
Sad thing is most people that are injured airside walk into the situation. So maybe the aircraft themselves need to wear hi vis vests as the humans are struggling to see them. Yesterday a tram in Melbourne 'hit' a cyclist. So that infers it was the trams fault... it should have swerved or stopped instantly because trams can do that.
In the Alabama case the worker had been just been told to keep away from the aircraft, then almost walked into the jet exhaust where she was warned again and then walked in front of the engine and was ingested. I doubt any amount of high vis would have stopped that, considering she'd already been seen and warned to stay away a few times.
In the Atlanta incident the worker was wearing a high vis vest, clearly visible and holding two glo sticks in the air for marshaling. Watch the video, the truck driver showed no sign he saw her, and really goes to show when there is so much light clutter around high-vis wear just joins in the background.
In the Atlanta incident the worker was wearing a high vis vest, clearly visible and holding two glo sticks in the air for marshaling. Watch the video, the truck driver showed no sign he saw her, and really goes to show when there is so much light clutter around high-vis wear just joins in the background.
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Safety. What’s not to like? On the surface, it’s impossible to argue against, it is after all the Universal Good. Sadly, it also enables way too many of the wrong sorts of people to manufacture careers out of making mountains out of molehills in the “safety space”.
One of the more amusing arguments I was fortunate to witness was between two such safety “luminaries” as to whether day glo orange or the yellow hi vis vest should be the company standard. Two grown men fighting over the merits of a particular colour vest to be supplied. Events like these make me happy to be retired.
One of the more amusing arguments I was fortunate to witness was between two such safety “luminaries” as to whether day glo orange or the yellow hi vis vest should be the company standard. Two grown men fighting over the merits of a particular colour vest to be supplied. Events like these make me happy to be retired.
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then on another occasion one of our old and bold 737 captains was bailed up in the terminal by a very indignant ground Ops person “you were seen on the tarmac without your yellow vest on.” His response was “I rest my case” and walked off.
sometimes there are so many yellow vests flashing yellow lights and other “safety” crap that you can’t pick the wood from the trees, they all blend in together making them effectively useless.
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This thread seems to have drifted somewhat from the original post. If Tailwheel or another mod would care to pare the 'safety' bit off into another thread I'd be most happy to make a contribution to the drift side that may be of interest to some.
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CASA's dodgy Avmed 'statistics' are about 'safety', Pinky, but I know what you mean!