CASA Medical Standards Discussion Paper
 

See here: https://www.casa.gov.au/standard-pag...tion-standards

Is this the latest version of the Xmas eve fax - want to avoid discussion, put out a discussion paper when no one will see it?

Medical Proposals
 

The one thing that is missing from the list of subjects is that of service by the AvMed department or lack thereof.


My experience is one of less than satisfactory response by CASA AvMed. I have been right up to and past the two months extension expiry date and no word from AvMed.
I have then had to follow up with AvMed but no 'sorry' or apology.
As a commercial pilot I need to know where I stand so that I can make plans around that lack of service, for which I am asked to pay a fee.


I am of the view that AvMed section needs to sharpen up its customer relations and work with the punters rather than against them which is the ways it is as present.

Quite simple really, empower the DAME to issue the full 12 Month certificate on the spot. A whole load of conditions should be 'normalised' especially in Multicrew ops. I have thought for a while now that the whole aviation medical lark is a bit of a waste of time, there should just be a basic checkup each year and barring any horrendous developments you should be good to go, if you develop a serious condition then and only then should you be referred to AVMED for management, otherwise for he majority of conditions surely the DAME can manage the plan. I have know 4 pilots now over the last 10 years who have died due to unexpected cardiac events, all were relatively young 45 - 55 and on the face of it fit and healthy and in possession of Class 1 medical Certificates including recent ECG's. Can you see, hear, talk and pee on a stick please should be the extent of the checkup, along with blood pressure and weight readings for tracking.

Ollie,

On the face of it, what you say sounds sensible. But it's not as simple as that. A friend of mine recently went through the Class 1 process, he'd hit a milestone age that required the whole shebang. His markers whilst being high were 'within tolerance' but led him to a stress ECG. And there it was, a congenital issue that required open heart surgery. Interestingly the normal ECG was fine and the stress ECG met the required standard for a Class 1 to be issued (and it was!) It was abnormal electrical activity that triggered concern and further tests.

Long story short, with your solution this fella would have gone undiagnosed. A sudden cardiac event would have happened, it was not a matter of if but when. This fella was not overweight nor did he have any glaring symptoms. There are some pilots that are quite happy to do the Class 1 medical process as it stands, it's the one time of the year they'll see the inside of a doctors office!

Yep, drpixie, this IS the current version of the Christmas Eve fax. All 45 pages of it.
AOPA have pushed for a similar medical standard to that which will be used in the USA for PRIVATE PILOTS. The UK has brought in something similar.
Porter, nobody is even questioning the Class 1 yet CASA puts this and many other considerations on the table and has pulled the wool over the Minister's eyes.
The medical isn't for YOUR benefit, it is a risk mitigation exercise to protect people on the ground and others in the air. There is a complete lack of evidence that it does any good. Both in the US and Australia glider pilots operate on a self certification basis and RAAus pilots in Australia on a State car driver's licence (around 40% of pilots in Australia) so the experiment has been run for decades. You are at greater risk of killing an innocent pedestrian or a car full of of passengers coming the other way in the event of sudden incapacitation than you are of hurting anyone else in a small aircraft for the same reason.
Regulation should be evidence based and if there is no evidence, it should be abolished.
The CASA paper looks to me like a calculated insult to AOPA Australia.
CASA will manage to keep this whole thing going for decades to avoid taking action.

what a load of bull**** this all is.
the greatest risk is the microsleep in hot weather ending up hitting a tree.

the casa medical started out after the second world war when they realised that the civilian pilots could be called up to save the bacon of the RAAF.
Donald Anderson decided that all civilian pilots would pass an RAAF medical so that they could be immediately drafted into the RAAF in the event of war breaking out again.

from that simple start the whole medical empire has grown to employ "thousands" and run the world.
does it actually achieve much. doubt it.

the pilots who fail the medical all drive home through the traffic without incident.

the real question is "can you still be functional at the end of a 3 hour flight and land safely?"
I doubt that a CASA medical would ever be able to determine that.

a sip of water and a few barleyscotch lollies probably work more wonders than all the CASA medicals ever will.

of course if you actually have some health issues why arent you seeing your GP?

Eyrie,

I was just responding to Ollie's comment, the rest of the review obviously has merit :ok:

dubbleyew eight, correct. Remember also glider pilots fly for up to 8 hours or more in turbulence most of the time, hand flying the aircraft continuously. These folk self certify both here and the USA. The experiment has been run. There is nothing to discuss.
Oh yes, Sir Don Anderson. I once heard an interesting story about his visit to the Waikerie World Gliding contest in 1974 in the new Departmental Merlin.
As for the RAAF, we certainly aren't going be to defending Australian cities with Spitfires flown by hastily drafted private pilots any time soon.
Here's what a friend of mine found after some research:
"As at least 40% of Australia's aircraft fleet is piloted by people who simply submit a declaration that they are fit to fly (RA-Aus and GFA predominantly) and as the statistics do not support an increase of regulation in this area the underlying thrust of the discussion paper should be disregarded. For example, in its report entitled "Pilot incapacitation occurrences 2010�2014" the ATSB found::
Why the ATSB did this research
Occasionally pilots become incapacitated during flight. Incapacitations can arise from different reasons. They include the development of an acute medical condition, changes in environmental conditions during the flight, or the effects of a pre-existing medical condition. The effect of incapacitation on a pilot can be restricting their flight duties for the remainder of the flight, or for single-pilot operations, a collision with terrain.

This research report documents pilot incapacitation occurrences in high capacity air transport, low capacity air transport, and general aviation to help educate industry about the causes and risks associated with inflight pilot incapacitation.

What the ATSB found
In the past 5 years, there have been 23 pilot incapacitation occurrences reported per year on average. Nearly 75 per cent of the incapacitation occurrences happened in high capacity air transport operations (about 1 in every 34,000 flights), with the main cause being gastrointestinal illness, followed by laser strikes. In the majority of the occurrences reported, the incapacitation was severe enough for the pilot to be removed from duty for the remainder of the flight. With multi-pilot crews in high capacity operations, these occurrences usually had minimal effect on the flight.

Low capacity air transport and general aviation had fewer occurrences with a wider variation of causes of incapacitation. These ranged from environmental causes, such as hypoxia, to medical conditions, such as heart attack. Furthermore, 70 per cent of pilot incapacitation occurrences in general aviation had an effect on flight operations, namely return to departure aerodrome or collision with terrain.​

In other words 6 pilot incapacitations per annum for low capacity air transport and general aviation would be beyond the predictive capabilities of medicine.
In fact, the ATSB report "Accident Occurrence Statistics 2005-2014" do not record pilot incapacitation as an accident or incident cause so the claim that "70 per cent of pilot incapacitation occurrences in general aviation had an effect on flight operations, namely return to departure aerodrome or collision with terrain." may be without foundation."

Note the Gastro-intestinal and laser strikes, neither of which are going to be predicted by an aviation medical. Neither are hypoxia and hyperventilation, the latter of which I suspect as a cause of otherwise unexplained accidents.

It probably comes back to the requirement to issue a licence to carry fare paying passengers. When CASA does that it takes on some of the responsibility on behalf of the Australian Government, it is not all borne by the individual pilot. So how does CASA determine for itself that you are a fit and proper person to hold the licence?

CASA does this via a network of delegated DAME's. The trouble is that CASA neither trusts them, nor the specialists to whom they seek additional opinion, nor the drug companies who make recommendations about side effects, etc, nor indeed the FAA who publish a much more comprehensive DAME manual than CASA.

Instead CASA centralises all decision making and review, but employs people with inadequate qualifications or experience, thus they have guidelines & protocols provided. But these are inadequate, contradictory and incomplete. And none of the administrative staff will take responsibility for going outside the guidelines (more than their jobsworth). So anything that is not black & white, enters a spiral of review until the pressure for a decision finally becomes overwhelming.

All CASA needs to do is:
a) harmonise its medical standards with other Australian bodies / overseas agencies. Australian aviation does not need unique standards for blood pressure, blood sugar, etc.
b) make the DAME guidelines clear & easy (or copy the FAA one)
c) allow DAME's to have proper authority. They are well qualified, serious people, seriously, why can't they be the arbiter of who is fit to fly? They or their colleagues do it for driving, boating, scuba diving and a range of occupations. As much as we would like to think otherwise, pilots aren't a special breed.

I think you missed the point that Mr Approach was trying to make Akro. The DAME DOES NOT decide if you are a "fit and proper person" to hold a licence. They simply assess your HEALTH indicators against a set of standards.

Fit and proper is a whole other ball of wax.

Icarus

Got it now. But, without having read the relevant legislation, I would expect that a pretty much identical phrase appears regarding driving licences, boat licences and a whole range of other things from gun licences to explosives licences.

CASA stands alone in creating such convoluted, contradictory, ill defined medical requirements. It also stands alone in the bureaucratic structure it has created to administer this.

Other bodies find easy, cheap, efficient ways of dealing with these requirements. CASA pretty much stands alone in wanting to not delegate any authority and administer it all centrally in Canberra.

Don't believe me? Go and get a heavy truck licence (administered Nationally, but delegated to the state bodies). It involves medical requirements, skill & knowledge requirements and fit & proper person requirements. And a truck driver can do a whole lot more damage in a 40 tonne truck than I can in a 1.9 tonne light twin.

W8
Agreed, if you have a problem see your doc however you don't always know you have an issue

If it wasn't for my casa medical a few years back I doubt I'd be here to write this

I look forward to my medicals, blood tests stress ect ect and this year Casa excelled themselves by completing the paperwork inside 10 working days

holdingagain, posting again: The medical isn't for YOUR benefit, it is a risk mitigation exercise to protect people on the ground and others in the air.
There is NOTHING to prevent you from having a medical every year to whatever extent you wish to pay for including blood tests, stress tests, colonoscopy and what ever else you wish to do.
This has exactly ZERO to do with the requirement for a formal aviation medical. This whole discussion paper is a result of medical reform for PRIVATE pilots in the UK and USA and AOPA Australia's push for the same here. The wide terms of reference of the CASA discussion paper are completely unnecessary. AOPA wasn't talking about Class 1 medicals for Commercial or ATPL nor for extending the RAMPC to recreational aviators in RAAus and GFA, just bringing the Class 2 medical requirement to that required to drive a private car in an Australian State. This experiment has already been run by GFA and RAAus and by private glider and balloon pilots in the USA and there are no adverse results.

Eyrie, this all seems to be bugging you, relax

The problem is that CASA will pervert the idea of a relaxed medical standard for private pilots. They will do this by restricting existing privileges available to the new class (for example IFR, controlled airspace,etc.) or by hedging the new class with restrictions so as to make it meaningless (for example limitations in respect of cancer, diabetes and other common conditions).

What we have now is a meaningless system and I don't believe CASA is going to do anything but window dressing. The phrase "all assistance except actual help" comes to mind.

I could go on.

Sunfish, you got it in one. There won't even be any window dressing. This will drag on until everyone forgets it or there is a change of government which kills it. All according to plan.
I hope AOPA is on to this perversion of their proposal. BTW glider pilots currently can fly in controlled airspace in Australia on their self declaration medical so the experiment has been run.
All the evidence I've seen says medical incapacitation WHICH MAY HAVE BEEN DETECTABLE IN A CLASS 2 MEDICAL is a very, very small cause of aviation accidents.
holdingagain, BOHICA may be your style but it isn't mine.

BTW why is IFR not in the new medical discussion paper for drivers licence?

I just flew 5hrs from Hobart > Adelaide IFR, and it was 10x lower workload, safer, stress-free, less fuel (optimum altitude) and relaxing than doing it VFR. A good 0.5 IMC.

Unfortunately when they release the drivers license medical I'll do that and be banned from operating IFR. Safety will have decreased.

IFR is a training/currency thing, not a physical one.

Shagpile, it is, in the AOPA proposal.
Download the CASA discussion paper proposal from the CASA website and go your hardest in your reply.

All great points of discussion here, though how much of this will translate to responses to CASA?

Following in from my comments in the PT61 thread, there were less than 100 responses to the letter the DAS put out.

Hopefully everyone on here that's complaining bothers to actually write a response to Avmed to let them know their opinion

.....and risk victimization in future? the key finding of the forsyth review is that CASA cannot be trusted.

Sure why not. I made a few suggestions last year which were adopted for the helicopter side of things.

"Following in from my comments in the PT61 thread, there were less than 100 responses to the letter the DAS put out".

You mean to tell me there are still 100 pilots left in Australia!!!!!
CAsA is obviously not doing its job stamping out these criminals, everyone should write to the minister and complain.

Sunfish, you are being asked to make a submission to a public call for comment.

You aren't being asked to "pledge your life, fortune and sacred honour" and start shooting at Redcoats with an excellent chance of being hanged by the British should your independence movement lose or leaving your home country to fight for freedom in the North America of the late 1770s like Tad Kosciusko. Yes, that bloke, who named Australia's highest mountain. Before that, he was George Washington's Engineer for the Continental Army.

You've been vocal here about how excessive regulation screws over Australian aviators. Now you have a chance to stand up and put your point of view officially.

Does AOPA or any other organistaion have a 'standard letter', with all the salient points about USA reforms, survey findings, and even some of the very good points discussed here, in regard to the effectiveness of Class 2 medicals on reducing actual Private flying incapacitation related deaths.

Many may not want to try and pen their own letter, but prefer a well written, factual letter showing positive arguments, and factual surveys about self assessments for PPLs.

Then everyone should print it out and send a copy to the Casa survey and the Minister of Transport (or whoever should receive it).

I'm sure they would receive more than 100 replies then. In fact every PPL and every CPL/ATPL should send a copy in, as you never know when you may be grounded for even PPL flying, should some issue arise when you get older. (and avoid a series of expensive 'Specialists' tests at every PPL renewal). I have heard of it happening.

In fact, check the 'For Sale' adverts and there are always a few aircraft for sale because of 'Loss of medical', obviously the cost of trying to prove to Casa you can fly a RV6 privately is too costly to continue on each renewal.

Id like to send one in.

I am all for a vibrant, inexpensive (as possible) Private Pilot GA Flying scene in Aus.

I've just re-read the Forsyth review on this topic. Its pretty forthright & specfic.

The question that needs to be askled is why CASA have not taken this as a starting point, or at least an option. Let alone just getting on and doing what the report recommends.

Do you have a link to that please, Old Akro?

A discussion paper is just one of the usual CASA look-busy tactics to avoid doing anything.

If CASA were genuinely interested in listening to and addressing substantive issues about medical certification, it would have listened to and addressed the substance of the submissions to the Aviation Safety Regulatory Review from the associations which represent many people across the aviation spectrum on the receiving end of AVMED's capricious bull****.

The Australian and International Pilots’ Association:The Australian Federation of Air Pilots:The Aerial Agricultural Association of Australia:The Aircraft Owners and Pilots Association:But what would AIPA, AFAP, AAAA and AOPA members know about the interrelationship between fitness to fly and aviation safety? What would they know about the relatively recent hijacking of the medical certification process by people who evidently consider their opinions on that relationship and the attendant risks to be objective truths?

CASA's argument, as put to me by the head of avmed, was that DAMEs would be exposed to much more liability and thus have to charge more to cover their insurance, if they were to issue their own medicals without the intervention of AVMED.

On the other hand, for simple medicals (ie everything passes) I think that I can tick the boxes just as well as somebody in avmed.

and on the gripping hand, I'm told that Australian DAME training (all of two weeks) is much easier to get through than DAME training in other countries (eg NZ).

Eyrie:

Eyrie, your ingenuous suggestion - that I stand up, is at best pointless and at worst malicious.

I would recommend that no one but an association should comment and the comment itself should be a terse referral to previous submissions to the ASRR.

You see Eyrie, I hold a medical certificate. If I eventually develop a medical condition, the reissue of that certificate is at the whim of CASA AVMED. As evidenced by the ASRR, numerous appeals to the AAT, the entire colour blindness saga, CASA AVMED is quite capable of being totally capricious in its decisions and has the ability to bankrupt an aspiring pilot trying to get a clearance to fly through specialist report costs.

"Oh! But they wouldn't do that would they?" you say? They might, since CASA has proven itself to be vindictive and most importantly untrustworthy.

So my first point. I would be exposing my medical certificate to risk by making an identifiable comment and suggesting otherwise borders on malicious.

But wait, there is more....... the discussion paper is a pointless exercise. It is an attempt by CASA to frame the debate about medical certificates on ground where CASA knows it can win. By "winning", I mean maintaining CASA's iron grip on Australian aviation and maximising its institutional power.

To put that another way, there is not a snowballs chance in hell that CASA wishes to voluntarily reduce surveillance and control of medical certificates, they have too many staff whose careers depend on maintaining control and institutions NEVER voluntarily surrender power ever..

So given that CASA is untrustworthy, has invested itself in medical control of pilots which it wishes to maintain despite being advised numerous times about the deleterious effects of its medical regime, the latest being the ASRR, and is now faced by concrete evidence of change by overseas regulators, what does it do? It lets off a discussion paper! Well done Sir Humphrey!

Eyrie, CASA AVMED is run by lawyers, even AVMED's doctors say that to DAMES. The discussion paper is written by lawyers with a view to frustrating meaningful change, for example it is written using language that can be readily compared with the Aviation Act, a typical weasel trick because they already have reams of interpretations of the Act with which to frustrate change.


All you will get in the end is: " I know the FAA has agreed to XYZ, but the Aviation Act does not permit that because of ABC, risk to the public blah, blah".. The desired end result is that CASA can say they responded to change, consulted widely and came up with a revised class 3 medical certificate that looks like its overseas equivalents, but still ties us into the medical straitjacket we now have to wear. Pointless exercise until the Act is changed.

The head head of AVMED really believes this, then I have a nice bridge I could sell him.

Seriously, if he has such little understanding of PI insurance, then he demonstrates that he in unqualified for the job. Does he seriously think that private pilot medicals are the highest professional risk activity that doctors perform? I doubt it would even make a list of the top 20.

I also think you are out of date with the Australian DAME training. And lets not forget that these are pretty highly trained doctors to start with, who in their practices deal with a range of other medical certifications, from drivers licences, boat licences, SCUBA medicals, to the employment medicals for fire fighters and ambulance officers.

In heyday of GA, there was no DAME training. In the 70's & 80's the DAME list was pretty much an old boys club.

The forsyth review is here:
https://infrastructure.gov.au/aviation/asrr/index.aspx

Old Akro,,your comment is consistent with what I have been told. CASA AVMED is ruled by lawyers not doctors. This was quoted to me by a DAME who had been talking to AVMED doctors at a conference, the AVMED doctors hated the situation but were powerless against the lawyers and their "liability" arguments. The Act needs to be changed before the lawyers can be dethroned.

P.S. I also know one opthalmologist who did the AVMED training but then declined to sign the agreement on the grounds that she was required to report any condition she found to CASA AVMED without the consent of the pilot. Her particular objection was the requirement to report the discovery of eye conditions that would take twenty + years before they became problematic for flying.

My own opinion is that AVMED may well be a danger to the health and safety of both aviators and the travelling public because their attitude to discovered medical conditions encourages pilots to avoid disclosing anything and defer seeking treatment in an effort to keep their certificate. IMHO AVMED needs to change its culture from the negative to the positive as in keeping pilots healthy and flying for as long as possible.

CASA needs to be brought back in to the Department of Transport. A lot of the liability stuff then goes away. It was always a bad idea to make it a government owned corporation and then a Statutary Authority.
I see some think the situation is hopeless. They may be correct but if nothing is done and they don't get any comments CASA will assume everyone is happy with the status quo.

Sunfish,
It seems that you accept the view that we live in a totalitarian state. Whilst I understand that you are unwilling to put you livelihood at risk by making a submission - in other words participating in the democracy that we live in - you can hide behind a association if you like but in my view you forgo the right to complain. This is just like people who don't vote complaining about the government we end up with.
Politicians only react when they feel the weight of public opinion witness Turnbull's overnight response to the twittersphere about the NT detention centre and others. So at least get your association into gear to prepare a form letter at least for their members because they cannot punish several thousand individuals.

GGC, CASA and aviation regulation has nothing whatsoever to do with democracy.

Sunfish,
Democracy only works if you participate. You and many others have allowed CASA to run rampant over aviation by succumbing to the fear of retribution. Consequently when they seek to change rules or other hold inquiries into aviation, the meek cower in the corner out of fear desperately hoping that someone else will do the heavy lifting. Contrast that with the US where submissions to the review of 3rd class medical attracted several hundred thousand submissions. The Forsyth enquiry barely scraped over 100 submissions and NPRM's are usually in the 10's. If you and many others don't participate the aviation community gets what it deserves.
Democracy doesn't start and finish with voting - it actually requires a continuing participation. That is how we got an experimental category.

"It seems that you accept the view that we live in a totalitarian state".

I think that is CAsA's view.

"You and many others have allowed CASA to run rampant over aviation by succumbing to the fear of retribution".

A very real fear that has been demonstrated time and time again to be very real. Many feel powerless because CAsA can and does operate outside the LAW, their bureaucrats have ensured they can, or have manipulated legislation to make resorting to the law a very expensive exercise, out of the reach of ordinary persons. Big corporations can fund high court actions, little people do not have that option.

I agree with sunny, any approach to CAsA must be via associations (strength in numbers)but even then fraught with risk. How easy would it be for CAsA to circularise the members of an association with a question "Do you agree with your associations stance on this issue?" and bob's your uncle the rabbit in the spotlight again.

The USA and Australia are poor comparisons, read the FAA charter and compare it with CAsA's, then the numbers, I don't believe there are enough pilots left in Australia to have any political influence.

Australia is an intolerant Bureaucracy and one day may well become a Theocracy or even a Socialist state of a World government, but whilst the current breed of politician of any persuasion remains with chronic competence disorder we will never resemble a Democracy. People who believe otherwise watch too much public broadcasting to enable reasonable debate.

Please read the discussion paper and make a submission. In my experience ( I have been able have a number of bits of legislation changed by lobbying politicians) you need to be able to show a polly that you are not a dis-affected individual but a part of a community with a common cause. Persistence is the key and remember that politicians by their nature are narcissists and like to be highly thought of so they respond to personal contact with problems that they can assist in resolving.