AOPA calls on CASA for private pilot medical reform

[Guest Benjamin]

29th July 2016

 

Mr Mark Skidmore

 

Director of Aviation Safety (CASA)

 

Civil Aviation Safety Authority

 

GPO Box 2005

 

Canberra ACT 2601

 

Australia

 

The Hon Darren Chester MP

 

Minister for Infrastructure and Transport

 

House of Representatives

 

Parliament House

 

Canberra ACT 2600

 

Australia.

 

- Members of the Aircraft Owners and Pilots Association

 

- Users of the Aviation Advertiser – Australia network

 

- Government Ministers and Senators

 

- Industry media

 

Aircraft Owners and Pilots Association supports the

 

Sport Aircraft Association of Australia call for PPL medical reform.

 

Mr Mark Skidmore,

 

I am writing to you as the Executive Director of the Aircraft Owners and Pilots Association (AOPA) in support of the request submitted by the Sport Aircraft Association of Australia (SAAA), calling on the Civil Aviation Safety Authority (CASA) to reform private pilot medicals.

 

Australia’s general aviation industry is being negatively impacted by excessive aviation medical assessments and approval requirements on private pilots license holders. The result has been the broad discrimination of a large number of experienced and healthy pilots, removing them from active flying and forcing them from our industry.

 

Over the past 9 years, a significant number of general aviation pilots have been forced to side-step into RAAus membership, to avoid the aviation medical bureaucratic red-tape. This transference of pilots has played an enormous role in pushing our general aviation industries into serious decline and toward bankruptcy.

 

AOPA estimates that the current CASA medical assessment and approval process is unnecessarily burdening general aviation pilots in excess of $10 million per annum. An unnecessary financial impost that is now recognised by leading aviation regulators as having no measurable value on aviation safety whilst negatively impacting industry economic performance and sustainability.

 

AOPA calls on CASA to take immediate action to harmonise private pilot aviation medical requirements, benchmarking both the United Kingdom and the Unites States of America, to provide all Australian private pilots – regardless of aircraft type flown – a level playing field.

 

As you are aware, the Civil Aviation Administration of the United Kingdom on the 9th May 2016 announced significant changes to medical requirements for private pilots. These changes were a result of extensive industry consultation, which found that 96% of industry respondents supported reducing medical requirements for private pilots to that of a drivers license standard.

 

The UK CAA determined that existing PPL medical requirements were disproportionate, costing private pilots both time and money unnecessarily, when compared to the benefit they provide.

 

The UK CAA consultation process considered the potential risks incurred by introducing changes, these included;

 

a) GA fatal accidents with potential medical causes

 

Over a 10 year period 151 GA fatal accidents of which only 20 could have been possible medical causes. These included factors such as hypoxia, fatigue, dehydration, alcohol and suicide. The UK CAA determined that there was a significant degree of uncertainty with regard to the actual cause of these accidents, with the medical cause only suspected. As a result, it was decided to focus the risk analysis on serious incapacitation in flight.

 

b) Third party risk

 

UK CAA historical records demonstrated that the probability of a GA accident causing injury to people on the ground is extremely low. Over a 10 year period from 2004-2013, out of the 151 GA fatal accidents, there were a total of six (6) accidents involving third parties on the ground. Only two (2) of these accidents resulted in fatalities and both involved third parties involved in aviation activities. The UK CAA determined that there were no fatalities to a third party as a result of serious incapacitation of the pilot. It was therefore determined by the UK CAA that there is no significant increased risk to third parties identified.

 

c) Risk of incapacitation in flight

 

The UK CAA gave consideration to the risk of incapacitation in flight by looking at the likelihood of different medical conditions occurring which could result in pilot incapacitation. The focus was on conditions which could result in sudden incapacitation (e.g. heart attack, seizure) where the pilot may be unaware of symptoms at the start of the flight. The considered risk profile was based from consultation, where 99% of respondents stated that private pilots do not generally take part in flying if they feel unwell. The UK CAA determined that there could be a total of approximately two (2) acute medical incapacitations events in-flight per year, compared with approximately one (1) at present. The UK CAA determined that whilst the risk of pilot medical incapacitation is increased, the absolute risk of a medically caused accident was assessed to be very low.

 

As a result of their extensive industry consultation and assessment of risks, the UK CAA have updated their regulation so as to reduce the medical requirements for private pilots, accepting an ordinary drivers license medical standard with no routine requirement to attend for a medical examination. The UK CAA clarified that pilots will be required to complete an on-line form once prior to the age of 70 years (and every three years after the age of 70) to make a legally binding statement that they meet this standard.

 

The UK CAA demonstrated that the drivers license medical was a more proportionate approach and would reduce both the amount of time and money spent on medical examinations and tests by private pilots, whilst having little to no impact on overall safety standards.

 

Attached to this email is a copy of the UK CAA CAP 1397 APR16

 

AOPA calls on you Mr Skidmore to take immediate action and to demonstrate your support for general aviation by removing the unnecessary private pilot medical assessment and approval red tape. If you would like to discuss this matter further, please contact me directly. AOPA stands ready to work with CASA on this important issue.

 

Best regards,

 

BENJAMIN MORGAN

 

Executive Director

 

Aircraft Owners and Pilots Association

 

Mobile: 0415 577 724

 

Hangar 600, Prentice Street, Bankstown Airport NSW 2200, Australia

 

PO BOX 26, Georges Hall, NSW 2198, Australia.

 

Telephone: (02) 9791 9099

 

Facsimile: (02) 9791 9355

 

Email: [email protected]

 

Web: AOPA Online : Aircraft Owners & Pilots Association of Australia

 

 

[facthunter]

I'm glad you posted that. (I am a member as I've often mentioned) and I have emailed them on this matter, and was fairly involved with the ill fated RPL. Skidmore has made comments about his attitude on the uSA situation which wouldn't give a lot of ground for optimism, but you have to keep trying. If you get the chance send your views (or information) to people who might have some effect on improving things. Nev

 

 

[Guest Benjamin]

Thank you for your response and support for AOPA's call for medical reform. I can assure you that AOPA are determined to achieve a positive result for Australian private pilots.

 

In my view there is no greater issue affecting aviation. Over the 9 years I have been involved in this industry I have received countless letters and documents pertaining to excessive medical assessments and approval processes - all of which are costing Australian pilots money and time.

 

A myriad of examples can be found where CASA AVMED have subjected pilots to extreme delays and stress in approving pilot medicals. The evidence has been piling up and the facts are our industry needs immediate relief.

 

Just a couple of days ago, I received a telephone call from a distressed pilot whom had undertaken his medical assessment and indicated that he socially drinks beer and that he could consume up to three (3) drinks per week. As a result, AVMED have subjected the pilot to unnecessary additional liver function tests. The consequence of which is increased medical assessment costs and lengthy delays.

 

The result of this madness is too many Australian pilots no longer flying and fewer aircraft hours flown!

 

 

Because of the above, thousands of general aviation private pilots across Australia have had no other option, than to move across to recreational sport flying to continue. The absurdity of course is that CASA AVMED deem these pilots unfit to fly, then in the same breath CASA approves them to fly with a recreational license! Go figure.

 

As more and more general aviation pilots are medically forced out by AVMED stupidity, general aviation will continue to suffer economic collapse, as fewer and fewer general aviation aircraft are being purchased and operated.

 

This situation is having a catastrophic impact on our aircraft engineering support industries, as businesses struggle to pay their rent and staff costs due to reduced customer inflow.

 

The result of this has been increases in operating costs for all commercial general aviation businesses, as they now struggle to cover their overheads. Pushing those that remain towards closure.

 

Be under no illusions, CASA have created the industry crisis that is enveloping general aviation.

 

Please do not take my comments as negative towards RAAus or recreational flying. I am fully supportive of the continued growth and development of this fantastic market segment. As recreational flying matures, this will be an incredibly valuable and influential component of our aviation industry without any doubt. More and more youth will be introduced to aviation through this exciting market segment, which has lead the charge on reducing costs to aviators.

 

 

That said, I feel it is important to protect the rights of all Australian private pilots, so that they may be free to fly whatever aircraft type they desire, without discrimination by CASA AVMED.

 

Best regards,

 

BENJAMIN MORGAN

 

Executive Director – Aircraft Owners and Pilots Association

 

Chief Executive – Aviation Advertiser - Australia.

 

 

[Kyle Communications]

Yes well the RPL route has been a klusterf**k. I can drive a 64 tonne B Double but cant pass the CASA RPL Ausroads infected medical.....what sense are you going to get for GA?....the place is run by idiots

 

 

[turboplanner]

Over the past 9 years, a significant number of general aviation pilots have been forced to side-step into RAAus membership, to avoid the aviation medical bureaucratic red-tape.

I don't like this positioning statement at all.

 

Driver Licence medicals are likely to come under scrutiny, starting with Victoria - see this link which starts out by saying hundreds of thousands of Victorians with a medical condition that may make them unsafe are going undetected by Vicroads, is alarming.

 

Thousands of unsafe drivers on the roads? VicRoads under fire for medical reviews of drivers

 

As a result of what's come to light, it would not surprise me to see, in the near future, a tightening up of reporting obligations by the driver, and a much higher level of assessement by Vicroads.

 

As we know from recent discussions, for an RAA certificate you don't require a driver's licence; you just have to meet the standard of health required.

 

So positioning RAA at the bottom of the health heap in a high profile gripe with the Minister is likely to beg the question of HOW an RAA Certificate holder assures the Association of this, who is auditing pilot reporting of medical defects, and who is assessing those defects against the licence standard.

 

This could open up a whole new and unwelcome can of worms that could affect RAA pilots.

 

 

[Bats]

The law of unintended consequences perhaps? That said, there are quite a few thousand RA-Aus pilots puttering about the place and despite the fact that a few may be there precisely because they wouldn't pass any more onerous a standard, there is a manifest lack of them plummeting out of the sky, turning blue and clutching their chests, which supports the original argument, non? I note that the same approach was used in the US submissions, with great success as it turns out.

 

 

[Vev]

I think AOPA should be congratulated for taking up this issue.

 

I have long held the view that CASA AVMED adds very little to safety and may even cause a health and safety issue. I am concerned there are pilots forgoing proper health management, on very treatable conditions, out of fear that CASA may find out about a minor health issue and unreasonably ground them or send them off for ridiculous testing.

 

In my view, CASA would do better to educate pilots to develop better health behaviors centered around their GP's qualified advice.

 

The AVMED system for private pilots is broken, it's costly, ineffective and most probably counter productive ... the experience with RAA surely demonstrates that pilots can manage their own health issues evident by the lack of fatalities related to medical causes.

 

I will be sending a copy of the AOPA letter supported by my own cover letter to my local MP today.

 

Cheers

 

Vev

 

 

[facthunter]

I got a personal letter in response to mine from AOPA yesterday. This is the organisation to protect and advance pilot's conditions. Organisations like RAAus and other pilot bodies may feel inhibited at getting into CASA when they should, for fear of compromising their dealings with them. AOPA don't rely on favours from the Authority or the parliament. I'm not criticising the RAAus either. They have been strong when they feel the need lately,. but the situation existing with conflicting interests is my point. Do you have to be "nice" to CASA to exist or get good treatment. Have they been vindictive on occasions.? I know they have and so do others. They should face criticism or analysis without any fear or favour involved.. Nev

 

 

[turboplanner]

there is a manifest lack of them plummeting out of the sky, turning blue and clutching their chests, which supports the original argument, non?

You missed the point; the Driver's Licence conditions might soon eliminate some aviators automatically. Now is certainly not a time to be raising noisy heads above the parapet.

 

 

[Bats]

No I didn't miss the point, just chose not to address it, not wanting to produce a thesis on the subject. I wouldn't be overly concerned about drivers licence standards ramping up significantly in any of our lifetimes, every voter and politician over 40 is aware that they will one day become old, or have elderly parents who face losing their independence. Curbing what most see as a right, will be a political minefield and after some noise and consultation will be watered down to the point of removing only the entirely decrepit from the driver pool.

 

 

[Mike Borgelt]

I don't have the URL's but I researched this issue a few years ago and since the early 1970s there have been at least 3 studies on this in the US. All concluded there was NO safety benefit to formal aviation medicals. In fact there seemed to be a small benefit to NOT having them, possibly due to people without them not flying when feeling off while someone with a medical may say "I must be OK, I have a medical".

 

We've run this experiment as glider, motorglider and private hot air balloon pilots in the US have no formal medicals. Same in Australia for glider pilots and RAAus.

 

If we are going to have regulation it should be EVIDENCE based, not based on vague feelings or "we've always done it that way". IF Skidmore won't get on board the Minister needs to be pressured to remove him.

 

Ben Morgan, I'll get Australian EAA to support your move in a letter to CASA. May take a couple of weeks.

 

Private and sports aviation regulation in Australia is an unholy shambles of conflicting and differing regulatory requirements with organisations like GFA and RAAus bought by CASA for a pittance each year when they should in fact be acting for their members.

 

CASA is charged by Parliament with regulating. So do it. The various organisation should be consulted and should lobby politically to make sure the regulations are the minimum necessary and are evidence based. The regs must be CASA regs, not rules or quasi regs promulgated by private organisations like GFA and RAAus which can force people to join them. Whatever happened to freedom of association?

 

 

[Mike Borgelt]

Turbo, how is this going to have bad effects? If someone is eliminated by a Driver's Licence medical requirement being slightly tightened, they sure aren't going to pass the RPL or PPL medical so won't be able to fly anyway. In any case a DL medical STANDARD is all that's required, not an actual licence. In coming years there may be quite a few people who don't or never learned to drive due to self driving cars appearing and things like Uber and Lyft. Already young people in the US are delaying getting driver's licences.

 

 

[kgwilson]

I note that we have stats from the UK.

 

"Over a 10 year period 151 GA fatal accidents of which only 20 could have been possible medical causes. These included factors such as hypoxia, fatigue, dehydration, alcohol and suicide. The UK CAA determined that there was a significant degree of uncertainty with regard to the actual cause of these accidents, with the medical cause only suspected. As a result, it was decided to focus the risk analysis on serious incapacitation in flight."

 

What are the stats of fatal accidents in Australia in the last 10 years?

 

Given the Jabiru fiasco where fuel starvation and oil leaks & on the ground shutdowns were all labelled in flight engine failures, CASA are likely to label all fatal accidents as having possible medical factors because dying is a medical issue.

 

This is a cynical viewpoint but based on history entirely justified IMHO.

 

 

[turboplanner]

Turbo, how is this going to have bad effects? If someone is eliminated by a Driver's Licence medical requirement being slightly tightened, they sure aren't going to pass the RPL or PPL medical so won't be able to fly anyway.

Which group has just gone on the public record as flying at the same level as a driver's licence? ..........RA.

 

What happens in PPL or RPL is the problem of GA, not RA.

 

In any case a DL medical STANDARD is all that's required, not an actual licence.

Now that RA has come to public attention, what's to stop someone thinking "I wonder how they prove they meet the driver licence standard, I wonder how RAA address Compliance and Enforcement on reportable illnesses.....and the fire takes off.

 

 

[Vev]

Now that RA has come to public attention, what's to stop someone thinking "I wonder how they prove they meet the driver licence standard, I wonder how RAA address Compliance and Enforcement on reportable illnesses.....and the fire takes off.

Hi Turbs, I think understand your concern and I agree there is some risk in RAA becoming highlighted and forced to demonstrate their risk mitigation process. However, I do think your concern, whilst legitimate, is low risk regarding a curtailment of the norm and an increase in medical standards required for RAA pilots.

 

Reasonably, in my view, the audience that is likely to challenge the RAA medical is going to be the same people that will oppose the AOPA push ... If I was developing a strategy to suppress change I would not be inclined to attack a model (RAA) that can argue success through the use of empirical evidence.

 

Cheers

 

Vev

 

 

[turboplanner]

Hi Turbs, I think understand your concern and I agree there is some risk in RAA becoming highlighted and forced to demonstrate their risk mitigation process. However, I do think your concern, whilst legitimate, is low risk regarding a curtailment of the norm and an increase in medical standards required for RAA pilots.Reasonably, in my view, the audience that is likely to challenge the RAA medical is going to be the same people that will oppose the AOPA push ... If I was developing a strategy to suppress change I would not be inclined to attack a model (RAA) that can argue success through the use of empirical evidence.

 

Cheers

 

Vev

That view is based on logic; analyse the injury/fatality data > research what, if any Medical process will provide an optimum result > adopt that into policy.

 

Life isn't like that; just ask the extinct NSW greyhound industry.

 

In any case, the comments are now out there and searchable.

 

 

[Mike Borgelt]

Which group has just gone on the public record as flying at the same level as a driver's licence? ..........RA.What happens in PPL or RPL is the problem of GA, not RA.

Now that RA has come to public attention, what's to stop someone thinking "I wonder how they prove they meet the driver licence standard, I wonder how RAA address Compliance and Enforcement on reportable illnesses.....and the fire takes off.

Oh goody, the old Australian "we're all right Jack, F--- you."

 

Brilliant.

 

It is easy to see how CASA has divided and conquered.

 

Do you REALLY think the leadership, to use the term loosely, of RAAus is going to arc up if CASA insists on raising the medical standards? I highly doubt it. They'll come out with platitudes and meekly roll over.

 

As for public attention, most of the public think that people who fly gliders or RAAus aircraft are suicidal loonies who get everything that was coming to them. They don't care.

 

 

[mike_perth]

Surely though consideration must be given to the fact that the current medical testing prevents accidents because it stops those at risk from flying. If medicals weren't needed would the accident rate in GA increase? Looking only at RAA, Gliders and other non medical/basic medical required is there a higher proportion of medical related accidents?

 

 

[Bats]

If you read the overseas studies referred to in posts above, the answer is no. Aviation medicals started in the military, ensuring that pilots were fit for the rigours of combat including Gs, high altitude etc. Since then the various aviation medical departments have become a self-perpetuating industry, inventing ever more stringent tests with little or no clinical relevance and removing people who by any normal definition are fit, from the pilot population. Ask most specialists about CASA Avmed's revised cholesterol standard, or the infamous colour vision tests - then stand back and watch the explosion.

 

 

[mike_perth]

I've just re-read the report mentioned in the OPs letter - UK CAA CAP 1397 APR16

 

And to be honest I still think my point is valid - and please don't think I'm saying this because I'm super fit and pass a class 2 with ease....I don't...my class 2 picked up hypertension a few weeks ago which has meant a long list of further testing that's still not over, but has this stopped a potential ticking time bomb of a pilot from flying...absolutely...did I know I was a ticking time bomb before the medical...no way.

 

I feel the statistics are so low and there has been few in flight incapacitations due to a medical condition because the system we have as annoying and drawn out and slow and expensive it is keeps pilots likely to be incapacitated out of the cockpit. Surely that makes some sense.

 

Has anyone got the statistics on how many medical incapacitation events/accidents have occurred in RAA with the lower medical standard?

 

Don't see this as an RAA bashing I hope to be an RAA pilot myself in the coming weeks just an observation.

 

 

[planesmaker]

Mike your dealings with CASA have only just begun. Passing a medical guarantees nothing medically. You could be severely impaired from the pizza you ate last night. RAAus drivers license medical has been good for 1000's of pilots flying lots of hours. I'm in favour of AOPA's call.

 

 

[mike_perth]

Mike your dealings with CASA have only just begun. Passing a medical guarantees nothing medically. You could be severely impaired from the pizza you ate last night. RAAus drivers license medical has been good for 1000's of pilots flying lots of hours. I'm in favour of AOPA's call.

Im certainly under no illusions that my path with CASA is complete I figure I have months of tests ahead of me at best.

 

And I'm not saying at all I don't support the idea of a reduced medical requirement...I'm just asking if this is going to make the skies less safe than they are now? Nothing more nothing less

 

 

[planesmaker]

Apparently not

 

 

[Bats]

Mike-perth, part of the debate centres on; less safe than what? From where I stand, it is ludicrous to demand a higher standard of medical fitness (according to a discredited protocol) from the pilot of a Cessna with 2 pax, puttering from Woop-Woop to Toowoomba, than from the driver of a large bus or truck, operating in close proximity to anything from other trucks, to the humble pushbike and at closing speeds approximating a light plane's cruise speed. The oft quoted response is we'd all be safer if no-one moved faster than they could run and indeed if no-one got airborne, but society will not pay the price for that improvement in safety so we need to find a balance somewhere between utopia and anarchy.

 

As for the RA-Aus medical incapacitation stats, again an almost impossibly small sample - I know of one instance in the past few years which was anecdotally ascribed to incapacitation (mainly because they couldn't find anything else to pin it on), but not confirmed by the coroner to the best of my knowledge. On the other hand there are examples most years of airline pilots becoming incapacitated and even dying, in some instances within days of passing an even more stringent medical than we are subject to, so the medical is not a warranty against this happening.

 

 

[greybeard]

Mike-Perth.

 

I also had a few things picked up by my class 2 medical that I wasn't aware of that would have pushed me off the perch quicker than I hope for. Whilst the class 2 is a partial pain and yet another cost I could live with it if it was just the class 2 every couple of years. Unfortunately once you get pinged for anything the costs start to ramp up rapidly for what (my DAME and) I believe re excessive and duplicated tests. I have a perpetual cost to try and continue keeping my class 2 every year. This includes std class 2 medical, special trip to CASA rated optometrist for (what seems like) the same eye test that the DAME has given me (extra $250/annum) , special trip to the tredmill for a stress test and cardio report from a cardio who wants to know why I'm wasting their time when sick people need to be treated (~$600/annum), annual vampire test at the pathologist. And to get all of this done requires trying to coordinate appointments with specialists that can have waiting lists of 1-2 months.

 

So, as you say, it's a good thing that your DAME picked up on your hypertension (me too, I've forecast your future with and annual tredmill and cardio report) and 'a' visit to a specialist as directed by your GP is a good thing if they recommend it. But the change from every two years for an over 40 class 2 medical to annual and the ~$1k all up cost is just taking the piss.

 

Oh, just to rub salt into the wound, the last two years CASA have 'lost' the reports from my DAME and specialist causing months of delay. Last medical I did in December last year came through in May this year, still with an annual expiry date in December this year.

 

I'm used to the class 2 medical and every couple of years seems to be ok with me, if nothing else it makes me visit a doctor for a checkup and oil change, but if a DAME needs special training from CASA (and it's expensive training), why isn't the DAME good enough to say if I am dead or not? Why all the specialists reports?

 

CASA need to held to account to justify why specific requirements are in place and it should be part of their charter to unregulate themselves out of a role.