CASA medical Standards Discussion Paper

[Mike Borgelt]

CASA has released a discussion paper on medical standards.

 

Review of medical certification standards | Civil Aviation Safety Authority

 

Looks to me like deliberate effort to obfuscate and delay any change by including the Class 1 medical in this. The only current problem with the Class 1 medical is CASA's colour vision standards which is pretty much a stand alone issue and easily fixable by aligning it with that of the FAA.

 

The medical standards discussion is otherwise about the Class 2 requirement for PRIVATE pilots. The Uk has already brought in a car driver's licence medical and the FAA is in the process of doing something similar. If the FAA guys are smart they won't delay or obfuscate in view of President Elect Trump's known antipathy to useless and irrelevant regulation.

 

We should of course align ourselves with similar western nations, particularly the USA as they do far more aviation than anybody at the private level.

 

I suggest you all write polite but pointed submissions to this DP and copy to the Minister and your local Federal MP. If you fly RAAus or GFA don't think you will be OK. You could be affected as one of the options seems to be to extend the RAMPC to recreational aviators.

 

For once don't think "I'm alright, Jack" and spend a little time to benefit all private aviators in Australia. You may like to point out that there is ZERO evidence that a formal medical does anything beneficial to the accident rate.

 

In fact, in 2002, CASA in a discussion paper on a Recreational pilot licence did acknowledge this point specifically.

 

Unfortunately that proposal did not see the light of day as Messrs Middleton of RAAus and Hall and Meertens of the GFA went to the Minister and demanded it not apply to RAAus and GFA. The rather clueless Minister, John Anderson agreed to do that. One of the more stupid actions inflicted on Australian sport aviation ever. No, they didn't ask the members if they wanted it.

 

 

[Jim McDowall]

As the RSL used to say "the price of freedom is eternal vigilance". It is essential that all of us with an interest in maintaining our flying "rights" make a considered response along the lines suggested by Mike.

 

The CASR's madate 1.003 (2) " (2) An object of these Regulations is to harmonise certain parts of Australia's aviation safety law with the FARs.".

 

The FAA is now manadated to accept the aeromedical reforms passed by the US Congress. (see Aeromedical Reform FAQs | EAA )

 

I am sure, given the litigious nature of the US, that the US legislators paid high regard to safety in adopting these rules. The reticence of CASA to follow the lead of the US and Britain and create the regulatory environment similar to those jurisdictions simply illustrates the resistance to change that is endemic in the organisation.

 

The lengths that CASA will go to are illustrated by the misquoting of the UK Civil Aviation Authority General Aviation Policy Framework:

 

The CASA discussion paper says:

 

"The questions relating to third parties are as follows:

 

2.1: Would the proposal/change to existing regulation involve an incremental increase in the

 

level of risk to third parties on the ground?

 

2.2: Would the proposal/change to existing regulation involve an incremental increase in the

 

level of risk to commercial transport users of airspace?

 

2.3: Would the proposal/change to existing regulation involve an incremental increase in the

 

level of risk to other general aviation users of airspace?

 

 

An answer of ‘yes’ to these questions

 

triggers risk assessments taking into account the criteria by

 

which probability and severity are to be measured and EASA and ICAO levels of risk."

 

In actual fact the UK Civil Aviation Authority General Aviation Policy Framework says in answer to the questions posed in 2.1, 2.2 and 2.3:

 

• If you answered yes to any of questions 2.1, 2.2, or 2.3, you must assess the level of the risks to these classes of third parties by using the following steps:
   
   
  

 

 

 

1. Conduct a risk assessment using the tables listed in Annex A and Annex B of this policy framework. Determine the level of risk to each separate class of third party (both probability and severity), taking geography and population density into account whilst making your calculations.
    
    
   
2. List the evidence relied upon in reaching the conclusions regarding risk. Also list any evidence you discounted.
    
    
   
3. If such risk is at a low level using the criteria in Annex B, the risk is acceptable.
    
    
   
4. If such risk is at a medium level using the criteria in Annex B, assess how such risk could be appropriately mitigated in a cost-efficient manner using a proportionate and targeted option.
    
    
   
5. Demonstrate using evidence that the above option will be effective and less burdensome than existing regulation.
    
    
   
6. If such risk is at a high level using the criteria in Annex B, STOP.
    
   
   The proposal/change to existing regulation is not appropriate. If a change to an existing regulation is proposed in order to remove gold-plating, proceed directly to 5.2.
    
    
   

 

 

 

After completing these steps, proceed to 2.4.

 

 

• If you answered no to 2.1, 2.2 and 2.3, continue directly to 2.4.
   
   
  

 

 

 

2.4 Would the proposal/change to existing regulation involve an incremental increase in the level of risk to others not on the aircraft which are not listed above?

 

 

• If yes, describe the risk identified, assess the probability and severity of the risk using the tables in Annex A and Annex B and identify targeted and proportionate options to mitigate identified risk. Determine costs associated with targeted option, and continue to 3.1.
   
   
  
• If no, continue directly to 3.2.
   
   
  

 

 

The omission of the word "ANY" changes the discussion markedly. The CASA paper infer that ALL questions must be answered "NO" in order to proceed directly to question 2.4

 

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 aan 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.

 

The foregoing is but a sample of the mis-statements that can affect the circumstances under which we are "permitted" to fly. So please take the time to respond to this discussion paper so that the weight of opinion leaves no doubt in the regulators mind that to do anything less than follow the lead of the US and hopefully the UK regulators.

 

Dont forget to copy in your local MP and your state's senators - they may be pilots.

 

Thmis

 

 

[Frankus1aust]

Downloaded the document. 45 pages. Might as well make a start while we have some time

 

 

[davebutler]

Here we go again, another talk fest, waste of tax payers money to find out what we already know and then to use some flimsy detail to maintain the status quo.

 

How much info do they need, the FAA did research and made changes as did the UKCAA, the NZCAA and I am sure there are more countries that have also made similar changes and add to that data from our own RA-Aus.

 

AOPA has already had a talk with them and put forward a proposal which I believe most are happy with.

 

Come on Mr CASA enough stalling lets see some positive action NOW!!!

 

 

[Mike Borgelt]

davebutler, what did the NZCAA do? I was there about 16 months ago and their PPL medical system was more expensive and difficult than ours then. I'm looking to flee this dreadful penal colony.

 

 

[dutchroll]

What exactly is a "car driver's licence medical"? Genuine question. As far as I'm aware, this is the exact same thing as not having medical category at all. I've been driving for 34 years and have never once had a medical examination for a driver's licence aside from an eye test at a licence renewal, and even then it was a long time before the eye test came in. Usually you just paid the money and that was that!

 

Why wouldn't the proposal be to simply scrap any and all formal medical standards aside from an eye test for private flying (not saying I necessarily agree with that in its entirety, but it's the same thing)?

 

 

[Mike Borgelt]

What exactly is a "car driver's licence medical"? Genuine question. As far as I'm aware, this is the exact same thing as not having medical category at all. I've been driving for 34 years and have never once had a medical examination for a driver's licence aside from an eye test at a licence renewal, and even then it was a long time before the eye test came in. Usually you just paid the money and that was that!Why wouldn't the proposal be to simply scrap any and all formal medical standards aside from an eye test for private flying (not saying I necessarily agree with that in its entirety, but it's the same thing)?

dutchroll, there are certain medical conditions , which if detected by your GP, require him or her to advise you and the relevant authority that you are medically disqualified from driving a car. If this hasn't occurred you can drive. The "driver's licence medical" means you haven't got one of those conditions and can legally drive a private motor vehicle.

 

Queensland doesn't even have an eye test for driving a car anymore. My optometrist is horrified as he has had people in who are legally blind and when asked, say they drove, but they had the "seeing eye missus" to help.

 

I'd support a PPL medical standard that required a statement from your optometrist as to your vision standard. Even if you are instrument rated most of your time you will be in a "see and be seen" environment.

 

 

[coljones]

dutchroll, there are certain medical conditions , which if detected by your GP, require him or her to advise you and the relevant authority that you are medically disqualified from driving a car. If this hasn't occurred you can drive. The "driver's licence medical" means you haven't got one of those conditions and can legally drive a private motor vehicle.Queensland doesn't even have an eye test for driving a car anymore. My optometrist is horrified as he has had people in who are legally blind and when asked, say they drove, but they had the "seeing eye missus" to help.

I'd support a PPL medical standard that required a statement from your optometrist as to your vision standard. Even if you are instrument rated most of your time you will be in a "see and be seen" environment.

I have just had a cataract operation. I didn't know the extent of my disability as I had 2 eyes and the other one worked. It was only picked as I was reactivating my CASA Class 2. I was still flying RAA through all this. If I had stabbed myself in the eye while flying (rough weather while plotting a diversion, say) I would have been flying blind. Makes you think, and I doubt my GP would have picked it up when I popped in for my flu shot. I don't have a problem with a DL style examination but without the Class 2 paranoia, even for RAA Pilots.

 

 

[dutchroll]

Right....so I guess it's an "absence of notified restrictions" rather than an actual medical category.

 

Of course, the problem with these things is that going to your GP for such a condition is entirely voluntary, and if you don't go, no-one will know. So I guess it's food for thought with medical standards.

 

 

[coljones]

Right....so I guess it's an "absence of notified restrictions" rather than an actual medical category.Of course, the problem with these things is that going to your GP for such a condition is entirely voluntary, and if you don't go, no-one will know. So I guess it's food for thought with medical standards.

The alternative to a Class 2 Medical for PPLs is the Recreational Aviation Medical Practitioner's Certificate (RAMPC) which is based on the Australian Road Transport (AusRoads) standards of medical fitness. It was expanded by AvMed to, additionally, target a range of aviation related conditions. The RAMPC used to be called a DL Medical. It is a test suite which the GP follows with a series of tick boxes and its greatest problem it is pass/fail - fail and you need to do a full Class 2 through a DAME and with AVMED poking through it.. A fit person with no hidden vices will pass a RAMPC but any probs and you are stuffed.

 

 

[dutchroll]

Well surely if you have a hidden vice which flags an alert as far as operating machinery like an aeroplane, then it should be investigated by an appropriately qualified doctor to ensure that it is not something which affects your abilities in that respect?

 

I guess what I'm saying is that there should be a medical standard to meet of some description. However I do sometimes get the vibe when reading commentary about "easing" private pilot medical standards (something I don't inherently object to as long as it is done sensibly) that there is a small community out there which would like to advocate for zero medical standards to meet, or a situation which would have the same effect like relating the aviation medical standard to that of a drivers licence, which in practical terms is virtually none at all.

 

It is hard to collect data on whether medical standards have or haven't prevented accidents because by default, pilots with significant medical problems are grounded until those problems are resolved, like I was early last year (and was allowed back flying again when it had been fixed). So under the current regime you'll never know whether they would've ended up being a statistic or not. A certain level of gastro incapacitations in commercial pilots contributes little knowledge to this topic because by default, the inherent risk of eating out by necessity in weird and wonderful slip ports is going to sometimes result in consumption of a dodgy vindaloo, but in a two-pilot aircraft this risk is mitigated by default.

 

My wife was recently driving behind a truck driver on the M1. He coasted to a stop right in the middle of the motorway. As a doctor she stopped behind him and walked to the driver's side to check whether he was ok. He'd gone into a diabetic coma which had been undiagnosed. From a risk-management perspective, that's not the sort of thing you want to happen in a single-pilot aircraft.

 

 

[facthunter]

There ARE standards applying to driving private cars .I've had mine cancelled in error and that required sorting out with my GP who knew all the rules. She originally said I should inform them along certain lines but they wouldn't accept that, even though she felt they should. She had to send the information to them herself and I was not able to drive until the erroneous assumption had been cleared up.

 

IF you have any record of some "problem" you cannot tick ALL the boxes so the RAMPC is not for you. A problem will be there even IF you went in for a check of some condition and nothing was found to be a problem. You should never be discouraged from going into have any symptoms checked but this process does just that. You are penalised for being cautious and responsible and doing what all Doctors advise.

 

Anyhow there are plenty of words written to define what is required for the standard to be able to drive a private car in various states and being realistic I can't see how you should expect be able to drive a plane with a lesser standard or no medical. When you state that you meet the medicals standards to drive a car, IF you do that deceptively you will be breaking the law. You can't claim ignorance of the facts of what the standard is as defence either. There are plenty of misconceptions about what really applies here. Over a certain age or with having had certain conditions you will require a statement from your GP backed up by specialist reports if necessary. to keep the medical, and drive (or fly) Doctors reports are often the initiating factor in a driver having to do extra testing to retain a licence. Nev

 

 

[Jim McDowall]

Guys,

 

The ATSB report I previously referred to says it all. 6 pilot incapacitations per annum for low capacity air transport. This why the FAA and the UK CAA have elected to abandon regular medicals for recreational and non-commercial GA. The cost of this particular regulation to the community is not justified and an impediment to the growth of private aviation. I am sure if all the medical episodes discussed above happened on the road the consequences would be worse than a possible accident of a single pilot aircraft with a high probability that a road accident will involve other road users AND YET we as a community accept it and move on. Why should private aviation be burdened with this impediment of medicals when that are demonstrably incapable of identifying many medical events (eg stroke) and are based on a probability sets many of which are outdated or so broad to be of little use. Dont forget your RAMPC or Class 2 medical has a lifetime of upto 2 years- how many medical conditions can arise in that period or should we have a medical before each flight? The combined scientific evidence examined by the FAA and CAA concluded that there was very little point in medicals for private pilots.

 

 

[Mike Borgelt]

I have just had a cataract operation. I didn't know the extent of my disability as I had 2 eyes and the other one worked. It was only picked as I was reactivating my CASA Class 2. I was still flying RAA through all this. If I had stabbed myself in the eye while flying (rough weather while plotting a diversion, say) I would have been flying blind. Makes you think, and I doubt my GP would have picked it up when I popped in for my flu shot. I don't have a problem with a DL style examination but without the Class 2 paranoia, even for RAA Pilots.

col, that's nice for you but I have to ask if you inspect and maintain your car and your aircraft, why you weren't having your body regularly inspected too? Eyes are important and I can't believe you didn't notice that one eye was a fair bit better than the other. Anyone over 40 should be being checked by a competent optometrist every 12 months for various eye conditions which can be more easily treated if caught early (glaucoma, cataracts, macular degeneration, etc)

 

 

[Mike Borgelt]

dutchroll, as Jim McDowall points out the risk analysis has been done. I'm not up on the exact details of the driver's licence medical in the UK but the proposed FAA one involves an initial examination and an online refresher course in medical factors very two years.

 

The CASA or other government mandated medical isn't about YOU or your health. It is about attempted risk mitigation to innocent people on the ground and other airspace users. Aircraft crash all the time for reasons due to bad maintenance or much more usually, utterly stupid pilot decision making or because pilots never were taught to fly properly in the first place. It is EXTREMELY rare that even property on the ground is damaged. Hence any rational risk assessment says that the risk mitigation of having a formal aviation medical is not worth the expense. There is nothing preventing YOU having any standard of medical exam of your choice at any time. The RAMPC is EXACTLY the same medical as for a PPL. It is a HEAVY VEHICLE driver's licence medical with a few extra CASA restrictions, which can be done by a GP.

 

The hazards to innocents are far higher in a private car than in a small aircraft. Consider collapsing at the wheel and running a school bus coming the other way off the road resulting in a rollover or collision with a tree by the bus.

 

This driver's licence medical experiment has been run with no adverse results. Around 40% of Australian private pilots already fly on the RAAus driver's licence medical standard .i.e. not precluded from so doing by a disqualifying medical condition or the GFA self declaration medical (no known medical reason why you shouldn't fly a glider). It has also been run in the USA where private glider, motorglider and balloon pilots fly on a self declaration medical.

 

I don't have the URL's handy but you can search and find that there are at least 3 major studies done over the last 45 years or so on the effectiveness of formal aviation medicals. There was none. In fact, the people without the formal medical had a slightly lower rate of medical incapacitation caused accidents than the one with the formal medical in one study. Probably not statistically significant as the rates were so low anyway.

 

Dick Smith was berated for his stance on "affordable safety" by idiots without a clue. As he said, the alternative is unaffordable safety (pretty much what we have in Australia as light aviation is slowly suffocated to death). What it really means is spending the always limited money and resources for the most effective outcome. As the PPL medical costs AT LEAST around $3.5 million a year in Australia and has been shown to be ineffective the money would better be spent by the pilots on getting some more practice in the aircraft. It is a lot more fun too. I can fly an extra 6 hours in my aircraft for the cost of the medical.

 

As for your truck driver example with the diabetic coma, a few years ago a woman collapsed at the wheel of her car on the Sunshine Coast Motorway, ran across the median and collided head on with a car coming the other way resulting in the death of a child in that car. She didn't go to jail but you might like to consider that she was an insulin dependent diabetic and a GP.

 

I don't believe insulin dependent diabetics need more than a GP clearance to drive and yes, I have had to talk one out of driving when his blood sugar got too low and he got all weird and paranoid. Took me 20 minutes sitting in the front passenger seat to convince him to have a sip of a soft drink whereupon he came good in about a minute and had a sandwich. (Don't get me started on the current medical treatment of diabetes which seems designed to sell drugs and kill and disable people. My wife (former RN) has done a lot of research over the last few years. Search for high fat, moderate protein, low carbohydrate diets.)

 

Anecdotes like yours about the truck driver or mine about the GP don't actually add to any rational analysis of the safety debate. Proper statistical analysis and a hard headed cost/benefit study is required, not some "feelz" that a formal aviation medical is a good idea which might make you or others more comfortable. After all, you are asking that the government put a gun to my head in order to lighten my wallet for no no good purpose.

 

 

[coljones]

col, that's nice for you but I have to ask if you inspect and maintain your car and your aircraft, why you weren't having your body regularly inspected too? Eyes are important and I can't believe you didn't notice that one eye was a fair bit better than the other. Anyone over 40 should be being checked by a competent optometrist every 12 months for various eye conditions which can be more easily treated if caught early (glaucoma, cataracts, macular degeneration, etc)

Yes, it does come as a wake up call!!

 

 

[01rmb]

To complete the CASA medical CASA requires a full history to the month including a broken leg, any pain relief, over the counter medication or herbal medicines taken over the last 4 years, any visits to a chiropractor and anything else that may have ever happened in your or your families life! At what point does this history of temporary events become irrelevant to what is going to happen in the next 1-4 years and which would if not disclosed lead to an increase the risk to the general population?

 

By all means check normal function and history to ensure safe operation an aircraft such as vision, diabetes, seizures, psychiatric conditions and heart disease but to have to declare a Codral taken 4 years ago for a cold? The whole CASA medical process seems to take a reasonable medical assessment of fitness to fly to a whole level of extreme paranoia.

 

The medical if needed to investigate any issue should be able to be conducted by any doctor and be limited to any long-term or permanent injury or illness that may affect their ability to fly safely.

 

 

[dutchroll]

In fact, the people without the formal medical had a slightly lower rate of medical incapacitation caused accidents than the one with the formal medical in one study.

You imply knowledge of statistical analysis and you quote that?

What were the confounding factors?

 

Who was in the study group?

 

What was defined by "accident"?

 

What type of medical examinations did they have?

 

Were there inherent age differences?

 

We're there inherent pilot occupational differences?

 

How often did they fly?

 

What are the causation/correlation factors?

 

Etc etc etc.

 

How do you expect to be taken seriously simply by saying (paraphrased) "people without a formal medical are less likely to crash?"

 

That's utter nonsense. I'd suggest a study showing that is unlikely to be worth the paper it is written on.

 

 

[planesmaker]

RAAus pilots have been operating aircraft on a self declared medical for over 20 years quite successfully. most private pilots are not likely to do more than100 hrs a year or 2 hours a week ( probably more likely 1hr). That translates to 2 in 168 hrs fairly low risk wouldn't you think. Any responsible pilot knowing any medical condition that would affect their flying, would ground themselves until fit again, nanny state not required.

 

 

[Jim McDowall]

Have a look at the UK CAA medical declaration - most illuminating.Note the period of validity - once only upto age 70 - 3 years after that.

 

Here is the link -

 

https://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=form&id=7493

 

This is even more relaxed than the annual GFA or Ra-Aus certification.

 

 

[djpacro]

FAA reviews AOPA medical course - AOPA

[rgmwa]

That's good. CASA just reminded me that my Class 2 expires in a couple of months, but as they are sure follow FAA's lead, I'll let you all know how the new system works. Can't wait!

 

rgmwa

 

 

[planesmaker]

I won't hold my breath waiting for CASA to change the medical. Maybe 12 months or more,maybe before the next medical in 2 yrs?

 

 

[Mike Borgelt]

You imply knowledge of statistical analysis and you quote that?dutchroll,

 

I actually said:

 

"In fact, the people without the formal medical had a slightly lower rate of medical incapacitation caused accidents than the one with the formal medical in one study. Probably not statistically significant as the rates were so low anyway."

 

Read it properly and don't put words in my mouth. As I said I don't currently have the URL's, as I found the websites as a result of a discussion on medicals on the aus-soaring list server a couple of years ago. DO YOUR OWN RESEARCH.

 

AFAIK the research studies were done properly and were extensive, covering thousands of pilots over many years. How about YOU find and post some studies that show that a formal aviation medical for PRIVATE pilots does any good at all?

 

If we are going to have regulation on safety grounds it must be shown to be effective or it is simply spending money and time for no good purpose, resources which can be used for other things.

 

So far you've only added noise not signal to the discussion. I really don't care if you want regulation up the gazoo for yourself, just refrain from imposing it on others for no good purpose.

[Frankus1aust]

I won't hold my breath waiting for CASA to change the medical. Maybe 12 months or more,maybe before the next medical in 2 yrs?

My last medical took six months from application, and was a 12 months certificate with renewal based from the date of my application asking, for 12 months worth of data for reapplication. Bearing in mind they want you to submit the renewal 4 weeks early (for "special" cases), that gives me PIC privileges for 5 months before reapplication. Since my cert runs out start of Feb, that means I have to supply all the data at the time when all the medicos are on holidays. So I have to get in early. That means at best I have 5 months or less of data for them to evaluate when they really want 12 months. So with the short time frame data set I'm guessing they will extend my limitations for another 12 months and I will maybe get 8 months worth of viable C2 Med (with safety pilot limitations). Is this just a load of nonsensical BS or am I just being unreasonable?