Hook:-
CASA intro:- “Aviation medicine is complex, involving medical, regulatory and legal considerations. Mindful of this complexity, we have decided that a wide-ranging discussion paper is the best way to canvass community views about medical certification in the sport and recreation, general aviation, aerial work, air transport and air traffic control sectors alike.”
When there is a slim chance that a submission to a ‘discussion’ paper will be weighed, measured and considered, it is worth spending the time and making the effort to provide one. This ain’t one of those times. CASA Avmed can more readily access empirical statistics from sister bodies, such as the USA and would have done so, should there be an internal desire to utilize a similar system. The data, protocols and system details have been available for donkey’s years and if there was any chance of ‘change’ then the discussion paper would be referenced to the proposed changes to system.
Line:-
CASA intro:- “This discussion paper will form the basis for future consultation between CASA and all affected stakeholders on the issues raised and any action CASA proposes to take. Such consultation would take place through a dedicated development team, possibly leading to release of a notice of proposed rulemaking (NPRM) for industry and public consideration.”
The vast majority of ‘stakeholders’ (read pitch fork wavers) have little to no acceptable expertise “involving medical, regulatory and legal considerations”. Unqualified submissions may then be disregarded with impunity. The local DAME may well be qualified to provide ‘expert’ medical opinion; but their comment on ‘legal’ and ‘regulatory’ matters will, for the reasons mentioned, be discarded as quickly as those from the ‘unshriven’.
& Sinker:-
CASA intro:- “This discussion paper does not contain proposals for or draft regulations. That would be premature. What we need to do now is to identify and articulate the issues, and to begin to consider better ways to address those issues.”
No doubt ‘irritated’ by the constant yapping of the small dogs next door – a juicy bone is lobbed over the fence; this will keep ‘em quiet and occupied for a good long while.
Any real attempt at reformation would be presented as “we have considered the FAA pilot medical system and propose to bring a similar system into law”. “This discussion paper and the attached NPRM is provided for industry and public consideration”. Anything else is simply a bollocks, cunningly designed to provide employment for a number of years and make it appear as though CASA are actually doing something. No doubt there will be many sound, solid, well argued submissions presented, all making perfectly good sense; and it must be done. But the temptation to toss the discussion paper into the bin and never think of it again is great. In truth, ‘tis irresistible – THUD.
Toot- toot.
Last thought: perhaps a ‘discussion’ paper on how to stop CASA getting away, every time, with this sort of frivolous, time wasting, costly exercise would draw more ‘suggestions’ from ‘stakeholders’
CASA intro:- “Aviation medicine is complex, involving medical, regulatory and legal considerations. Mindful of this complexity, we have decided that a wide-ranging discussion paper is the best way to canvass community views about medical certification in the sport and recreation, general aviation, aerial work, air transport and air traffic control sectors alike.”
When there is a slim chance that a submission to a ‘discussion’ paper will be weighed, measured and considered, it is worth spending the time and making the effort to provide one. This ain’t one of those times. CASA Avmed can more readily access empirical statistics from sister bodies, such as the USA and would have done so, should there be an internal desire to utilize a similar system. The data, protocols and system details have been available for donkey’s years and if there was any chance of ‘change’ then the discussion paper would be referenced to the proposed changes to system.
Line:-
CASA intro:- “This discussion paper will form the basis for future consultation between CASA and all affected stakeholders on the issues raised and any action CASA proposes to take. Such consultation would take place through a dedicated development team, possibly leading to release of a notice of proposed rulemaking (NPRM) for industry and public consideration.”
The vast majority of ‘stakeholders’ (read pitch fork wavers) have little to no acceptable expertise “involving medical, regulatory and legal considerations”. Unqualified submissions may then be disregarded with impunity. The local DAME may well be qualified to provide ‘expert’ medical opinion; but their comment on ‘legal’ and ‘regulatory’ matters will, for the reasons mentioned, be discarded as quickly as those from the ‘unshriven’.
& Sinker:-
CASA intro:- “This discussion paper does not contain proposals for or draft regulations. That would be premature. What we need to do now is to identify and articulate the issues, and to begin to consider better ways to address those issues.”
No doubt ‘irritated’ by the constant yapping of the small dogs next door – a juicy bone is lobbed over the fence; this will keep ‘em quiet and occupied for a good long while.
Any real attempt at reformation would be presented as “we have considered the FAA pilot medical system and propose to bring a similar system into law”. “This discussion paper and the attached NPRM is provided for industry and public consideration”. Anything else is simply a bollocks, cunningly designed to provide employment for a number of years and make it appear as though CASA are actually doing something. No doubt there will be many sound, solid, well argued submissions presented, all making perfectly good sense; and it must be done. But the temptation to toss the discussion paper into the bin and never think of it again is great. In truth, ‘tis irresistible – THUD.
Toot- toot.
Last thought: perhaps a ‘discussion’ paper on how to stop CASA getting away, every time, with this sort of frivolous, time wasting, costly exercise would draw more ‘suggestions’ from ‘stakeholders’