[Peetwo]

Hook; line; sinker; & a parallel universe -  

Our public servant are no longer servants of the public Sandy, they are self servers.

On UP duty (yawn -   ) I note that there is a thread (currently active and not yet shutdown    ) that is endeavouring to discuss the CASA Avmed discussion paper...

Last post courtesy of thorny...

TB - "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.

Besides thornbird's latest contribution, which risks possible moderator sanction due suspicions of sarcasm and possible CASA derogatory comment, there seems to be much confusion and scepticism on the real intent and purpose of the CASA bollocks DP...

Here is a small cross section of some of the UP posts:

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Old Akro -

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.

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Icarus2001 - 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.

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Old Akro - 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.

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 Which leads me back to the TB post...     

While on the CASA Avmed DP, this was from the horse's mouth Herr Comardy in the introduction to the DP:

...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...

...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...

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...

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’

Unfortunately the Ferryman's pessimistic post is IMO about as close to reality as you'll get.

I seem to recall that this cynical attempt by CASA, at placating the miniscule and obfuscating the IOS, was due to AOPA supporting the SAA attempt at harmonising pilot medical requirements with that of the RA_Aus  and in line with the Class 3 driver license medical concept in the US...

However, as "K" succinctly points out this is the way Fort Fumble works, get the original minor contention lost in 45 pages of weasel words and the rest is history...
      
Coming back to the "K" comment..

"..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. etc.."

..& the possibility or sensibility of making a submission. The trouble is CASA again cynically use lack of interest/uptake of submissions as an indicator that most sectors of the industry don't have a problem with the current Draconian 19th rule-set for pilot medical (re-)certification.

However here's a thought, why don't the TAAAF collective put up a front man/women/expert panel that truly does know what they're talking about.

Choice No1. to front up such an industry panel IMO would have to be Rob Liddell...

Reference quote from ASRR submission 69:

..Recently there has been a move for reasons that remain unclear to change the Australian regulations to be totally compliant with the ICAO medical standards. This move is without any evidence that adopting more restrictive practices will have any effect on safety but rather will discriminate against some pilots.

I now have several pilots, one of whom has over 16,000 hours of operation, most of it flying night freight in command on Boeing 727 aircraft and who in mid-career are being advised that they do not meet the standard because of their colour vision and so cannot hold the required class of licence to retain their occupation.

I suspect that due to my previous role in CASA, I seem to attract many pilots who are totally confused and despondent at their medical certification by CASA aviation medicine. This involves conditions such as head injury, hearing, cardio vascular disease and prostate cancer, where the opinions of the pilots own specialist doctors are ignored and stringent and expensive repetitive imaging and blood testing is required if the individual wishes to retain their medical certificate. On a weekly basis I receive requests for assistance by pilots with conditions ranging from renal stones to early type 2 diabetes where the pilots own specialist’s advice is ignored by CASA and further expensive or repetitive testing in required to obtain a medical certificate.

The dangerous result of CASA’s draconian regulatory measures is that now many pilots tell CASA as little as possible about any medical problems in order to protect themselves from expensive and repetitive investigations or possible loss of certification . Most pilots are responsible people and they have no desire to be in charge of an aircraft if their risk of incapacity is unacceptable. When their DAME and their specialist believe they meet the risk target for certification without endless further testing demanded by CASA and the advice of their own specialist is ignored by the regulator then the pilot’s lose confidence in the regulator.

In medical certification CASA appears to have lost sight of the fact that all pilots self-certify themselves fit to fly every day they take control of an aircraft. The only day in the year when a doctor has any control over their fitness to fly is the day that they have their medical examination.

Dr Robert Liddell..

Speaking of self-certification of pilots in a parallel hemisphere, read & weep the following flight safety briefing courtesy of another NAA the FAA...  :

Say Ahh ...A Pilot’s Guide to Self-Assessing Risk

by Tom Hoffmann, FAA Safety Briefing

In the grand scheme of aviation risk management, it is easy to focus on the more tangible and black-and-white realities of flying. For example, will my airplane clear that 50-foot obstacle at the end of the runway with full fuel? Or, is my aircraft properly equipped for night flight in instrument meteorological conditions (IMC)? A few performance calculations, handbook references, and preflight checks can usually affirm a clear go, or no-go, decision.

Where it can get fuzzy and gray is assessing the level of risk that you, as the pilot, bring to the equation. Instead of relying on calculations and hard numbers to measure risk, it requires a more internal assessment of your readiness to fly, as well as being honest with yourself and your abilities. It boils down to three basic questions you should ask yourself before any flight: Am I healthy? Am I legal? And am I proficient? This article will explore how to assess and address pilot risk in each of these areas.

Am I Healthy?

I’m a visual person. The more of something I can visualize, the better I can understand it and tuck it away in my memory banks. I’m also a firm believer in the power of acronyms and mnemonics, those memory-jogging abbreviations that are engrained in aviators’ everyday operations. While some aviation acronyms don’t always give us a good sight picture of what we’re expected to do, the “I’MSAFE” acronym is one that I believe hits the proverbial nail on the head. It offers a simple and easy-to-remember way of checking your health before every flight. Let’s break it down.

Illness — Am I Sick?

While the average 9-to-5er may bristle at the thought of calling in sick from a simple case of the sniffles, that same act of fortitude can prove

problematic when deciding to fly. In addition to dealing with the distraction of pain and/or discomfort, even common maladies like a cold are often accompanied by a regiment of over-the-counter (OTC) medications that can wreak havoc on a pilot’s ability to stay focused and clear-headed during flight. We’ll cover more on meds next, but the bottom line here is quite simple: if you’re not well, don’t fly.

Let’s say you knew in advance that your engine was only going to give you 80 percent of its best possible performance on a given day. Would you still fly? It’s the same expectation you should have for yourself — nothing less than running on all cylinders should be acceptable.

The regulations have something to say about this as well. Title 14 Code of Federal Regulations (14 CFR) section 61.53 outlines operational prohibitions for pilots when they know, or have reason to know, of any medical condition (whether it’s a chronic disease, or a 24-hour bug) that would make them unable to meet the requirements for the medical certificate necessary for the pilot operation, or — for those not requiring medical certification — make them unable to operate an aircraft in a safe manner. Although vague in design, the rule prompts pilots to use good judgment and voluntarily ground themselves when they’re not feeling up to the task of aviating.

Medication — Have I Taken Any Prescription/OTC Meds?

As we noted earlier, medications can have a clear impact on a pilot’s ability to perform. While some effects are obvious, others can be deceivingly detrimental and may vary according to an individual’s tolerance level. Among the top offenders are sedating antihistamines, in particular, diphenhydramine (aka Benadryl). In addition to being an active ingredient in many cold medications, diphenhydramine is also used as an OTC sedative and is the sedating agent in most PM pain meds.

Evidence of rising antihistamine use (as well as other OTC medications) was at the forefront of a 2014 NTSB study, in which the percentage of pilots with potentially impairing drugs found in their system after an accident was greater than 20 percent in 2012. That was more than double the rate found at the outset of the study in 1990. The most common potentially impairing drug found in this study of nearly 6,600 aviation accidents: you guessed it, diphenhydramine.

A good way to ensure the medications you use don’t impair your flying is to first check the labels. Thankfully, the U.S. Food and Drug Administration (FDA) has strict labeling standards for all OTC medications so it’s easy to make comparisons and spot any potential side effects. The FDA also has a handy, online label checker you can use too (http://labels.fda.gov). For medications that have a warning about using caution when driving a vehicle, the FAA recommends using the “Rule of 5” — waiting at least five times the longest recommended interval between doses before flying.

Labels won’t always answer all your questions so contact your Aviation Medical Examiner if you’re unsure about a particular drug or would like to know more about safer alternatives. For more information, go to http://go.usa.gov/xkMvh.

Stress — Do I Have Any Job, Money, Family, or Health Issues?

We may not always think about it, but we’re under some level of stress with almost everything we do — whether on the job, with family, or even during what’s supposed to be a relaxing backcountry camping trip. Stress can affect people differently, so it’s really important for you to have a way of gauging a clear head and a sound state of mind before taking that flight.

A brief quarrel with your spouse, while seemingly insignificant, can easily cloud your thoughts and cause you to be distracted during flight. (Been there, done that, and learned a valuable lesson!) A more severe event, like the loss of a job, or a loved one, requires even more attention and self-examination to assess whether or not you’ve been able to properly come to terms with your situation and your emotions. It may not always be the easiest thing to do — especially if others are counting on you to fly them somewhere — but delaying or postponing a flight due to stress is always a good call.

There are several ways to help manage stress and prevent it from accumulating. For starters, try maintaining a regular exercise regime and make relaxation a priority in your daily schedule; have you actually ever tried yoga? It’s a great way to combine the two.

Sharpening your time management skills can also help reduce stress by meeting deadlines and keeping those honey-do lists from growing too large. Finally, an FAA study in 2000 on the impact of stress in aviation found that the top ranked stress coping strategy among participants was a stable relationship with a partner, so don’t be afraid to bend your spouse’s ear!

To learn more about how stress can affect your performance, watch this FAA video (see below or click here) and check out the article “Stress in Flight” in the Jan/Feb 2009 issue of FAA Safety Briefing.

Alcohol — Have I Had a Drink in the Last 8 Hours? 24 Hours?

For many, “throwing back a few” can be an effective way to relax and unwind after a tough day. But if flying is on your horizon, you’ll want to reconsider your actions. Like beer and wine, the two just don’t go together. The regulations (14 CFR section 91.17) say you may not operate an aircraft within eight hours of having consumed alcohol. Given the lingering effects alcohol can have on the human body, it’s best to pad that time and wait 24 hours before flying. And if you were really in a “celebratory mood,” keep in mind that the damaging effects of booze can last 48 to 72 hours following your last drink in the form of a hangover and well after your body has eliminated all alcohol. Add in night conditions or bad weather to any of these scenarios, and the negative effects on flying can be magnified greatly.

For more information, have a look at the FAA’s brochure “Alcohol and Flying — A Deadly Combination” at http://go.usa.gov/xkFJd.

Fatigue — Am I Properly Rested?

The impact of fatigue in the aviation industry is an all-too-common phenomenon.

Although it’s rarely the singular cause of a fatal accident, the term pilot fatigue is riddled throughout NTSB probable cause reports in all segments of aviation. It’s more commonly the ugly precursor to many poor last decisions (or indecisions). As to why a simple lack of rest is not mitigated more often, some might say it’s because it can be easily remedied with coffee or an energy drink, or that it’s just something they feel is a nuisance they can power through. Both are false narratives that gravely underestimate fatigue’s disastrous potential.

In order to manage fatigue, it’s important to listen to what your body is telling you. Do you feel yourself uncontrollably yawning? Are your eyes bloodshot and bleary? Are you feeling sluggish or slow to react? Keep in mind that fatigue isn’t limited to just these more obvious signs. It’s often a more insidious problem fueled by a creeping accumulation of inadequate rest (e.g., long nights at the office, a new baby in the house, etc.) Fatigue can also be caused by physical exertion. Those first few great-weather flying days we look forward to in the spring are usually accompanied by a mountain of strenuous yard work. And while you may not typically be exposed to the long duty days and time zone shifts that a commercial pilot might have, you do have to deal with the stress of a single-pilot workload with no one to catch your mistakes.

Regardless of what causes fatigue, the important thing to know is how it can affect your performance in the cockpit and how to prevent it in the first place. The antidote here is simple: get more sleep. You may have heard it a thousand times before, but strive for eight hours of sleep per night. Easier said than done, I know. But one thing that I find helpful in measuring the quantity and quality of sleep, is wearing a wristwatch activity tracker to bed. Many are able to provide a full report of your sleep cycles, including periods of restlessness and time awake. Arming yourself with this kind of data can go a long way to more accurately assessing your fatigue level before a flight.

For more tips on combatting fatigue, see the FAA brochure at http://go.usa.gov/xkMwc.

Eating — Have I Had Enough to Eat or Drink?

Now, I know many versions of I’MSAFE use Emotion for “E,” but I think that is something we covered adequately under our discussion about Stress. Instead, we’ll use “E” to cover a subject more near and dear to my heart: eating. Eating healthy, well-balanced meals is the best way to achieve your body’s peak performance levels. Unfortunately, not every airport has a Joe’s Diner conveniently nearby. In fact, GA pilots can often go several hours past their normal mealtimes without eating thanks to weather delays or unexpected diversions. It’s always a good idea to pack a lunch just in case, or at the very least, a few healthy snacks that will tide you over. The same goes for hydrating. Drink whenever you get the chance. Dehydration can cause dizziness, confusion, and weakness and can seriously impair your ability to fly. I never fly without at least one bottle of water in my flight bag, and I always hit the water fountain anytime I see one.

Am I Legal/Proficient?

Now that we’ve reviewed some of the physical and mental hurdles an airman can face, it’s time to cover some of the legal and experiential aspects of completing a pilot risk assessment. Let’s start by addressing the fact that being legal or current is by no means an indication of being proficient when it comes to flying. The FAA sets clear standards when it comes to what’s required in your logbook before you can fly as pilot in command, within a certain time period. For a complete list of these requirements, see 14 CFR section 61.57 (http://go.usa.gov/xkM7t) as well as 14 CFR section 61.56 (http://go.usa.gov/xkMHp) for flight review requirements. However, just meeting these requirements alone is unlikely to make you a fully competent and proficient pilot. That takes additional effort.

A good start towards fine-tuning proficiency is to use a flight review as an opportunity to go outside your comfort zone. Weak on crosswind landings? Been a while since you did a short field grass takeoff or simulated an onboard fire? Then make these priority items to work on with an instructor and/or during a flight review. A review that just substantiates all the things you already have a good grasp on is not exactly time (or money) well spent.

The key to proficiency is practice. And then more practice.

There’s lots of resources, and the FAA can help you become proficient. If you haven’t already signed up to be a part of the FAA Safety Team’s WINGS Pilot Proficiency Program, I highly encourage you to do so. The program is specifically designed to help pilots become more proficient by attending safety seminars, completing training courses, and performing various flight activities. Go to FAASafety.gov for complete details.

It’s Personal

Flying is an inherently risky business. However, learning how to identify and mitigate the potential risks that a pilot brings to a flight is a significant step towards improving your odds of a safe outcome. I hope the information presented here can give you a better understanding of what to look out for and what to question before each and every flight. It can be difficult, as assessing pilot risk is a very personal process and one that requires intimate awareness of your limitations. You have to be upfront with yourself mentally, physically, and experientially. Here, honesty is not the best policy — it’s the only policy.

Tom Hoffmann is the managing editor of FAA Safety Briefing. He is a commercial pilot and holds an A&P certificate.

Meanwhile in Dunceunda land AIOS reaches epidemic proportions - "nothing to see here move on.." 


MTF...P2