[Peetwo]

CASA promises self-declared medical reform?? - Let's do the timewarp again!!  

Via the latest Su_Spence (bollocks) CASA Briefing: The CASA Briefing - November 2021

Work starts on new self-declared medical

Work is underway on the development of a new self-declared medical certificate for pilots.

Details on how the new medical certificate would operate are being examined by a joint CASA and aviation community technical working group.

Once the technical working group has completed its review CASA will put out a detailed proposal for broad consultation. This is likely to occur in the first part of 2022.

The new medical certificate is likely to reflect the self-declaration system used by Recreational Aviation Australia for its members. The technical working group is also broadly reviewing the current medical regulations and changes made to the requirements in 2018.

It is looking at a simplification of the overall approach to medical certification, with the intention of provided greater flexibility and less onerous processes.

Find out more about the medical regulations. 

This has sparked much comment -   

Via the AP email chains:

..With the greatest of respect, nobody trusts CASA consultation to take genuine notice of advocates of reform, but always ignores proposals that are not in accord with its pre-conceived ideas, as always, dressed up in a mantle of “safety”.

And I can say, based on long experience, CASA can always be relied upon to drum up “submissions” from vested interests who agree with CASA and oppose reform.

Sometimes (as John Sharp did as Minister, followed by Mark Vaile) it is necessary to implement a policy in the face of concerted, even ferocious, opposition from “the usual suspects”.

 In the period 1996-1999, we (the Minister and his Program Advisory Panel, PAP) had absolutely no interest or intent in heeding the forces, particularly in CASA, arrayed against regulatory reform

Here, your Minister’s policy should be: “Australia, having once led the world in driver’s license medical standards for ultralight aircraft, after approaching half a century, should extend that reform to all private flying”.

After all, the FAA drew on the Australian experience with the Australian Ultralight Federation (AUF, now Recreational Aviation Australia) in its first attempt to introduce a “driver’s license” medical. This proposal failed, not on “safety” grounds, but as a result of US aviation medical examiner associations lobbying DoT and “on the hill”.

The second time around, the lobbying effort of the likes of AOPA US and EAA defeated the doctor’s lobby.

Opposition to reform all about vested interests, dressed up as “safety”.

We should lead, not wind up with some “negotiated” result, which is a bit of what the US has done, a bit of what the UK has done and a bit of what we do here, already.

It should be just the national standard for a private motor car, with no fiddling by CASA,  and apply to all aircraft under 5700 kg, with no artificial limits. There is absolutely nothing in the statistics to justify multi-engine, IFR or airspace limitations (GFA pilots are not limited to Class G, are they?).

You may or may not be aware, but the FAA has a vast library of data on pilot medicals (mostly available on-line) and operational risk (I do not like the word “safety”, it is emotional, and without dimension) outcomes.

The bottom line: there is little to no correlation between air-safety outcomes and the medical certification status of the pilot. After all, pilots self-certify every time they go flying.

Time for action and concerted political direction, and your Minister is just the person to do it!...

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...CASA making rules that determine CASA’s own functions and powers under those rules is fundamentally flawed regulatory model.   It’s a process affected by emotion, cognitive bias and vested interests, heavily disguised under a cloak of safety sophistry...

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...Referring to the link for the medical Technical Working Group in your first email the following is the list of that group:-

• Peter Antonenko  (I believe is a psychologist)
  
• Dr Priti Bhatt
  
• Dr Ian Hosegood
  
• Dr Anthony McCarthy
  
• Mr John Raby
  
• Dr Jeremy Robertson
  
• Dr Sara Souter
  

This Group was initiated, according to the website link in December 2020, with view to:-

• • provide industry sector insight and expertise for the analysis and review of Civil Aviation Safety Regulation (CASR) Part 67
  
• • evaluate the discussion paper on Part 67 to ensure it will achieve the outcomes of the review and reflect current practices in aviation medicine.
  

(To be passed on to the ASAP group.) 
Industry insight?  With a preponderance of those clearly with vested interests the notion of “industry sector insight” is preposterous, unless it speaks of the medical industry. 

I agree fully with XXXX's (the above) assessment. There is no need for more consultations when the overwhelming evidence from some thirty years local experience of the self declared driver licence standard, and the overseas examples, are proof that this reform should not wait. The TWG has had nearly twelve months, asking for yet more time is not on. 

The existing Basic Class 2 could and should be modified immediately to car driver standard even if keeping some of its other pointless and undesirable conditions, like no IFR, in place for the time being. 

This would be hugely popular with practically the whole of the GA community and reflect very favourably on the Minister, who should back this reform now.

There’s no reason for any delay which will be seen as delay for the sake of putting off a decision which can then be lost in the heat of an election and the possibility of a change in government. 

Most of the General Aviation community will see delay as just another excuse for no action. 

We need to be frank because the stakes are higher than ever as the industry is going downhill.  We are losing aviation businesses, skills, manufacturing, flying schools and charter operators. Aircraft are being exported and maintenance personnel are dropping out with no replacements. To make matters worse key GA airports are being lost to non aviation uses. These matters need attention and correction urgently. 

What’s happening is bad for Australia...

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...CASA is asking us to prepare for the consultation about the medical reform. This is a total nonsense, most of what is needed for reform was accepted by government out of its 2014 Forsyth report but never implemented, including the recommendation to delete the ASIC. There is no safety case against the proposed medical case, there are many years of studies and experience, including many years of RAAUS which is conclusive to make this reform immediately. The only opponents will be those with vested interests, a handful of medicos might object along with AVMED and perhaps, but hopefully not, the management of RAAUS. The latter because it will assuredly lose some members. 

Timing, well guess what? Election frenzy will provide CASA with the cover and comfort to put off the evil day of reform. Why? Simply because one reform might well lead to others which will lead to loss of power, influence and money. GI (Government Industries) will be upset. It’s still war and Can’tberra’s proposed minor strategic retreat will not be welcomed in the Public Sector, that which used to be known as the Public Service...

MTF...P2 

ps Referring to the Pip piffle (caution vomit bag may be required -   ), I note that on the one hand PS indicates that CASA are there to assist...

..I want to thank everyone who has been working through the transition steps and reassure organisations that may be behind their schedule that we will assist you to finish the necessary tasks...

..However in the next breath PS indicates that CASA have effectively knocked off for 2021...

..Finally, as this will be the last CASA Briefing for 2021, I want to thank everyone for their ongoing commitment to safety during what has been a stressful and challenging year. Despite the COVID disruptions, you have continued to put safety first and you should be proud of that achievement..

...which kind of makes it hard for small aviation businesses, operators etc to get some form of CASA assist till at least the 1st week of 2022 - 

Ah yes the fantasy world (underneath the Can'tberra bubble) has once more been inflicted with the AIOS disease.. (Ref: AIOS - & the 21st Century??)