[Peetwo]

PMO at Estimates; & Class 5 consult opens??

Via APH:  Hansard out, see - HERE - or PDF Version - HERE:

CHAIR: Welcome back, everyone! I welcome officers from CASA. I won't ask for opening statements; if you have one you can table it. Senator Fawcett, who is 60 today, has the call. Happy birthday—there's no better way to spend it than at Senate estimates!

Senator FAWCETT: We won't be asking for your age, either, Ms Spence, you'll be glad to hear!

Ms Spence : Happy birthday, Senator!

Senator FAWCETT: Thank you. In fact, this does actually take me back a little bit. I'm assuming that in preparation for your role you read through the Hansard transcripts of many years and that you're aware that between 2014 and 2017 your predecessors and I had many discussions about colour-vision-deficient pilots?

Ms Spence : Yes.

CHAIR: I'm aware of it!

Senator FAWCETT: Eventually, as you'd be aware, in February 2020 your predecessor, Mr Carmody, announced something to the world, which I will read from the statement that he sent out:

Research in recent years has shown relying on diagnostic tests alone may be unnecessarily limiting when considering the impact of colour vision deficiency on aviation safety. Advances in technology, operating techniques and human factors training can now mitigate many of the safety risks of colour vision deficiency. Technology to assist pilots has developed significantly and the impact of colour vision deficiency on aviation safety should take these changes into account.

At the end of his statement he said:

CASA has carefully examined all relevant safety issues and believes this new approach—

Which is the same as in New Zealand and for the FAA—

offers a practical alternative assessment for colour vision deficient pilots. We have listened to the views of pilots and made judgements based on research and evidence.

That is a fantastic outcome. They changed the lot of pilots, which had been thrown into confusion by a new senior medical officer within CASA who didn't like Australia's position, which was to allow pilots to do an operational test. Despite losing AAT cases et cetera and despite reviews of evidence that finally proved we should do this operational test, like the New Zealanders and the FAA, it's all happening again. Could you explain why CASA is spending half a million dollars on a review? What is the evidence base to justify this change of position? What incidents have occurred? What evidence has led to the decision to spend half a million dollars of taxpayers' money and overturn what has been in the CASRs for some years now, to the detriment of a group of individuals in our aviation community?

Ms Spence : I wouldn't describe it in the same way that you have, in terms of someone coming in and not supporting the previous position. I will ask our principal medical officer if she wouldn't mind joining us at the table, but I think the first thing really is that it's a question about what's consistent with the standards versus what's okay from an operational perspective. I don't think we've changed our position that there aren't ways of overcoming the issue of colour blindness from an operational perspective. I think there is a different question about whether that is consistent with the standards, and that's a harder question to answer, so I might pass to Dr Manderson to provide a bit more detail.

Senator FAWCETT: Dr Manderson, welcome.

Dr Manderson : Thank you very much. Regarding the colour vision assessment, what we found a couple years ago, and going back a bit before that, was that there was a lot of difficulty and confusion in how that colour vision assessment was being applied by the flight instructors who were assessing the pilots with colour vision deficiencies and in how the pilots themselves knew what they would be expected to demonstrate in their flights. We had some difficulties where the forms and the flights were not being conducted to a consistent standard across the board. Someone might have one kind of flight or assessment with one assessor and a completely different one with somebody else. With that degree of confusion and lack of clarity, we realised that, having established that an operational flight based assessment was really important, how we did that was where there was a big gap in what we were doing and why we were doing it, and it was that gap that led to all of that confusion and some difficulties in what standard was being met by whom and when. That's why we saw that gap in the how that hadn't been filled by any of those other organisations or jurisdictions.

We've consulted really quite extensively. Even last Friday we had an international meeting here in Canberra with our colleagues from FAA, New Zealand and ICAO. The United States military have come across as well to share their experiences with us and how we do it now. There really is a global consensus that the approach we've taken is world leading and will make a big difference to the consistent application of a good standard that our instructors and pilots can rely on to make a safe decision.

Senator FAWCETT: Sure. I don't have a problem with standardisation. I think that's excellent. I do note my understanding is that New Zealand did have a course to standardise their examiners, which we didn't adopt, even though we adopted their operational test. Am I correct in my understanding of that?

Dr Manderson : I'm not familiar with the detail of the way the New Zealand team initially applied theirs, but they're certainly very excited about looking at what we're doing and learning from what we're doing. That's because we have gone to the next level. There's much more depth and it's much more comprehensive. The CAA New Zealand chief medical officer is very interested in learning from what we've done.

Senator FAWCETT: My understanding is that, because we didn't have any standardisation initially, the initial batch of flight examiners went to New Zealand to get their training there. In fact, we encouraged or enabled it, saying that, if pilots wished to bear the cost to go to New Zealand to be tested by the New Zealanders, we would accept that as a valid system that did have standardisation and did the test. I don't have a problem with standardisation. What I have a problem with is this. When I look at your website, we have gone back to the days of saying: if you pass the operational test, we are still going to limit you in terms of what you can do as a pilot; for example, fly as or with a copilot. Given everything Mr Carmody said, everything the AAT found and cases back in ancient history—30 years ago now—when Australia became a world leader, what evidence justifies that imposition of a restriction on someone who passes the operational test?

Dr Manderson: The evidence is based around the demonstration of being able to do the elements of the flying task that have been assessed by this international group of expert pilots and flying instructors as being the time-critical, safety-critical colour-vision-dependent tasks of the flying task. That was a gap that was there in the work that was done leading up to the New Zealand assessment that we've now been able to produce. It is not about the medical diagnosis; it is what it is with the diagnosis of colour vision deficiency. The evidence is now about being able to know exactly how that medical status affects a person's fitness to fly and fly safely. That's exactly the same as we do with people with kidney disease, hearing deficiency or heart disease. They don't meet the standard, but now we can—in very great detail and very safely—effectively and consistently assess whether or not the way they meet the standard presents a hazard to safe air navigation. That's the way we do all of our medical assessments.

Senator FAWCETT: In theory that is fine. What you're describing is that your test is now focusing on some discrete task elements that you believe are important. But what your website says is that even if someone passes that test—they've now jumped through these additional hoops of specific tasks—you're still going to put limitations on what they can exercise as captain in command of an aircraft. What is the evidence to justify those limitations? That is my question.

Mr Marcelja : Could I jump in? The website and some of that information sits in my area. I think what you're describing, if that is correct, is not our policy. Our policy is that there are various conditions that we can put on medical certificates, depending on how you go in the test, but if you pass the test and can demonstrate that you're operationally safe there is no condition of a copilot. What Dr Manderson is saying, though, is that, because you have not met a medical standard that's internationally accepted but have proven you are safe, we will grant you a medical certificate. We can't say that you've met a standard but we can say you're safe to fly, and those conditions will be applied depending on the way you've gone. If that's on our website, I'll take that up, because that's not the policy.

Senator FAWCETT: I have two points. I think it was amply proven almost a decade ago, and two decades before that, as we dug into the history, that those standards emerged from maritime standards that were applied in the United Kingdom in the days of Sopwith Camels and things in World War 1, and the reason we no longer require them is that we have secondary means of communication. We've demonstrated through a whole range of flight profiles and cockpit modifications, particularly with the advent of EFIS screens et cetera, that many of the old colour hierarchies around warnings et cetera are no longer relevant. They're not required to do the task. Even the red and green lights are not required. Pilots wear Bluetooth headsets.

I come back to the fact that your website—at this stage, this is what industry is seeing—states that a pilot who passes the test will have these restrictions until they have 100 hours of flight at night, the ATPL standard, or 75 hours of instrument time. I've done just a very quick bit of research on the current costing of something like a Cessna 172RG, which is the kind of aircraft for night VFR or instrument flying, the costs between Moorabbin, Dubbo, Adelaide and Sunshine Coast vary from about $250 to $355, excluding GST. We're putting a burden on pilots who want to enter the industry of $30,000 to $40,000, and I'm not aware of any evidence that would justify those restrictions if they have passed the operational test.

Ms Spence : I think what we're saying is that we think our website's wrong. We will go back to review it, because that doesn't sound like our policy. As Dr Manderson said, we're working—and we're working internationally—looking at how we manage this issue. But the whole point, in the simplest terms, was that if you pass the test then you've got a permission to fly. Those sorts of conditions you've just described should not be applying. If you can bear with us, we'll review the website, because what you've read out just doesn't sound right.

Senator FAWCETT: I'll have a look tomorrow afternoon. I'll be very pleased to see that gone. This is my last question. My understanding is that, in accordance with the regulation—which I could look up; I've got it written here somewhere, but I'm sure you know what it is—CASA was still advising pilots to do the operational test, which they did at some cost, and then AvMed were denying them an aircrew medical because CASA had changed its mind, even though the regulation still said it was possible and even though pilots have been directed to that. Some pilots now, over periods in excess of 12 months, have forked out thousands of dollars to take a flight test and have had their application refused. What is the situation for people who have previously done it, before this change in approach? What is the situation for those who did it in the intervening period, when the regulation said they would be approved? They committed to a flight test on that basis and have now been told they're not able to fly. What is CASA going to do to enable those people to move ahead with their lives, and can you guarantee there's going to be no retrospective action against the many pilots who did the original operational flight test as announced in 2020 and have been flying—single-pilot, in RFDS type operations, and multi-pilot, in RPT operations, both domestically and overseas—without incident since they got their medicals? Can you guarantee that they will be able to continue to exercise the qualifications that they have earned in accordance with the regulation, or will there be any retrospective action that CASA is looking to impose upon them?

Ms Spence : Can I just jump in first: if you've got people who've come to you saying that they haven't been approved, I would really encourage you to refer them to me, Mr Marcelja or Dr Manderson, because that doesn't sound like that's consistent with our policy. I would have thought, with medicals, that they're things that come up every two years or whatever, depending on where you are, and so there would be no retrospective requirements. If matters change over time then get your medical renewed, but there's certainly not an intention to have a retrospective element to all of this. Again, for anyone who's spoken to you and said that they've been refused on the grounds that you've described, please encourage them to talk to us, because that just doesn't sound right.

Senator FAWCETT: This is my last question, Chair, before you wind me up. Industry had been told that the new test and all of its conditions would be released in September this year. We're now approaching the end of October. Where are we at, and when will these people have some certainty about their future or current careers?

Mr Marcelja : We have slowed that down just a little bit because we're working through some of those implementation issues that you just mentioned. As Ms Spence said, we don't expect people to automatically have to prove things themselves, but, where we've discovered that a test maybe has some uncertainty around it, we might ask somebody to do that test again. In that circumstance, we would fund that. These are the policies that we haven't yet settled, which is why you haven't seen a policy come out. They haven't been finalised, but they're very close. As Ms Spence said, we'd very happily follow up any individual case where someone's been disadvantaged, because our understanding was that the existing scheme was in place while we were settling the new one.

Ms Spence : As far as my understanding goes, no-one has been refused—

Dr Manderson : There have been no refusals or cancellations for colour vision deficiency.

Senator FAWCETT: Okay. I'll go back to the email trail that I have been given and see if I can see whether there's substance to what was reflected in that email. If that's the case, I will come to you, Ms Spence, as the best person to—

Ms Spence : That'd be great. Thanks, Senator.

Some comments, via Youtube:

@SChoice93
19 hours ago

I completed and passed an OCVA in January 2022, at direction of CASA. I was then subsequently refused a medical in April 2022. I have been battling and advocating ever since. This completely disproves Dr Mandersons committed statement of, "no refusals have been made"

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@forreal76
3 days ago (edited)

the lights are in fixed positions, what does being color blind have to do with it? Fighter pilot need color vision...but domestic pilots???? what the hell. If the left light is on, all good, if the right light is on it is bad....derrrrr

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CHAIR: Senator Roberts.

Senator ROBERTS: Thank you all for appearing tonight. Dr Manderson, the last two times I've requested your attendance at Senate estimates, you've been otherwise engaged. Does your role at CASA have your full attention?

Ms Spence : Can I just intervene briefly on that question? The first time, I think, Dr Manderson was traveling overseas for CASA work. The second time, we only got notice, I think, 24 hours before the actual estimates hearing. So to suggest that Dr Manderson wasn't available and didn't have full—

Senator ROBERTS: That's true. Does your role at CASA have your full attention?

Dr Manderson : Yes, it does.

Senator ROBERTS: How many hours per week do you complete work specifically in relation to your role as principal medical officer at CASA?

Dr Manderson : I don't keep a logbook, but I would say in excess of 40 to 50 hours per week.

Senator ROBERTS: Are you full time with CASA?

Dr Man derson : Yes.

Senator ROBERTS: What other roles and positions do you hold on boards or in businesses?

Dr Manderson : Any roles I have at present have all been listed and notified to CASA on my required reporting.

Senator ROBERTS: Do you have any personal businesses or clinics?

Mr Marcelja : We went through this a couple of hearings ago.

Senator ROBERTS: I want to hear from Dr Manderson.

Ms Spence : There is nothing further that we would add from what was previously said.

Senator ROBERTS: I want to hear from Dr Manderson.

Ms Spence : From my perspective, Dr Manderson has done the same thing as all CASA staff do, which is she has provided advice on any potential conflict of interest, mitigation arrangements have been agreed, and to my mind—

Senator ROBERTS: Ms Spence, the senators ask the questions. I have a question for Dr Manderson. I want her to answer.

Ms Spence : As I said, I am happy to turn to Dr Manderson—

Senator ROBERTS: Thank you.

Ms Spence : but I do feel that there has been advice provided to this committee previously.

Senator ROBERTS: Dr Manderson?

Dr Manderson : Could you please repeat the question?

Senator ROBERTS: What other roles and positions do you hold on boards or in businesses?

Dr Manderson : I have declared on my declarations that I have a role on the Australasian Society of Aerospace Medicine board and I have a role on the Australasian College of Aerospace Medicine board. Both of those have been declared to CASA. Also of course my role at CASA is declared to those boards, and the potential for conflicts are managed appropriately there.

Senator ROBERTS: Do you have any clinics that you operate?

Dr Manderson : I have businesses that support doctors in their practices, but I don't—

Senator ROBERTS: Could you tell me more about them please?

Dr Manderson : Sure.

Senator ROBERTS: Are they declared?

Dr Manderson : Yes, they are declared. The structure of the way many general practice services work in Australia is that there is a company that is set up that employs the nurses and the receptionists and pays that for the electricity and pays for the internet connections. The doctors that work in those clinics see their patients in those clinics, and they are supported by nurses and receptionists, the internet, the computers and whatnot. I have a service company that provides nurses and receptionists so that other doctors can look after their patients.

Senator ROBERTS: Do you work in those clinics?

Dr Manderson : No.

Senator ROBERTS: Have you ever received benefits or payments directly or indirectly for the administration of COVID-19 vaccines or injections?

Dr Manderson : I was operating a GP respiratory clinic under the Commonwealth GP respiratory clinic program. Those clinics were funded by the government to deliver COVID vaccinations and to do assessment and testing for people who may have COVID.

Senator ROBERTS: Was that while you are doing your job at CASA?

Dr Manderson : Partly.

Senator ROBERTS: Can you tell me more? What do you mean by 'partly'?

Dr Manderson : I established the GP respiratory clinic in Sanctuary Point in early 2020, and I started with CASA in July 2021. The respiratory clinic was closed in September 2022.

Senator ROBERTS: What is the definition of 'subclinical'?

Dr Manderson : Subclinical is a term that's usually used to describe the fact that someone has the presence of an illness or a symptom or syndrome that is not overtly obvious to them or to other people. An example might be subclinical hypothyroidism, where we do a blood test and find that your thyroid level is low. It might be causing some non-specific or vague symptoms, but it isn't really obvious to everybody. That would be subclinical hypothyroidism.

Senator ROBERTS: That was excellent, thank you. We had evidence at the last estimates that the buck stops with CASA with regard to whether a pilot is fit to fly aviation safety and medical certification that would support aviation safety, and no other department has responsibility within that remit. Do you accept that, Dr Manderson?

Dr Manderson : Only to suggest that the buck stops with the individual pilots to make their own self-assessment of their wellbeing each time they go to the aircraft, and we encourage them to do that every time.

Senator ROBERTS: Apart from that, do you agree?

Dr Manderson : Yes.

Senator ROBERTS: Can you confirm neither you nor CASA have evaluated the aeromedical implications of the pilots taking the new mRNA technology injections at low atmospheric conditions?

Dr Manderson : No, we haven't.

Senator ROBERTS: Do you consider that you have any additional responsibility to evaluate in an aeromedical context or at least surveil a new medical technology that only has provisional approval?

Dr Manderson : No, that is not the responsibility of the safety authority.

Senator ROBERTS: So you don't think you have any additional responsibility, yet you agree the buck stops with CASA on aeromedical safety?

Dr Manderson : If somebody is unwell enough that they can't fly and has a medication that means that they can't fly, then we would look at that. But we don't decide whether or not a medication is safe.

Senator ROBERTS: How does a drug make it to 'prohibited or restricted use' for pilots?

Mr Marcelja : Senator—

Senator ROBERTS: Dr Manderson.

Dr Manderson : We look at the work that is done by the authorities that are responsible for assessing medication safety and approvals in Australia, and we have a look at all the literature and the evidence that's available, based on the assessments by those expert authorities, to see whether or not there are any aeromedical implications for that. For example, a new antidepressant might change the way someone thinks or feels, or it might be sedating. So we would look at the degree of sedation that that antidepressant has been shown to have and decide whether or not a person ought to fly while taking that antidepressant.

Senator ROBERTS: So who completed this evaluation for the COVID-19 products—injections specifically, Dr Manderson?

Dr Manderson : AVMED looks at all medications that are available to pilots to see whether or not they're a concern. They were assessed by the aviation medicine section in the same way we assess any medication that's available to pilots and air traffic controllers.

Senator ROBER TS: The answer we've been given before is 'we've relied on the experts', who weren't named.

Ms Spence : Senator, I think what Dr Manderson is saying is that we don't do the actual assessment of the medication, but, knowing what we know about the medication, we assess whether it will have a negative impact on a pilot.

Dr Manderson : That's correct.

Ms Spence : So we do not go into the detail of—

Senator ROBERTS: Okay, let's continue, then. I want to respect the committee's time. I've got a few questions to go through. In answer to SQ23-003972, CASA states it has no role in the black triangle medicine scheme. The TGA says the black triangle 'means that the medicine is new or is being used in a new way'. It says:

We encourage people to report any adverse events for these new medicines to help us build a medicine's safety profile over time.

So CASA does have a responsibility to report any adverse events if it comes across them.

Dr Manderson : The black triangle is designed for the people who prescribe, dispense, administer or take medications, and that's not part of the role of aviation medicine centre at CASA.

Senator ROBERTS: In a February 2022 Zoom meeting with Virgin pilots, Dr Manderson, you stated that the provisionally approved mRNA vaccines or injections can cause myocarditis and pericarditis, but that you'd rather pilots got these conditions from the vaccine rather than COVID, which you claimed to be a higher risk. What evidence do you have to substantiate that claim that the risk of myocarditis is higher from COVID infection?

Dr Manderson : There's extensive medical literature and evidence in peer reviewed—

Senator ROBERTS: Can you give me the references, please—titles, authors, publications.

Dr Manderson : Not immediately, but—

Ms Spence : We can take that on notice.

Senator ROBERTS: On notice. Thank you.

CHAIR: Senator Roberts, have you got many more? I might cut you off and go around, and then come back to you if you've got more.

Senator ROBERTS: Just on this thread, I've got a couple more.

CHAIR: Just on that thread. Then I'll go to Senator McDonald.

Senator ROBERTS: Can I point you to a study entitled 'COVID-19—Associated cardiac pathology at the postmortem evaluation: a collaborative systematic review', published in the Clinical Microbiology and Infection journal, 23 March 2022, which concludes that there was no increased myocarditis as a result of COVID infection. Can you please take on notice to provide what evidence or studies you have that refute a systematic review like that?

Dr Manderson : Sure.

Senator ROBERTS: Thank you. In relation to question on notice SQ23-003393, does CASA still not capture information in your medical records system in a way that allows conditions like myocarditis, Guillain-Barre syndrome and other COVID adverse events to be accurately reported?

Dr Manderson : We do capture that information in our medical records system. We ask every pilot and air traffic controller that's applying for a medical certificate to tell us if they have any symptoms or signs or diagnoses of any of those conditions, and they can write that in. We also ask their doctor, their medical examiner, to write in any details about any of the diseases or diagnoses or symptoms that that pilot or air traffic controller may have.

Senator ROBERTS: So there are no incidences? How exactly do know that if you can't give me a report on how many cases of myocarditis or any other recognised side effect you've recorded for each year? How can you say there have been no pilots with adverse events?

Mr Marcelja : Senator, the way we answered that question when you asked the question was that we said that—

Senator ROBERTS: I'm after Dr Manderson's answer.

Mr Marcelja : No, the medical records system is my responsibility, Senator.

Senator ROBERTS: My question is still to Dr Manderson. She's overseeing the whole of CASA—

Ms Spence : Sorry, Senator, my view would be that the most appropriate—

Senator ROBERTS: I didn't ask for your view, Ms Spence. I asked for Dr Manderson's view. I want to know if she's aware—

Ms Spence : But it is not Dr Manderson's responsibility. It is Mr Marcelja's responsibility, and he is trying to answer the question that you asked.

Senator ROBERTS: She is responsible for CASA's safety and aeromedical—

Ms Spence : Mr Marcelja is responsible for—

Senator ROBERTS: I want to know her relationship with that. I am asking her if she knows—

Ms Spence : That is a different question.

Senator ROBERTS: That's correct.

Mr Marcelja : Dr Manderson sets medical policy. The medical record system doesn't capture—

Senator ROBERTS: How do you know that?

Mr Marcelja : Because it does not capture the information about whether there was an adverse event or whether there was simply a suspicion of an event.

Senator ROBERTS: It doesn't capture that?

Mr Marcelja : It captures comments that may have been entered into—

Senator ROBERTS: Is it capturing it or not?

Mr Marcelja : It is not capturing it in the way that you are asking about, and that is what we were providing to you on notice.

Senator ROBERTS: How does it capture?

Mr Marcelja : Through text comments which might refer to symptoms, diagnoses or a comment that a patient made. So it does not capture the information in the way you have asked for, and that was the response that we gave to your question last time.

Senator ROBERTS: Dr Manderson, does CASA still maintain that no pilot has been grounded or had a medical restriction placed on them because of a COVID-19 vaccination injury?

Dr Manderson : Yes.

Senator McDONALD: Dr Manderson, I was in the Northern Territory the other day and met with a pilot who lives in Mataranka, 400 kilometres south of Darwin, who requires a medical every two years to maintain his licence. Until 2019 he was able to visit a designated aviation medical examiner in Katherine. Now of the four DAMEs registered in the Northern Territory on the CASA website only one conducts medicals just once a month at Alice Springs, which, as you know, is 1,100 kilometres from where this particular pilot lives. So we have a DAMEs shortage, I assume. Do you know what the problem is? Are fewer GPs registering to carry out this work?

Dr Manderson : I would suggest that it is not so much a DAME shortage but a distribution issue, which is a symptom of the health workforce issues in rural and regional Australia across the board. That is one of the reasons why we have looked at training more DAMEs, particularly focusing on DAMEs who live in rural and regional areas. At our Brisbane DAMEs course earlier this year, we did have a doctor from Alice Springs. She is happily now going to be a DAME there.

Senator McDONALD: Nobody north? Nobody in Katherine or Darwin?

Dr Manderson : Unfortunately we can't compel GPs to take up this particular role. We just invite them to and encourage them and provide that training to them if they choose to.

Senator McDONALD: I appreciate you can't force them to, but it is problematic for the closest one to be 1,100 kilometres away. Do you have a plan for what you might be proposing to do going forward?

Dr Manderson : I would say that part of the plan is to look at ways to get medical certification without needing to see a DAME. Some of the new programs and systems are looking into a self-declared medical certificate where the pilot can assess themselves in collaboration with their treating doctors and a GP issued medical certificate in future as well. This would mean less need to see a DAME for all those pilots. Hopefully that will make—

Senator McDONALD: That is very exciting. I can hear cheering all over the country.

Dr Manderson : Watch this space.

Hmm...'watch this space'?? -

Well today CASA AVMAD released their (intended DRAFT) version of the self-declared medical; IE Class 5 for consult:

Class 5 medical self-declaration - (PP 2302FS)

Overview

We are seeking your feedback on a new Class 5 medical self-declaration policy. It will allow private pilots to self-assess and self-declare without requiring a medical assessment if they meet fitness requirements and operate in accordance with specified operational limitations.

The policy aims to improve accessibility to a streamlined medical self-certification pathway for the general aviation and recreational aviation community.

To support the implementation of the new Class 5 medical self-declaration, there will be comprehensive guidance material for applicants, certificate-holders and healthcare practitioners.

We are proposing to enact the policy through an exemption instrument to the Civil Aviation Safety Regulations 1998 (CASRs). This will enable industry to access the new Class 5 medical self-declaration as soon as practical.

This proposal has been developed with input from the aviation community, including the aviation medicine technical working group.

This is also one of the initiatives in our General Aviation Workplan for simplifying health arrangements.

Your feedback will inform the finalisation of the proposed policy, supporting documents, and the regulatory review process.

MTF...P2