[Peetwo]

Update to CASA medical certification DP -  


Reference:

Hook; line; sinker; & a parallel universe -  

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’

   

Today it was brought to my attention that at least one of the industry Alphabet advocate groups/associations has made a submission to the CASA Avmed Medical Certification DP:
AAAA Submission CASA Medical Certification Standards Discussion Paper

Introduction

AAAA recommends a significant overhaul of the aviation medical system in Australia that will deliver a similar level of safety outcomes, but which will significantly boost the efficiency of the avmed system, reduce costs, anxiety and delay and greatly improve the transparency of the process and the use of the best expert opinion in resolving more complex cases.

There are five core areas for reform:

•Improved alignment and simplification of aviation medical certification classes/requirements against the classification of operations, and consequently relevant to risk and consequence.
•Significant improvements in the management of the Aviation Medicine Branch - howsoever called - including cultural realignment to a ‘client’ model, case management and tracking, reporting and management of delays and the prioritisation of commercial licences.
•Reinforcement, increased delegation and support of the DAME system. 
•Establishment of a transparent and credible appeals process, including the ability of the candidate to nominate an expert to argue on their behalf.
•A need to consider how relevant medical information can be made available to Chief Pilots to help them fulfil their responsibilities.

---

Avmed cultural change
The attitude of the CASA Aviation Medicine Branch (or ‘team’ as it has been repackaged) is central to any discussion of lack of trust of DAMES, the inefficiency of current systems and the ongoing conflict and difference of opinion with specialists.

The branch appears to adopt a ‘we know better than you’ attitude which was the subject of considerable discussion in the ASRR Report - putting themselves above other processes, demonstrating little care concerning getting pilots back to their livelihood, and a level of arrogance in treatment of ‘clients’.

Case management and workflow
It will be critical for improved ‘whole-of-life’ (ie ‘life’ referring to the time CASA is
considering an issue before cancelling or issuing a medical) case management to ensure
the absence of any single individual within the Avmed branch does not compromise the
movement of a case to completion.

AAAA has been provided with many examples of urgent - in the eyes of pilot unable to
earn a living - medical cases stalling because a person in the branch has gone on
recreation or longer term leave and there does not appear to be an effective system to
identify that a case folder is sitting on someone’s desk and not being progressed.

This is not an ‘aviation’ or ‘medical’ problem - it is the complete absence of sensible
‘practice’ management and robust systems within the branch.

Similarly, the stalling of cases because of administrative errors on the part of CASA is at
the same time a cultural and management challenge. This problem is characterised by
failures and excuses reported by AAAA members including..

..While cultural change relies on leadership and very clear messages about what is and is not acceptable - backed up by action and attention to priorities, many of the shortcomings of the branch can only be attributed to administrative slackness that has been allowed to be perpetuated by a lack of robust systems, lack of regular reporting on achievements or delays and other KPIs and management action.

It appears that new management of the branch may be necessary to kick start such
processes with an air of urgency...

Well done AAAA, the choccy frog voucher is in the mail..

MTF...P2

Ps Will see if I can track some more Alphabet responses to the DP...