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Aviation medical policy review - (DP 2206FS) - Sandy's response

Response ID ANON-437A-VN42-9
Submitted to Aviation medical policy review - (DP 2206FS)
Submitted on 2022-05-03 12:05:59

Personal information
First name: Alexander
Last name: Reith
Email: sandy@reith.com.au

Do your views officially represent those of an organisation?
No, these are my personal views

Which of the following best describes the group you represent?
Air operators, Flight instructors and flight examiners, Flight training organisations, Pilots

Do you give permission for your response to be published?
Yes - I give permission for my response/submission to be published.

Medical certification structure
Topic 1a: Assess the implementation and outcomes of Basic Class 2 certification and of other changes to the Class 2 certification process.

Comments:
Your Basic Class2 in present form is not fit for purpose because :-
1). The operational restrictions, especially the irrational denial of IFR use.
Explanation, IFR is arguably the safest, most efficient and most controlled type of flying and should be encouraged. Existing IFR rated pilots should not be
induced to lapse their ratings, unreasonable restrictions beggar the whole of General Aviation and policies must change.
2). The present AUST Roads standard via BasicC2 is higher for the pilots than for than for truckies and bus drivers because of the ‘unconditional’
requirement. I was caught out on this one owing to a technicality. It is a fact that, as one highly dissatisfied pilot complained, he could drive a truck load of
fuel through a city centre but was prohibited from a BascC2 medical certificate.
3). Thus the Australian BasicC2 is so limited in benefit that it has little respect or utility compared to the very successful USA version which relies far more
on self reporting and does not preclude IFR.

Comments:
As my previous comment the USA model is a far better model, the AOPA organisation of the USA estimated that approximately 17,000 pilots came back to flying when that reform was introduced.

However for the best model look no further than that of our recreational low weight category that’s a proven safe model across some thirty years right here in Australia.

As to the question of risks, I’ll refer you to the record of the RAAUS experience, the model quoted above and tables and statistics from the USA, search their AOPA website and data from the FAA. I can send you excerpts from those sources if you wish.

These sources clearly indicate that the risk of accidents attributable to in flight medical incapacitation is negligible, the numbers so few, and also that there’s no pattern to distinguish between the classes of aviation medicals or no special medical examination.

Topic 1b: Austroads levels
The Private Austroads standard should be considered for the Class 4 noting the unconditional application of the Commercial Austroads standard for Aviation use can be a stricter standard to meet when compared to the conditional application of a Class 2 Medical.

Comments:
These matters have been canvassed for many years, the information about risk is as good as one could expect particularly with the record of RAAUS and from the USA record. GA is in need of rapid reform and the timetable of this inquiry is too long, if CASA wishes to have a GA industry worthy of Australia it
must get reform on the books urgently.

There’s no rational reason to delay, RAAUS self declared car driver standard with an annual GP examination fit to drive a private motor vehicle is the correct way ahead.

I urge all those involved to move this reform as quickly as possible.

Expanding DAME delegations
Topic 2: Determine the effectiveness of CASA delegations to Designated Aviation Medical Examiners (DAMEs) and whether these could be extended or improved.


Comments:
Apart from the politics

Self-declared medical for private pilots
Topic 3: Review other areas of aviation activity where medical certification could improve safety outcomes.

Comments:
As always it depends on the detail.

First principle is to determine the risk factors and what is the purpose of the aviation medical examination certificate. If it is mainly protect the general public, and I submit that that is a rational and legitimate government pursuit, then the conclusion must be that there’s no evidence that aviation specific medical examinations contribute to the safety of the public, or indeed the pilots themselves.

Furthermore I don’t see the proposal detailing operational restrictions, if any, such as aircraft types and other limitations, IFR or CTA operations for example.

Comments:
Unnecessary limitations based on nothing more than unsubstantiated opinions have severely reduced participation in General Aviation (GA).

Risk of accidents by medical incapacitation are far more likely to involve more people on our roads than in flight. We accept some extremely slight or negligible risk every journey by road, there’s no reason or facts to make flying so incredibly different.

BITRE statistics, especially if plotted against population growth, clearly demonstrate a very substantial decline of GA but arguably don’t show the full potential of where we should be because we are also a much wealthier and technologically advanced country than we were 30 years ago.

The negative outcome of our present languishing GA industry is lower levels of experience in safety management, less innovation towards efficiency and safety, less GA business and involved personnel.

Allowing free enterprise room to move will provide the very necessary motivation to keep up to evolving community standards and provide aviation services to a much greater extent than the present way of bureaucratic strangulation and regulatory overkill.

What we need is a simple ’road rules’ approach coupled with an airports policy to preserve availability to assist that growth and to fulfil a very important role in terms of National security. Aviation is undoubtedly a crucial element of our ability to project strength and protection for the Nation.

Standards for drone pilots
Topic 4: There are no current Australian medical standards in respect of remotely piloted aircraft operations. This is an area for future policy consideration, and we would like your ideas early.

Comments:
No, not until and unless there’s facts, and no doubt from the USA experience which is many times that which pertains in Australia, to give cause to make this an issue.

Flight instructors in sport and recreation
Topic 5: Establish whether the current structure of medical certification for recreational aviation is fit for purpose.

Comments:
This is a non issue by the very statements accompanying this question.

Firstly there’s not one quoted accident attributable to an instructor’s medical in flight incapacitation.

Secondly there’s not one shred of evidence to make claim that having an aviation standard certificate will preclude such an event.

In reality the quoted incident proves the point, it’s not possible to predict the onset of an incapacitation because the instructor no doubt had the required medical certificate.

There’s always some risk in flying, you generally drive your car to the airport past numerous other drivers with all sorts of possible medical conditions.

Lastly, in the USA instructors need no medical certificate if instructing those students who have soloed. Why not here and immediately instigate one easy reform? While we wait.

Modernising the rules
Topic 6: Examine the Part 67 regulation to ensure it is up to date and fit for purpose.

Comments:
Making advisory what is now in the regulations is sensible. In terms of clarity all regulations should be in plain English even if that means some difficulties for the legal perfectionists because the overall effect would mean that your rules are simplified, understandable and might even become respected.

Final feedback
Topic 7: Consider any other relevant matters.

Comments:
I’m sure that in my submission the message is plain. I understand that there’s inertia and a natural unwillingness to make simplification because this direction says that much of CASA’s medical work is not now necessary.

Sometimes change reduces personnel in one area but government could assist, encourage and promote technology for in flight health monitoring and auto pilot systems for autonomous flight and safe landing in case of single pilot incapacitation.

MTF...P2