[Peetwo]

Aviation medical policy review - Cont/-

Via Oz Flying:

Part 67 Consultation hints at Self-declared Medicals
2 May 2022


CASA today opened consultation on the future policy surrounding aviation medical standards, which contains the option to introduce self-declared medicals for private operations.

Recreational pilots have had self-declared medicals for many years, which has continued to be a sore point with private pilots who fly the same, or similar, aircraft, but have been subject to CASA medical examinations to stay in the air.

The consultation is part of the review of CASR Part 67, which covers the requirements of all medical standards.

"Our review of the aviation medical rules aims to simplify and modernise our overall approach to medical certification," CASA stated today. "It follows work done over several years to improve and reform aviation medicine through a tiered approach to risk management.

"This considers how we can make it easy and simple for private pilots to get in the air and stay flying. It allows us to focus effort on higher risk activities such as passenger transport."

The consultation focuses on six areas:

• examining Part 67 to ensure it is up to date and fit for purpose
  
• assessing the implementation and outcomes of Basic Class 2
  
• determining the effectiveness of CASA delegations to DAMEs and whether these could be extended or improved, or whether DAMEs can be given direct authority under the regulations to issue medical certificates
  
• considering other areas of aviation activity where medical certification could improve safety outcomes
  
• establishing whether the current structure of medical certification for recreational aviation is fit for purpose
  
• considering any other relevant matters.
  

Part 67 has been under review by a CASA technical working group (TWG), which forms the basis of much of the consultation. Among the options coming from the TWG are removing the requirement for medical examinations for PPLs, enshrining the principles of the Basic Class 2 into Part 67 and expanding DAME delegations to allow them to do more.

The consultation covers not only standards for PPLs, but also for drone pilots and flying instructors.

Feedback to the Part 67 consultation can be submitted to CASA through the Consultation Hub on the CASA website.

Plus from AOPA Oz, via FB:

CASA SEEK PUBLIC CONSULT ON PILOT MEDICAL REFORM, AOPA AUSTRALIA IS CALLING FOR INDUSTRY-WIDE SUPPORT
The Civil Aviation Safety Authority is seeking industry feedback for three key potential reforms to aviation medical policy, and are considering:
- self-declared medical for private pilots
- building the principles underlying the Basic Class 2 into Part 67 and simplifying the medical certification structure
- empowering DAMEs to do more by expanding delegations.

BEFORE YOU CONSIDER RESPONDING

AOPA Australia will today release a comparison table of pilot medical certification standards, that will enable you to see how Australia stacks up against our international counterparts.  In the week following this release, we will publish guidance material on how you can respond to this important public consult, and we are calling on pilots nationwide to get behind our push to achieve meaningful reform.

Plus some comments in reply:

Steve Curtis
  · 11:32
Ben, I trust you’ll include stats on the aircraft currently operating in Australian controlled airspace by self certified medical holders? Camden is a good example with the safe history of glider operations for at least the past 60 years.

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Aircraft Owners and Pilots Association Australia

Steve Curtis yes I have collated these. Would not mind running this by you before I release today.

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Mark Newton

Steve Curtis Not just Camden. The folks at the Canberra Gliding Club have been negotiating clearances with Canberra Approach for wave soaring flights above FL200 for decades.

Their “medical” is a box ticked on the annual membership renewal form to assert that they’re safe to fly.

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Mark Newton

Steve Curtis (I’ve also had a clearance myself to get through the R’s north of RAAF Edinburgh between Lochiel and Gawler in a glider. No transponder, they gave me a block clearance with position reports and left me to it)

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Shannon Baker

Mark Newton I don't get why controlled airspace increases risk?... It decreases it!
IE: if a pilot becomes unresponsive to the controller - they can clear traffic away from that aircraft... If anything it's the uncontrolled airspace that is higher risk. ?

Anyway, this point should negate most arguments entirely about operating in controlled airspace with a self declared medical ! All procedures etc are already in place for an unresponsive aircraft.. nothing new needs to be invented. ??

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Mark Newton

Shannon Baker For some reason they’ve never adequately explained (because they outright refuse to proffer written safety cases), CASA has drawn a line in the sand between access to controlled airspace and medical standards not administered by avmed.

So you can fly RAAus on a drivers license standard, and not have access to controlled airspace; Or you can fly on a Basic Class 2, which is also based on a drivers license standard, but is administered by avmed and therefore conveys access to controlled airspace.

They’ve only been able to maintain that position by refusing to acknowledge the places where their own regulations have grandfathered-in occasions where controlled airspace access is permitted without avmed.

The most obvious of those cases are their 70-odd years of GFA regulation (where CASA has always allowed pilots to self-declare without any doctor involvement whatsoever, and has always allowed controlled airspace access), the Avalon Airshow (where CASA allows RAAus pilots access to controlled airspace, but only for three days once every two years) and capital city secondary airports (where the airspace is deemed too dangerous for RAAus pilots except in the early morning or the late afternoon when the tower is closed, in which case Kitfoxes can blast in and out of class D over built up areas with gay abandon)
When you see those examples, it’s obvious that CASA has no safety reason to discriminate between medical standards, and the only reason they do it is because THAT’S THE KIND OF ORGANIZATION THEY ARE. They are determined to be that kind of organization, which is why the only feasible way to fix this is to simply stop talking to them and go over their idiot heads and get the politicians to force them to perform whether CASA likes it or not, which is what the AOPA event on May 1st was all about.

If the reason was any deeper or more complex than “that’s the kind of organization they are,” they’ve had plenty of opportunity to show a written safety case which explains it. The first consultation for RAMPC happened in 2010. They’ve been “reforming” medical standards on a rolling continuous basis for nearly a decade and a half, and if they haven’t been able to explain themselves by now it’s because they can’t.

Personally I think we should spend a lot more time talking about their budget: Their only significant job is regulatory drafting, and if they can’t do it correctly they shouldn’t be paid for it. An organization with a $200m+ budget should be required to answer, “What the hell do your 900 staff do all day?”

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Shannon Baker

Mark Newton obviously the statistics (facts) don't gel well (paint the picture the way someone wants) with whoever has a bee in their bonnet about it in the organisation. - so they simply ignore it... It's obvious the statistics are so supportive of the idea they are even beyond manipulation and cherry picking by CASA.

It's ok, I've seen how they run investigations - filter out and ignore all exculpatory evidence - so only the damning stuff (that is mostly out of context) is left to run a particular narrative.

Plus from Sandy:

Sandy Reith

If there’s rational reform for private pilot medical certification this would give our General Aviation industry a huge boost.

Well done Ben and AOPA for promoting a reformed certification, as opposed to the unreasonable regime that currently applies. We’ve been labouring under AVMED’s unreal standards that are based on nothing more than unsubstantiated opinion when all the evidence indicates that the current rules and administration of medical standards for pilots are restrictive and wasteful for no good purpose.

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Sandy Reith

The USA’s investigations:

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Sandy Reith

And the statistics, the USA BasicMed is largely a self declaration regime, includes IFR, six seats and 18,000ft and CTA. The restrictions such as they are were the compromise in face of a very strong physicians lobby but nevertheless very successful in bringing some 17,000 pilots back to flying as reported by AOPA - USA.

MTF...P2