It’s been quite a while since our last update, but rest assured that work has been ongoing behind the scenes now for some time. We are pleased to advise that these lobbying efforts culminated last week with CASA CEO Shane Carmody announcing the most significant shift in Australian colour vision policy in over three decades.
CVDPA congratulates CASA on the below announcement which finally recognises what we have been arguing all along. Whilst it should never have taken this long and Australia shouldn’t have needed to wait for the New Zealand CAA to lead the way with their changes last year, it is however a result that we are very pleased with and one which opens the door for all current and aspiring CVD pilots to reach their full career ambitions.
The CASA Briefing – February 2020
A solution has been found to a somewhat thorny and long-running issue that is important to a group of pilots. The issue is colour vision deficiency and the way CASA manages safety related assessments as part of the medical certification process. Colour vision deficiency affects about 400 Australian pilots and a three-stage testing process has been in place for some time, with a pass at any stage allowing an unrestricted medical to be issued. Where all three tests are failed then a medical certificate can be issued subject to conditions.
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. These factors have been recognised overseas, most recently in New Zealand where a new approach to colour vision deficiency came into effect in May 2019, which includes an operational colour vision assessment. This assessment comprises a ground-based assessment and an in-flight assessment which looks at a pilot’s ability to interpret visual information. A separate assessment is done for day flying and for night flying.
We have decided to adopt this approach to colour vision deficiency assessment and in the short term we will recognise the New Zealand operational colour vision assessment as an alternative to Australia’s current third level of testing. Work is already well underway on the development of an Australian operational test for colour vision deficiency by mid-2020. Any Australian pilots who wish to use the New Zealand assessment can do so now, although it will require travel to that country. CASA has carefully examined all relevant safety issues and believes this new approach 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.
In early June 2014, CASA officially announced changes to colour vision policies which completely disregard 25 years of empirical evidence and safe flying by Australian pilots at all levels of the industry. They also ignore the findings of two previous independent tribunals, the latter of which was conducted as a publicly funded test case. These cases remain as the most comprehensive examination into colour vision standards ever conducted in the entire world. Both cases found overwhelmingly in favour of CVD’s posing no safety risk.
CASA have also pre-empted the decision of a further AAT hearing which has not even been heard yet. One has to ask, if there are supposedly no “immediate” changes for existing pilots, then what is the safety case for refusing certification for new pilots into the industry?
CASA’s Principal Medical Officer Dr Pooshan Navathe has emailed all Designated Aviation Medical Examiners (DAME’s) asking them to discuss with CVD affected pilots whether additional restrictions are necessary on their flying privileges (reproduced below with permission).
CASA has also written to all Australian AOC holders advising them to re-consider whether it is safe to continue to allow CVD pilots to operate. CVD pilots also received a similar letter too.
Each of these above letters needs to be read in conjunction with the following investigative article by Aviation Journalist Paul Phelan:
Recent medical research indicates that the safety-related implications of an individual’s CVD may be more significant than they were initially considered to be.
This [Dr Watson’s treatise] is not evidence of anything of any consequence in this entire debate. Indeed, it is evidence of what a mess the aviation colour perception standard is in worldwide. Imagine relying on this as legal evidence to impress a judge just how dangerous colour vision defective pilots are!
Can CASA point out any recent research presented in the Watson article that indicates anything of the sort? As anybody familiar with the debate would observe, the Watson prose is packed with subjective assertions, mind-numbing statistics, tables and flow charts that are in no way relevant to the “safety-related implications of an individual’s CVD”.
The main conclusions from this research are that:
There is a high degree of variation between States in the detection and medical assessment of CVD applicants; and
The observed variation stems not from the wording of the medical standards of the States, but from the application of those standards.
So 190 separate states have all figured out different but similar satisfactory ways of managing the same issue, right? Furthermore Dr Watson’s research actually refers to:
The paucity of documented aircraft accidents or incidents where CVD is implicated as a contributory factor.” [Because there are none]. And states that:
It is beyond the scope of this report to analyze [analyse] the issues and the debates concerning CV standards and civil aviation.
Additional queries have led to a further letter of response from CASA, including a lengthy list of references. Much of this literature is well out of date (some even dating back to the 1800’s!) and much does not even relate to aviation. It is clear that the focus continues to be on the “testing” of colour vision, rather than examining the core issue of whether or not it makes any difference to flight safety. It is obvious that CASA is attempting to use an approach of quantity rather than quality.
CASA cannot be trusted!
Colour blind pilots will not be grounded in Australia following study: CASA
Today, CASA spokesman Peter Gibson said the changes would be years in the making. “There’s certainly nothing for any Australian pilot who has colour vision issues to be concerned about,” Mr Gibson said. “We’re not grounding any pilots, we’re not putting any further restrictions on any pilots, we’re simply saying there is some new information out there which we’re considering.”
Does Mr Gibson care to explain the below letter to a CVD airline pilot with 12,000 hours?
“No not grounding but CASA have taken my ATPL from me. I did a “Real Life” night IFR renewal in 1997. I was assessed as being colour safe which gave me the condition “11” that has been accepted by CASA ever since. The testing officer was and still is an approved CASA ATO.
In 2009 Pooshan tried to take my ATPL but when challenged they reversed the decision immediately. Make no mistake they are aiming to remove all privileges.
Don’t be fooled by the spin doctors. There is a definite agenda here by CASA.
I fly with guys that have 150 hours and still don’t have a car licence and yet they want to take my 12000+ hours LHS Jet out of the industry. Sorry, I forgot I am the “Safety Issue” here.”
After almost two months of being ignored by Avmed, this pilot finally recieved a response after lodging a complaint with the Industry Complaints Commissioner.
“Well after a rather direct complaint to ICC and a rather speedy reply, I might add, CASA has returned my ATPL privileges apologising for the “Imposition”.
However, I am under no illusion that they will have another crack at me further down the track pending the “New Research”.
The PMO must be under a little pressure judging by the way he signed off the letter. Take a look at the numerous spelling mistakes in his sign-off.”
Medical Certification – Frequently Asked Questions
How does CASA deal with pilots with colour vision deficiency?
CASA has reviewed the application of Civil Aviation Safety Regulation Part 67 – which covers the medical certification of pilots – as it relates to pilots with colour vision deficiency (CVD).
CASA is not changing the regulations relating to CVD but is putting in place new procedures to better align with the existing regulations.
There will be no impact on existing pilots as the new procedures will relate to new applicants only.
Australia is more flexible in its approach than other countries in allowing applicants to sit multiple sequential tests for CVD where a fail is recorded and a medical certificate can be issued if at any stage any of the three-level tests are passed. Most overseas regulators do not allow this level of flexibility.
The new procedures are:
Initial issue of class 1 medicals
A pilot must undergo all three stages of tests until a pass is achieved before a class 1 medical certificate can be issued in accordance with regulation 67.150 of the Civil Aviation Safety Regulations.
Initial issue of class 2 medicals
If the Ishihara test is failed, a certificate will be offered restricted to day VFR only. If the applicant wants this restriction removed, they must pass one of the tests as per Part 67.
Class 1 medical renewals
No immediate change. CASA will write to affected class 1 medical holders and the major airlines advising them to consider the impact their CVD may have on their flying, and such other obligations as they may have to inform their employer of a condition which may affect their ability to safely perform their duties. CVD Class 1 pilots may need to undergo a CAD test in the future.
Class 2 medical renewals
No immediate change. CASA will write to affected pilots asking them to consider the safety-implications of their condition and govern their own flying activities accordingly.
A certificate will not be issued until a test has been passed as per the existing regulatory requirements.