CASA’s proposed CAO 48.1b MEDICAL TRANSPORT AND EMERGENCY SERVICE OPERATIONS LOWERS SAFETY STANDARDS
CASA is developing new Flight and Duty Time limitations for pilots engaged in Medical Transport operations. There has been limited consultation of affected pilot groups
Pilots of scheduled patient transfer flights have been included in rules made for pilots of emergency flights. These are different kinds of flying with different demands, and so the rules need to be different. Scheduled patient transfer flights are less like emergency flights than commercial scheduled flights.
This exposes scheduled patient transfer pilots to fatiguing duties and lowers safety for patients and flight medical nursing staff who are passengers on these flights
Pilots of planned, scheduled flights should not be exposed to fatiguing duties that can occur when conducting emergency flights.
The passengers (patients and medical/nursing staff) demand the same standards as any other scheduled commercial flight. Passengers will not be aware if the pilot is fatigued from working to emergency duty rules rather than the more appropriate scheduled patient transfer type flight.
These proposed new rules appear to minimise costs to the operators rather than properly manage the risk of pilot fatigue
Pilots of scheduled services should not be included in the newly proposed CAO 48.1b MEDICAL TRANSPORT AND EMERGENCY SERVICE OPERATIONS
Pilot rostering and rules for these scheduled flights should be the same as for normal air traffic which includes the Flight and Duty time and rest period rules of CAO 48.1 Appendices 3 and 4.
Operators providing these scheduled Medical Transport Services should plan all Flight Duty Periods, Standby and rest periods in accordance with CAO 48.1 Appendices 3 and 4 and only revert to the proposed Appendix 4(b) to conduct Aeromedical Evacuation or emergency flights
CASA must engage pilot groups as well as operators, before proposing new rules that may be unsuitable for that particular type of flying.
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