The new Class 5 Medical is a part of CASA’s General Aviation workplan and has been proposed in response to advocacy from associations and pilots in the PPL and RPL domain. AusALPA made a submission in response to the proposal in November 2023.
AusALPA was unable to support the proposed Class 5 medical policy but would be prepared to revisit their position if several concerns raised with CASA were addressed. Details of these concerns are included in AusALPA comments on the Class 5 medical self-declaration policy consultation summarised below.
AusALPA begins by expressing reservations about the current form of the Class 5 self-declaration policy, deeming it a potential lowering of existing safety standards. The association voices concerns about the risks associated with outright self-declaration for medical fitness, especially considering the diverse and complex airspace in which pilots operate. Issues related to inappropriate self-declaration by some pilots, resistance to Civil Aviation Safety Authority (CASA) determinations, and concerns about health status suitability are highlighted as key points of contention.
Policy Improvement Opportunities:
AusALPA proposed several constructive improvements to address its reservations and enhance the policy's effectiveness:
- Trial Basis: AusALPA suggests implementing the policy on a trial basis to evaluate its impact and effectiveness.
- Initial Medical Examination: The association recommends that an initial Class 5 medical certificate should not be obtained through self-declaration, aligning with practices in the UK where it requires an examination by any medical practitioner.
- Data Collection: AusALPA advocates for comprehensive data collection on Class 5 medicals, including usage frequency, experience levels of certificate holders, and demographic information such as age.
- Auditing: A representative sample of pilots using Class 5 medicals should undergo audits to ensure the integrity of the dataset, informing a Post Implementation Review.
- Transparency: CASA is urged to be transparent about its intentions for scheme audits, outlining the scope, frequency, and structured processes.
- Access to Class C and D Airspace:
Drawing from a previous submission on access to Class C and D controlled airspace for sport and recreation aircraft, AusALPA emphasizes that medical standards criteria for such airspace should be risk-based. It stresses the need for a balance between minimizing restrictions and maximizing system performance while adhering to a risk-based approach to Air Traffic Management (ATM).
AusALPA concludes with a strong expression of concern regarding the Class 5 policy proposal in its current format, suggesting that it could potentially compromise safety standards. The association calls upon CASA to pause progress on the policy's implementation until necessary improvements are incorporated and subsequent considerations can take place, ensuring the highest standards of safety in Australian airspace.
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