ࡱ> xzwS@  qbjbj hFFFFFFFZ~~~8DZS/:T"vvvv: .......$0RE3P.F#vv##.FFvv /$$$#RFvFv.$#.$"$&V-@FF.v Pdd~1$|. .#/0S/&.x3$"3.ZZFFFF3F. ,$ ~!a..ZZ$~$ZZ~P.O. Box 5041 Manly QLD 4179 23rd September 2002 Disability Rights Unit HREOC GPO Box 5218 Sydney 1042 SUBMISSION OF OBJECTION TO APPLICATION FOR EXEMPTION UNDER DISABILITY DISCRIMINATION ACT SECTION 55 AND SEX DISCRIMINATION ACT SECTION 44: CIVIL AVIATION MEDICAL STANDARDS. Dear Sir/Madam, I wish to lodge an objection to the proposal from the Civil Aviation Safety Authority (CASA) to be granted an exemption by the HREOC under the DDA section 55 and SDA section 44. My main area of concern that I wish to object to any exemption being granted relates specifically to the Civil Aviation Regulations 1988 (CAR 1988) Part 6 Schedule 1, Part 1, Paragraphs 34-39 and to Schedule 1 Part 4, paragraph2 (g). Additionally, I wish to include in this objection proposed Part 67 of 1998 Civil Aviation Regulations (CAR 1998), in particular subsection 67.160, 67.165 and 67.015. These sections of both regulations deal specifically with Class 3 Medical Certificate (Class 3) issues for Air Traffic Controllers in Australia. I will highlight in this submission that the reasons behind the request for an exemption by CASA is not safety driven but is driven by economic expedience and fear of litigation. It is basically a dressed up request to allow unjustified discrimination against persons with the vision impairment of colour vision defect (CVD). In order to give credit and reasoning to my submission, I will give the Commission a brief employment history. EMPLOYMENT In late 1987, I joined the Royal Australian Air Force as and Air Traffic Controller. During my initial recruitment medical examination, it was found that I had a CVD. This was discovered by my failure in the Ishihara Plate test. The RAAF then administered the Farnsworth Lantern test, which I successfully passed and was designated as colour blind safe and subsequently employed as an Air Traffic Controller (ATC). I had absolutely no trouble completing all my training and ATC ratings. In 1990, I contemplated a career change to RAAF Pilot and knowing I suffered from a CVD I underwent further colour vision testing. It was discovered that my CVD was in fact worse than initial testing had indicated. This led to my suspension as a RAAF ATC until the matter was thoroughly investigated. Extensive operational testing in accordance with the Civil Aviation Regulations followed which I easily passed. (The RAAF ATC Licences were issued under a delegated Authority from the then Civil Aviation Authority (CAA) under the CARs.) This resulted in the unrestricted reinstatement of my ATC qualifications and I continued to progress in my career as an ATC. During my time in the RAAF, I worked in no less than 10 separate Control Towers and 6 Radar Centres both in Australia and overseas including some of the most technically demanding ATC situations that anyone would encounter in an entire career. I had worked extensively with a number of different radar and data systems that utilised colour displays. My technical knowledge and practical ability as a controller was excellent and well documented. Throughout my time in the RAAF I had an unblemished record as an ATC. Obviously, I could perform all the inherent requirements of my profession and my CVD was never called into question again. In June 1994, I applied to the CAA to become a civilian ATC. I was initially offered a job with CAA but later had the offer of employment revoked on the grounds I suffered from a CVD. I was told at the time by both CAA and Aviation Medicine that CAA had a policy of not employing people with colour defective vision. It was explained that even though I had substantial experience as an ATC and obviously met the requirements of the job, they would not allow me to be employed as they had a number of existing and former staff proceeding in litigation against the CAA on the grounds of discrimination. When I asked for a copy of this policy I was told that it was not in writing and no, CAA would not put in writing to me. I was advised that to let me in would open the flood gates and it was just bad luck. I also believe that there was a case before the HREOC at that time regarding this issue (Moody vs. CAA?). I was told that as I failed the Farnsworth Lantern test, I had no other recourse. I advised the Director of Aviation Medicine, Dr Rob Liddell that I believed that I did have recourse under Schedule 1 para 39 to CAR 1988. This paragraph allowed persons who failed the Farnsworth Lantern an opportunity to sit a supplementary test, namely; 39. A person who fails the Farnsworth Lantern test may be assessed as meeting the medical standard if all relevant coloured lights are correctly identified in a simulated operational situation test of a kind determined by the Director of Aviation Medicine. Dr Liddell advised me that the only supplementary test that he would accept was a Holmes Wright Lantern test. This test on the large aperture setting simulates aviation coloured lights at a distance of 2-5 nautical miles. He advised that he actually preferred this test over the Farnsworth test as it uses aviation coloured filters and actually tests light recognition, whereas the Farnsworth Lantern is basically designed to confuse people with colour defective vision. I subsequently passed the Holmes Wright test and advised Aviation Medicine accordingly. They initially denied saying they would issue me with the Class 3 medical Certificate as promised, as Air Traffic Services still would not employ me due to their ongoing legal conflicts and possible comebacks. I was fortunate to have a taped transcript of the conversation and upon refreshing Dr Liddells memory, a Class 3 was issued and I was subsequently employed by the CAA (now Airservices Australia) as an ATC. Dr Liddell in an email to Air Traffic Services advised; Andrew Denman has passed the colour vision test using the Holmes Wright Lantern which is a satisfactory alternative to the Farnsworth Lantern. This indicates that his colour defective vision is of a minor degree and should be of no consequence operationally. He has been issued with a Class 3 Medical Certificate. Upon employment with CAA, I completed a 6 week refresher/induction course and was sent to Tamworth Control Tower in NSW in August 1995. I attained all my ratings in only half the usual time (2nd fastest on record) and had no problems working in this environment. Unfortunately, on 1 August 1996, I was hit by a car on the way home from work and suffered severe orthopaedic injuries. This resulted in me being away from ATC for a period of 7 months. Aviation medicine cleared me to return to work in February 1997 and I continued to work as an ATC at Tamworth until complications with my injuries led to medical suspension in January 1998 and subsequent ATC licence cancellation in April 1998. Upon licence cancellation I redeployed to another position in Airservices which attracted less than half the salary and I continue in that employment today. I was advised by both CASA and Airservices Australia that if my injury related difficulties could be resolved, I would be entitled to re-apply for my Class 3 at any time. In April 2001, after some 13 surgical procedures, I finally gained a successful resolution to my injuries and on 2nd July this year re-applied for Class 3 certification by CASA. My aviation medical examiner fully supported my application. CASA initially requested further specialist reports regarding my injuries, which were supplied. I was expectantly waiting for my Class 3 in the mail. What I actually received was a letter from CASA advising me that they were refusing to issue my Class 3 on the grounds that I was colour blind and therefore did not meet the standards for colour perception as listed in CAR 1988. This caused me some confusion, as I was not aware of any change in CAR 1988 Colour perception standards for ATCs since I was cleared initially in 1995. CURRENTLY Subsequent investigation has found that in fact, the colour perception standards for ATCs in CAR 1988 were amended prior to my employment with CAA/Airservices. The amendment was number 382/94, Regulation 22. This amendment stated; Regulation 22 This regulation amends Part 4 of Schedule 1 (Medical Standards) by removing the power to conduct a simulated test for Air Traffic Controllers to test their colour vision. A simulated test of the type used is now considered to be unsuitable for that purpose. What this indicates is that CASA had mistakenly certified me to operate as an ATC under CAR1988 although at this time they will not confirm or deny this. Whether or not my application for CAA sparked this change as I could easily pass any operational test, I do not know. I am currently attempting to get reasoning behind this change in regulations through the FOI process from the Attorney Generals Department and Airservices Australia. Certainly, there was no operational changes in Air Traffic Control to warrant a tightening of colour perception testing. I firmly believe and have had this confirmed by CASAs current Director of Aviation Medicine, that Air traffic Services (now Airservices) lobbied CASA to amend the regulations. The reasoning behind this is fairly obvious it was to discriminate against people with CVD. By removing the simulated operational test, fewer colour defectives would slip through the loop and cause less headaches for Airservices Australia. The Director of Aviation Medicine, Dr Peter Wilkins, has also confirmed that the reason behind a further tightening of the colour perception standard as seen in the draft Part 67 to CAR 1998 was at the behest again of Airservices Australia. This was due to the new (1999) TAATS Radar System that utilises coloured displays. Rather than testing the displays for use by colour defectives, it was easier (and far cheaper) just to legislate them out. I have it on good authority that Airservices enquired about costing a validation of the TAATS system colour palette for use by ATCs with CVDs and the cost came back as too expensive for Airservices as this had not been budgeted for. Airservices response was to say that if people were unhappy with this they could just sue them. I am currently attempting to get the report commissioned by Airservices on this issue under FOI but am still awaiting response. I have asked Airservices Sponsor of Equity and Diversity, Mr Andrew Fleming to investigate my Class 3 refusal and Airservices role in it and the relevant regulatory changes. I am also aware that Airservices will be providing submissions to the HREOC on this exemption request as well. REQUEST FOR EXEMPTION I would now like to look specifically at CASAs request for exemption and address specific points in their proposal. Although I only have a rudimentary understanding of the DDA, I will also attempt to answer the HREOCs questions to be addressed. As previously mentioned, I am only addressing the exemption request in the context of how the existing and proposed legislation discriminates against both existing, prior and potential ATCs who suffer from the impairment of colour defective vision. I will deal with CASAs covering letter first. It is obvious, but does not state explicitly that CASA feel that they are in contravention of the DDA and SDA with CAR 1988 as well as proposed CAR 1998, otherwise they would not be asking for an exemption. CASA state that Part 6 of CAR 1988 and the proposed Part 67 of CAR 1998; are based on international standards and recommended practices, as prescribed in Chapter 6 of Annexe 1 to the Convention of International Civil Aviation. They further state; Conformity with international standards and practices prescribed under the convention is necessary. Chapter 6 of Annex 1 to the Convention of international Civil Aviation, Sub para 6.2.4, states that an applicant for a medical certificate; shall be required to demonstrate the ability to perceive readily those colour the perception of which is necessary for the safe performance of duties. The standard then prescribes that the applicant shall be tested using a pseudoisochromatic plate test of which the Ishihara Test (as used in Australia) is one type. This test is basically a CVD screening test and is used by practitioners to screen persons for a CVD. The test cannot advise whether a person who has a colour defect can in fact distinguish the coloured lights as required by the standard. Sub Para 6.2.4 then continues to state that if a person fails the pseudoisochromatic plate test shall be considered medically unfit unless able to readily distinguish the colours used in air navigation and correctly identify aviation coloured lights. There are several suitable methods of testing available to people with colour defective vision to demonstrate that they can in fact identify the relevant aviation coloured lights. Each member state of the International Civil Aviation Organisation (ICAO) determines which test is most appropriate. There is no international consensus on this issue. The main point in this case is that the applicant can identify the relevant aviation coloured lights. In Australia under CAR 1988, Pilots have the opportunity of not one but three tests to show that they can in fact identify these lights. In CAR 1988 Schedule 1 part 4, paragraphs 34-39, a pilot/Class 1 medical certificate applicant can undertake the Ishihara plate test, if he fails this then the Farnsworth Lantern is available and if this is subsequently failed then a simulated operational test determined by the Director of Aviation Medicine (CASA) can be performed. From my understanding, the current simulated operational test involves using a control tower signal lantern to shine red, green or white lights at an applicant at a distance of both 300m and 500m. If the applicant readily identifies these lights then they are considered to meet the standard. Up until the end of 1994, Air Traffic Controllers also had the opportunity for a simulated test if they failed the Farnsworth lantern as previously discussed. They currently have no such test. It must be remembered that Chapter 6 of Annex 1 to the Convention of International Civil Aviation, Sub para 6.2.4, only requires applicants to be able to demonstrate the ability to perceive readily those colour the perception of which is necessary for the safe performance of duties. There is no specific direction for member states to impose a Farnsworth lantern test on Air Traffic Controllers. What, in effect, this means is that CASAs tightening of the 1998 CAR colour perception standard, discriminates against people who cannot pass the Farnsworth Lantern but can readily identify the required aviation coloured lights. I am just one example of this. In the proposed draft Part 67 to CAR 1998, sub part 67.160, the colour perception standard for ATCs is being restricted yet again by CASA at Airservices request. Under this proposed regulation, the only test available for ATCs is the Ishihara pseudoisochromatic plate test. There is no mention of a Farnsworth Test or a simulated operational test of any kind. The reason behind this change is not justified at all. There has been no testing of qualified people with colour defective vision to see if the TAATS coloured radar system is compatible with colour defectives. Airservices, through CASA and the Part 67 change are hoping to avoid any need to consider if people with CVDs can operate on the system. I personally work with this system on a daily basis, though not in the capacity as an ATC and I have had no problems working with it at all. CASA may argue that the introduction of the TAATS radar system with colour displays is reason enough for the Part 67 change in colour perception standards but it must be remembered that a significant number of Airservices ATC staff do not work with the TAATS equipment and some never will. Therefore this change would be unnecessarily restrictive for no reason. Also with regard to draft Part 67, Chapter 6 Annexe 1 to Convention of International Civil Aviation, Sub para 6.2.4 specifically allows for persons who fail a pseudoisochromatic plate test to undergo other appropriate testing to see if they can identify the required colours for their job. Part 67, sub para 67.160 (6) specifically removes this option and unnecessarily so. In this submission, CASA have provided no justification behind the change or the need to discriminate further on this issue. They are basically hiding behind the convenient safety argument and expect non-aviation industry persons such as the HREOC to accept it on face value. This really needs to be investigated a lot further. In CASAs submission, have stated that the proposed Part 67 of CAR 1998 is based on international standards and recommended practices. It can be seen though, in the case of colour perception testing, that CASA has not followed international practice at all. In fact, in restricting colour perception testing to the pseudoisochromatic testing alone, they are at odds with international practice yet they would have the HREOC believe otherwise in an attempt to gain their exemption under the DDA. On this matter, CASA advise on their website  HYPERLINK "http://www.casa.gov.au/avreg/newrules/casr/index.htm" http://www.casa.gov.au/avreg/newrules/casr/index.htm that formulation of Part 67 included research on the standards and recommended practices published by the  HYPERLINK "http://www.icao.org/" International Civil Aviation Organization (ICAO) in accordance with the Chicago Convention, an international agreement with which Australia is  HYPERLINK "http://scaleplus.law.gov.au/html/pasteact/0/159/0/PA000180.htm" obliged to comply. ICAO, on the website listed above, state in their FAQ section; According to the medical provisions in Annex 1 to the Convention on International Civil Aviation, normal colour perception is required for all pilots and air traffic controllers. It is, however, also stated that a person whose colour perception is defective may be considered fit for licensing provided that he can pass a test with a specified colour lantern (red, green and white light). Once again, the question must be raised that if international standards allow for people with CVD to perform in the capacity of an ATC if they can pass a supplementary test, why is CASA restricting visually impaired people in Australia from performing in the same role? HREOC QUESTIONS The following questions are asked to be addressed in submissions to the HREOC on this issue. 1. Would an exemption in this case be consistent with the objects of the DDA and SDA? 2. Should an exemption be granted irrespective of consistency with the objects of the DDA or SDA? 3. Is there an arguable case of unlawful discrimination to require an exemption? 4. Are there conditions which should be imposed on the granting of an exemption in this matter? I will now attempt to answer these questions in the context of my submission. 1. Would an exemption in this case be consistent with the objects of the DDA and SDA? In my submission I am only concerned with the DDA the objects of which are as follows; (a) to eliminate, as far as possible, discrimination against persons on the ground of disability in the areas of: (i) work, accommodation, education, access to premises, clubs and sport; and (ii) the provision of goods, facilities, services and land; and (iii) existing laws; and (iv) the administration of Commonwealth laws and programs; and (b) to ensure, as far as practicable, that persons with disabilities have the same rights to equality before the law as the rest of the community; and (c) to promote recognition and acceptance within the community of the principle that persons with disabilities have the same fundamental rights as the rest of the community. In the context of my submission, it can be clearly seen that the way in which the CAR 1988 and the draft Part 67 have been written that there is inherent discrimination contained in both sets of regulation. The issue of discrimination on the grounds of CVD is but one of the many medical areas that contain such discrimination. In considering whether or not exemption under the DDA would be consistent with the objects of the act, it must be considered if CASA, through these regulations has discriminated because a particular medical requirement listed is an inherent job requirement or not. In the case of ATCs with CVDs, there has been an arbitrary tightening of the regulations both in 1994 and in the proposed Part 67 without sufficient reason behind the change to exclude those persons affected. The medical standard is outdated, not applicable to modern ATC work practices and environments and is conveniently upheld and defended at the highest levels on the grounds of safety. To my knowledge, there has not been any testing of colour defective ATCs that have supported either the 1994 CAR 1988 amendment (as outlined above) or the draft Part 67 of CAR 1998. Additionally, there has not been any ATC performance issues be they safety related or otherwise to support either of these changes. This is very similar to the case of Macdonald and others vs. QLD Rail 1998 (QADT) in which medical requirements had been made tougher but without the requirements actually being necessary for the performance of the duties in question. The Queensland Anti Discrimination Tribunal found in this case: As the evidence of those experts indicated, the Ishihara Test is very efficient at identifying people with colour defect vision. However, the results of such a test provide no information at all as to the type of colour vision defect or the difficulties that such colour vision defect imposes for carrying out duties Additionally the Tribunal found; If an occupational requirement was imposed specifically to avoid the impact of the ADA, then it could not be a genuine occupational requirement. CASA and its predecessor, the CAA, restricting the employment of people with colour defective vision without real justification have not tried to eliminate, as far as possible, discrimination against persons on the ground of disability in the areas of work, provision of facilities, existing laws or the administration of Commonwealth laws at all. An exemption from the DDA as requested would only further disadvantage an already disadvantaged group by denying them recourse to the HREOC. 2. Should an exemption be granted irrespective of consistency with the objects of the DDA or SDA? In the context of my submission regarding the colour perception standards contained in both relevant CARs, I firmly believe that the answer to this question must be no. The removal of the safeguard of the DDA will allow CASA to further restrict not only colour vision requirements but any other medical requirements at their discretion. As in the case of the colour vision standards, there would appear to be a clear case of arbitrarily increasing restrictions at the behest of another employer in an attempt to circumvent the DDA. The Civil Aviation Regulations and their application must remain accountable to the HREOC or they will be abused more than they have been already. 3. Is there an arguable case of unlawful discrimination to require an exemption? As I have mentioned previously, I believe that CASA through the CAR 1988 medical provisions, is unlawfully discriminating against Air traffic Controller past/present and future. I have recently received preliminary legal advice to support this. For CASA to continue to deny me my Class 3 medical Certificate and others with the same impairment, they would need protection under law from discrimination actions that could be bought against them. My understanding is that protection would be in the form of the exemptions requested. 4. Are there conditions which should be imposed on the granting of an exemption in this matter? Essentially, I do not agree with the granting of an exemption at all as such an exemption would be at such odds with the objects of the DDA and the process of natural justice. However, if the Commission sees fit to grant an exemption I would request that the following conditions are imposed. a. No exemption for Civil Aviation Regulations 1988 (CAR 1988) Part 6 Schedule 1, Part 1, Paragraphs 34-39 and to Schedule 1 Part 4, paragraph2 (g). These paragraphs relate specifically to colour perception for Air Traffic Controllers; b. Additionally, proposed Part 67 of 1998 Civil Aviation Regulations (CAR 1998), in particular subsection 67.160, Table 67.160. These sections also relate specifically to colour perception requirements for ATC; c. Proposed Part 67 of 1998 Civil Aviation Regulations (CAR 1998) sub-sections 67.165 and 67.015. These to sections effectively give unrestricted power to CASA to restrict or deny medical certification to any person without any provision for actually proving that the underlying condition is significant and relevant to the safe performance of their duties. If an exemption is granted for the above paragraphs I would ask that the Commission have CASA prove through extensive, relevant, simulated operational testing that the restrictions that they currently have under CAR 1988 and the proposed restrictions under CAR 1998 are fully justified and are inherent requirements of the job of an Air traffic Controller. CONCLUSION As I have stated previously, this submission deals only with a small portion of CASAs request for exemption under the DDA and SDA, namely that affecting colour perception standards for Air Traffic Controllers. I have shown that CASA have been unjustifiably discriminatory in their amendment and application of these regulations and essentially are acting in collusion with Airservices Australia to block any person with no less than perfect colour vision to perform in the role of an ATC. CASA on their website states that there are no significant differences for Air Traffic Controllers between Part 6 Schedule 1 to CAR 1988 and the proposed draft Part 67 to CAR 1998. I would consider the unlawful and unjustified exclusion of a large number of persons from performing in the role of an ATC as a very significant difference. International convention allows people with colour defective vision to perform in this role and therefore I contend that an exemption should not be granted to CASA in these areas and if anything, CASA should be bought to account for the misuse and abuse of regulatory power in this case. If there are any queries regarding this submission, I can be contacted on 0413765 984. 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