Comments in response to CASA policy paper
CASA is grateful for the comments received in response to this policy paper. Five individuals and organisations responded. Many of the comments were helpful and raised points for discussion. It is not the intent of this document to respond to each comment individually, however please refer to some comments in relation to the responses below.
Consultation, preparation of discussion papers, process of policy evolution etc
This policy represents a change to the way a sub-segment of the aviation community are assessed in terms of a particular regulation. It is not new regulation, and therefore does not invite a regulatory impact statement.
Competency and age
Some respondents quoted excerpts from the article "Does Age Affect A Pilot's Ability To Fly? - February 27, 2007, issue of Neurology, the scientific journal of the American Academy of Neurology by Joy Taylor". This paper is not relevant to this discussion, as there is no intent to suggest that older pilots should automatically be denied flying privileges. The policies for assessing cognition are to identify individuals with reduced cognition.
Testing for coronary disease, atrial fibrillation and visual field defects
Comments about this were supportive. There was a mention of cost for visual screening.
Comments about accidents
There were comments about the accidents in the mature age groups being low. The absence of accidents does not mean that the risk is acceptable. Safety can be defined as risk reduction, and this underpins CASA’s risk management practices.
The MOCA, flight testing and DAME assessment
The assessment of cognition ideally needs to be done over time, and by multiple means. There were many comments about the MOCA being too difficult to administer, and others about it being absurdly simple. One respondent made a cogent argument for DAMEs judgement forming the primary basis for the assessment of cognition. CASA agrees that DAME judgement is important, but more effectively that it is supplemented by an objective test done by the DAME (to provide a structure for the assessment) and the results of a contemporaneous flight test.
In evidence provided to a recent inquest into a mid-air collision that occurred in 2008, two eminent specialists (one neuropsychologist and one geriatrician) variously made the following comments:
Click on each question to open up or close a corresponding answer.
Q. Whether by reason of a referral to investigate a specific issue, or because of a general age-related referral, what diagnostic steps, if any, should be followed?
In my view cognitive testing should comprise standard medical evaluation in any person over the age of 65. When preliminary testing or screening identifies issues of concern then further testing and ultimately investigation are warranted – a stepped protocol should in my view be followed to provide a practical and sustainable approach to assessment.
Q. Is there a need for medical assessment of pilot competencies specifically in regard to age associated disorders as would comprise geriatric specialist assessment'? If there is, what are the factors that would merit consideration in determining the age at which compulsory testing should be required?
The prevalence of neurodegenerative disorders escalates significantly, and the rate of escalation increases, with increasing age. Between 65 years and 85 years the prevalence of diagnosed dementia increases almost four times. This increase is also reflective of the increasing prevalence of a range of other medical disorders many of which impact on (or whose treatments – medications – impact) the ageing brain. In my view therefore a regimen of testing should include evaluation of pilots after at least the age of 65 years as part of the standard evaluation undertaken by DAMEs (with preliminary training and guidance), and mandatory assessment by a specialist.
Clear guidelines need to be developed for regular (possibly annual) assessment of cognitive functioning in pilots aged over 65 years, using tests of executive functioning.
There need to be clear guidelines concerning triggers for referral for cognitive assessment for pilots under the age of 65 who may show signs of cognitive decline; these might include inappropriate behaviour and social interactions, poor decision making or memory difficulties.
It is apparent that there are many competing views about the optimal manner in which to manage cognitive impairment in mature pilots. CASA will continue to pursue the monitoring of literature and evidence on the subject with the intent of formulating policy in this area.
However in the interim no policy is being implemented, and decisions about mature pilots will continue to be made (as now) on an individual case-by-case basis.