Feeling a little DAMP?

AAAA supports in principle the concept of drug and alcohol policies and procedures, but remains concerned that CASA’s approach will burden the industry with increased costs for little to no change in safety outcomes.

AAAA has consistently lobbied for aerial work AOC holders not involved in the carriage of passengers to be exempt from the DAMP requirements but to be subject to the CASA random auditing program. Unfortunately, CASA has not accepted this practical proposal to significantly simplify the requirement for our sector. This highlights CASA’s difficulty in creating any meaningful policy distinction between AOCs that cover simple aerial work operations and those that involve the carriage of fare paying passengers.

There also remain significant sticking points with the regulations that only CASA will be able to clarify.

The first issue is the need for CASA to clarify who in an organisation can actually conduct the testing and the necessary procedures to govern that testing to ensure the validity of a test result.

AAAA understands that CASA intends that every operator will have a DAMP supervisor, who must have ‘appropriate training’ – as yet undefined.

From discussions with CASA, AAAA also understands that the intent is to have initial testing conducted by the DAMP supervisor, confirmatory testing of any ‘non-negative’ test by an accredited laboratory, and review of a positive result by a Medical Review Officer (MRO) – the regs and currently available guidance material do not make this clear. These three new positions or relationships for the AOC holder to negotiate further complicate the process.

The second issue is the potential shortfall in MRO numbers and locations that will enable operators to fulfil the mandatory requirement for a relationship with an MRO.

What medical practitioner (DAME or otherwise) outside major population centres would be interested in attending a course held only in capital cities at a cost of $550, having to shut their surgery or have a colleague cover for them and having to pay travel and accommodation costs, when they may only have a few AOC holders in their local region? The CASA counterpoint that a relationship with an MRO could be conducted remotely (perhaps over the internet) may represent a way forward, but why not have thought this through a bit better and simply extended education and support to existing DAMEs who already have an established relationship with operators? The third issue is the likely difficulties for operators in rural and especially remote Australia who simply do not have easy access to the required accredited testing facilities for confirmatory tests. The challenges of getting a confirmatory sample to an accredited lab in accordance with strict chain of custody procedures from remote parts of Australia has been raised with CASA from day one – and ignored.

AAAA has been trying to get the city-centric CASA to understand that access to accredited laboratories, access to trained personnel and access to efficient and timely courier/transport services that can guarantee chain of custody and appropriate storage conditions for samples on route to a lab, are real problems in many areas of Australia. The regulations even admit this is an issue by including the line that testing only needs to happen post-accident/incident ‘if suitable test conditions exist’ – obviously they won’t exist where a sample cannot be sent to a lab because of distance, security or access issues, let alone the health of the survivor.

There are plenty of companies outside aviation who have managed to introduce alcohol and drug policies and procedures – many including testing – with a minimum of fuss and cost.

Drug and alcohol policies and procedures are a good idea – it is just that the CASA way of achieving the outcome is so resource intensive the process begins to overshadow the likely outcome – confirmation that Australian pilots take their safety responsibilities, especially in terms of drugs and alcohol, very seriously.

There are plenty of other areas in aerial application that could do with safety dollars and resources that would be likely to return a better safety premium for the significant investment that all AOC holders will be forced to make through DAMPs. n Australian Aviation is proud to be the official supporting journal of the Aerial Agricultural Association of Australia. The views in this column are those of the AAAA, and not necessarily Australian Aviation’s.

Unfortunately, CASA has not accepted this practical proposal to significantly simplify the requirement.