Open letter from the Aviation Medical Society of Aotearoa New Zealand to CAA

To the Director of Civil Aviation,

We are writing to escalate our concerns regarding the absence of mission-critical aeromedical aspects of the Kapua IT project underway at CAA, and specifically the selection and implementation of the EMPIC Medical Module. In its planned form, it does not deliver a safe, efficient and ICAO compliant aeromedical system.

AMSANZ is also concerned that no consultation or analysis of the requirements of CAA medical applicants, delegated Medical Examiners or even the CAA Medical Unit appears to have occurred before the purchase of the EMPIC Medical Module. It is obvious to all involved that the design and functionality of EMPIC’s medical module is already out of date and is unable to be modified meaningfully for the New Zealand regulatory environment. Major concerns were raised at both recent Medical Examiners’ user group meetings with EMPIC medical IT project team. At the last meeting, these concerns were considered out of scope for the IT team, and therefore needed to be taken up at a higher level.

Our most pressing concerns are briefly outlined below. In addition, we have polled the membership about the online project. We would welcome the opportunity to speak to the Board to elaborate further on these matters.

• The EMPIC medical module is based on the European rules-based approach: a simple “Yes” or “No” approach. It has no native support for the complex risk-based assessments routinely undertaken by New Zealand Medical Examiners and the CAA Medical Unit;

• The EMPIC medical module has extremely limited medical classification and data- mining capability (which is a core part of an evidence-based SMS). Continuous evaluation of the medical assessment process is an ICAO requirement (s1.2.4.2(b)) that may be impossible to achieve if the EMPIC medical module is implemented as currently proposed;
• Implementation of the EMPIC medical module presents a risk to the integrity of the aeromedical regulatory system at a time when there should be a step up to the safety-benefits of online aeromedical certification;
• AMSANZ is aware that CASA have offered CAA their cloud-based Medical Records System (MRS) free of charge in the past. MRS interfaces with EMPIC and more than addresses the missing functionality of the EMPIC medical module. CASA is committed to further development work for at least the next three years. This would also be a golden opportunity to progress simplification and harmonisation of processes across the Tasman. AMSANZ is concerned this option has not even been considered by the IT project group;
• The majority of CAA Aviation Medical Examiners currently use the SkyCert programme to conduct aviation medicals. This tool, among other alternatives, does not appear to have been evaluated;
• The out-of-date design of the EMPIC medical module, limited ability to appropriately modify forms, the cumbersome user experience for pilots and medical examiners, and inherent limitations in how important documents are stored and able to be searched all raise serious concerns. In combination, we consider these issues would act as a significant disincentive for doctors considering training as Medical Examiners in New Zealand, and worse, lead to some current Medical Examiners exiting the system.

We look forward to the opportunity to discuss these issues with urgency.

Yours sincerely,

Dr Michael Drane
President
On behalf of the AMSANZ committee