Blue Sky Thinking – Civil Aviation Authority plans to cut medical services – public consultation appears to be tick-box

Updated March 2016: the world class services at the centre have been closed. Class 1 and 3 medical certificates are no longer provided via the aeromedical centre at Gatwick.

The most recent CAA update of January 2016 confirmed that the plans would go ahead despite almost universal objection to many principles and the way it would be done. Unsurprisingly, there were only 15 responses to the 3rd consultation.

CAP 1338 was the third of three documents published by the Civil Aviation Authority in 2014-15, which had only 15 responses. The first two were CAP 1214 (www.caa.co.uk/cap1214)
and CAP 1276 (www.caa.co.uk/cap1276) which includes the 40 original responses to consultation, including major airlines, BALPA, the Honourable Company of Air Pilots (guild founded in 1929), aeromedical doctors and other professionals. All of which objected.

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Blog published October 28, 2015:

If government divests the state of our expertise along with our infrastructure, how will we ensure services continue to deliver universal public good?

The NHS is struggling to monitor the safety and efficacy of its services outsourced to private providers, according to a report published in the Independent in April. Now consider an outsourced medical service where the safety and efficacy is reduced, for our commercial airline pilots. #Whatcouldpossiblygowrong?

If you looked very hard at the Civil Aviation Authority’s website over the last year you would be forgiven for missing the links to the consultation to outsource or divest from its medical services. [1]  This is the service organisation of 30 or so staff who ensure in a part state owned set up, that newly qualifying pilots for commercial airlines and air traffic controllers are fit for the job. And not only British pilots, but others come from outside the country, so great is its reputation. It is the last state-owned of 4 such centres, and based at Gatwick.

Pilots have unique needs and unique fitness-to-fly checks to pass, as documented by Aida Edemariam in last weekend’s Guardian: “The medicals especially, Bor says, mean facing “the risk of losing one’s job… as often as every six months”.”

The initial consultation, now a year ago, suggested outsourcing the service to the private sector. Today it seems the prefered path is complete divestment from the delivery of its services. The second part of the seemingly tick-box exercise closed today. [5]

Tick-box, because the plans are going ahead despite almost every response to the consultation voicing concerns or serious questions, including from major airlines. Balpa at the time hadn’t been able to adequately respond in the original Oct-Dec 2014 timeframe. Many other suggestions and ideas were raised, but from the CAA consultation response to criticisms it seemed blue-sky thinking, creative alternative solutions differing from the CAA plans, was not welcomed.

It seems that in a bid to become lean, akin to having less to pay for on the balance sheet, the government is selling off not only concrete assets but losing British state-led skills in services at which we excel. It is asking commercial companies to fill the gap and many question if there is sufficient expertise in the commercial market to deliver.

There are five key concerns here. The first, is that without the state to hold accountable for the service, airlines and pilots must foot the bill they can no longer control, in a near monopoly market. Elsewhere in health, spending on outsourcing these services has  reportedly rocketed.

The second, is quality control. How will quality of delivery be maintained for services which operate entirely for the benefit of the public good, but are now be required to turn a profit?

And the third is continuity of service. How will the universality of these services be maintained, offered fairly and to whom?

The fourth is whether the UK should sacrifice its unique leadership position of respected medical expertise in European and global flight safety?

And finally and most importantly, pilots, airlines, and healthcare professionals questioned in the last quarter of 2014 whether safety may be put at risk if the cost cutting move at the Civil Aviation Authority goes ahead.

This cut to regulatory oversight is part of the bonfire of red tape.

Responding to plans outlined by the Civil Aviation Authority in a public consultation [1] last autumn, professionals overwhelmingly suggested service improvements could be made without outsourcing what one airline called “the priceless nerve centre of expertise in the CAA”.

Based at the CAA’s Gatwick headquarters, the aeromedical centre offers the initial medical examinations required for commercial airline pilot and air traffic controllers and periodic checks thereafter. It also undertakes assessments of the fitness of pilots to return to flying after illness.

“All pilots who hold a commercial licence undergo an annual Class 1 medical assessment with an Aeromedical Examiner, increasing to every six months from the age of 60, or 40 if they are undertaking single pilot operations. [source: whatdotheyknow.com ]
The CAA expects to reduce overall costs by outsourcing all of its aeromedical non-mandatory functions, outlined in consultation plans that were discussed with potential providers at meetings in mid April. [2] But unions suggested the CAA is putting commercial pressures before the public interest and denounced the plans.

Steve Jary, Prospect national officer for aviation, said:

“The CAA executive board needs to listen and put safety, not commercial interests at the heart of its decision making.”

In its follow up consultation response in early 2015, the CAA said it does not believe in putting a price on public safety and it realised that cost and value are sensitive issues.

The national value of excellent medical services to pilots in any business model on paper however, may be impossible to put a price on in practice. It was especially sensitive earlier this year as the plans for change coincided with the climate of raised passenger awareness following the Germanwings flight 9525 on March 24.

Long before this, in response to the October 2014 consultation, the Honourable Company of  Air Pilots, a professional guild, wrote:

“As long as human pilots are part of the aviation safety chain, it is essential that their fitness to operate is monitored and supported by an expert community without fear of or bias from commercial pressures.”

Lacking in detailed financial analysis it is hard to see from the consultation how alternative solutions measure up against private provision. Specifically there was no estimate in the document of the cost of the CAA meeting its statutory obligations. [3]

One of the three airlines that responded in consultation, suggested the CAA could be seen to be outsourcing the commercially viable part of the service:

“The Aeromedical centre only seems to account for £500k out of the £3 million …and could potentially be seen as the most profitable element.”

By contracting out to a commercial provider, and introducing the need to make a profit, some respondents are concerned it would further increase costs to industry or individuals, and the CAA acknowledged this. Fees could potentially rise in what will be effectively a monopoly market, as in April there were only three other approved providers for this service, across all of the UK. Two are already operated by the same public private partnership and although part owned by government, are essentially commercially run.

Free from Treasury control, the Civil Aviation Authority is self-funding but sits under the wing of the Department of Transport, accountable to the Secretary of State for Transport. [4] But Government support was questioned by a pilot in the consultation, who wrote:

“If the CAA and the Department for Transport cannot resolve this without destroying the CAA medical service then we might as well pack it all in.”

Pressure has reportedly come from EASA, the European Aviation Safety Agency to follow regulatory best practices and separate the duties of the authority from the delivery of services.

However a group representing 15 CAA (UK) approved medical examiners, with a mean of 22 years experience, suggested this regulatory issue could be resolved in other ways, and said:

“Outsourcing any part of the medical department would remove essential functions, weakening the ability to respond to or promote future regulatory changes.

“Fragmentation will introduce inefficiency as work which should be integrated will be on at least two sites – never helpful.”

The medical service provided by the CAA is recognised as a market leader across Europe. It influences European and worldwide aeromedical policy and as one airline wrote in the consultation, has “rebuffed some of the more non evidence based demands of the European Aviation Safety Agency.”

Maintaining that globally respected expertise, say the CAA plans, is a third reason for redesigning a medical department fit for the future but many respondents believe that outsourcing will achieve the opposite.

The Honourable Company of  Air Pilots suggested the plans would have:

“an adverse impact on flight safety and diminish unacceptably the UK’s aviation medicine competency, research capability and global reputation for excellence and leadership.”

Headcount of currently over 30 full time equivalent staff could be reduced to eight if outsourcing plans go ahead and the service operates at its minimum regulatory duties.

Last year’s preparations for the outsourcing included an event in May open to providers through the NHS Partner’s Network of the NHS Confederation at which one was an NHS provider, but all others were private sector contracting organisations.

The Public and Commercial Services Union believes there is no provider which could fill the gap if the CAA stops providing its services in the current form. They said:

“We are requesting that this consultation be halted and consultation commences with the recognised trade unions on options within this paper to retain all existing services in-house.”

In April, the CAA said: “We are continuing to explore options for the future provision of medical services. Safety remains our number one priority and we will ensure that any changes that are made will be designed to enhance the UK’s excellent safety record. All medical requirements relating to pilots are set at international level and regulated nationally and will remain in force and unchanged regardless of any decisions relating to the provision of medical services in the future.”

Mr Haines,  explained at the April Board Meeting that “there would be a further discussion at the Board on the outcome of the CAA’s medical review consultation.” What that was is yet to be published. Transparency has not been the board’s strongest point in 2015.

Consultations are about allowing the public a chance to participate in democratic processes in order to play their part in determining the outcome. This consultation appears to have changed little of the plans.

There should be public debate around what we need our service institutions for, what value we place on a universal public good where cost and benefit cannot be personalised, and where change requires meaningful public consultation.  These changes are too important to be reserved for niche interested parties or for them to be a tick box exercise in which the planned outcome goes ahead regardless of the majority feedback. Public consultation in its present form, appears to offer little in the way of checks and balances in today’s democracy. Some are described as farcical.

Changes made in the public interest should be transparent, accountable, and robust to stand up to meaningful challenge.

As the Treasury seems set on its course, I wonder if they are using blue sky thinking to divest from our wealth of knowledge, staff and skills wisely, or plucking justification for ideology out of thin air?

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References:

[1] Responses to consultation on the future structure of the CAA’s Medical Department: http://www.caa.co.uk/docs/33/CAP%201276%20Future%20structure%20of%20CAA%20Medical%20Department.pdf

[2] The prior information notice: http://ted.europa.eu/udl?uri=TED:NOTICE:99734-2015:TEXT:EN:HTML  (not yet a full tender notice)

[3] Financial detail limited: https://www.caa.co.uk/default.aspx?catid=1350&pagetype=90&pageid=16369

[4] CAA independent but accountable to Department of Transport http://www.parliament.uk/business/publications/written-questions-answers-statements/written-question/Commons/2014-09-10/209031

[5] Autumn 2015 consultation part two

George and the Chinese Dragon. Public spending and the cost of dignity.

George Osborne has told departments to prepare plans for cuts of 25% and of 40% in non ring-fenced funding. What sacrifices will he ask society to make if public spending is to be further cut back?

The percentage of people wearing pristine white trainers was  unusually high in the international hotel chain’s breakfast room.

Most of the men fetching two adult breakfasts from the vast buffet wore cream coloured chinos, and button down shirts, and sported  standardised haircuts with hints of silver. Stylish women sat at  impeccable tables, cradling  babies in pink hats or spoon feeding small children.

On a busy street in downtown Guangzhou close to the Chinese embassy, the hotel was popular with American parents-to-be.

My  colleague explained that her sadness over thousands of Chinese daughters exported from a one-child policy nation in 2005 was countered by the hope that loving foreign families were found for them.

She repeated with dignity, party mantras and explanations drilled at school. She has good job, (but still she could not afford children). Too little land, too few schools, and healthcare too expensive. She sighed. Her eyes lit up as she looked at my bump and asked if I knew “girl or boy?” If it were a girl, she added, how beautiful she would be with large open eyes. We laughed about the contradictory artificial stereotypes of beauty, from East and West, each nation wanting what the other did not have.

Ten tears later in 2015, British Ministers have been drawing on China often recently, as a model for us to follow; in health, education and for the economy. Seeking something they think we do not have. Seeking to instill ‘discipline, hard-working, economy-first’ spin.

At the recent ResearchEd conference, Nick Gibb, [1] Minister of State at the Department for Education, talked about the BBC documentary “Are Our Kids Tough Enough” for several minutes and the positive values of the Chinese and its education system. It supposedly triggered ‘a global debate’ when British pupils experienced “the harsh discipline of a Chinese classroom”.

The Global Times praised the  First Minister Mr. Osborne as “the first Western official in recent years who focused on business potential rather than raising a magnifying glass to the ‘human rights issue” during his recent visit [2] when he put economic growth first.

Jeremy Hunt, Secretary of State for Health, was quoted at the political party conference  saying that he saw tax cut changes necessary as a cultural shift.  He suggested we should adopt the ‘hardworking’ character of the Chinese.

An attribute that is as artificial as it is inane.

Collective efforts over the last year or more, to project ‘hard-working’ as a measure of contribution to UK society into politics has become more concentrated, especially around the election. People who are not working, are undermined by statements inferring the less productive for the nation, the less value someone has as a person. Comments are repeated in a sustained drip feed, from Lord Freud’s remarks a year ago that disabled workers were not worth the full wage, to Hancock’s recent revelation that the decision to not apply the new minimum wage to the under 25s from 2016 “was an active policy choice.”  Mr. Hunt spoke about dignity being self-earned, not dependent on richness per se, but being self-made.

“If that £16,500 is either a high proportion or entirely through the benefit system you are trapped. It matters if you are earning that yourself, because if you are earning it yourself you are independent and that is the first step towards self-respect.”

This choice to value some people’s work less than others and acceptance of spin, is concerning.

What values are Ministers suggesting we adopt in the relentless drive for economic growth? [3] When our Ministers ignore human rights and laud Chinese values in a bid to be seen as an accepting trading partner, I wonder at what cost to our international integrity?

Simple things we take for granted such as unimpeded internet  access are not available in China. In Chinese society, hard working is not seen as such a positive value. It is a tolerated norm, and sometimes an imposed one at that, where parents leave their child with grandparents in the countryside and visit twice a year on leave from their city-based jobs. Our Ministers’ version of hardworking Chinese is idyllic spin compared with reality.

China is about to launch a scheme to measure sincerity and how each citizen compares with others in terms of compliance and dissent. Using people’s social media data to determine their ‘worth’ is an ominous prospect.

Mark Kitto from 2012 on why you’ll never be Chinese is a great read. I agree, “there are hundreds of well-rounded, wise Chinese people with a modern world view, people who could, and would willingly, help their motherland face the issues that are growing into state-shaking problems .”

Despite such institutional issues, Mr. Osborne appears to have an open door for deals with the Chinese state. Few people missed the announcements he made in China that HS2 will likely be built by Chinese investors, despite home grown opposition. Ministers and EDF have reportedly agreed on a controversial £25bn development of Hinkley Point C, nuclear plant, with most of upfront costs provided by Chinese companies, although “we are the builders.” [4]

Large parts of utilities’ infrastructure is founded on Chinese sourced spending in the UK it’s hard to see who ‘we’ are meant to be. [5] And that infrastructure is a two-way trade. Just as Chinese money has bought many of our previously publicly owned utilities, we have sold a staggeringly long list of security related items to the Chinese state.

In July 2014 the four House of Commons Select Committees: “repeated their previous Recommendation that the Government should apply significantly more cautious judgements when considering arms export licence applications for goods to authoritarian regimes which might be used for internal repression.”  [6]

UK to China exports
Chris Patten, former Hong Kong Governor,  criticised Osborne’s lax attitude to human rights but individual and collective  criticism appear to go unheard.

This perhaps is one measure of British economic growth at all costs. Not only is Britain supplying equipment that might be used for internal repression but the Minister appears to have adopted a singularly authoritarian attitude and democratic legitimacy of the Committees has been ignored. That is concerning.

The packaging of how upcoming cuts will be presented is clear.  We will find out what “hard working families” means to the Treasury. We need to work harder, like the Chinese, and through this approach, we will earn our dignity. No doubt rebuilding Britain, on great British values. Welfare will continue to be labelled as benefits, and with it, a value judgement on economic productivity equated with human worth. Cutting welfare, will be packaged as helping those people to help themselves out of self inflicted ‘bad’ situations, in which they have lost their self worth or found an easy ‘lifestyle choice’.

As welfare spending is reduced, its percentage spend with big service providers has risen after reforms, and private companies profit where money was once recycled in the state system. There is a glaring gap in evidence for some of these decisions taken.

What is next? If for example, universal benefits such as Universal Infant Free School Meals are cut, it will take food literally from the mouths of babes, in families who cannot afford to lose hot school dinners, living in poverty but not qualifying for welfare. The policy may be flawed because Free School Meals based on pupil premium entitlement does not cater for all who need it, but catering for none of them is not an improvement.

Ministers focus the arguments of worth and value around the individual. Doctors have been told to work harder. Schools have been told to offer more childcare to enable parents to work harder. How much harder can we really expect people to work? Is the Treasury’s vision is for us all to work more to pay more taxes? It is flawed if by adopting the political aim, the vast majority of people take home little more pay and sacrifice spare time with our friends and loved ones, running our health into the ground as a result.

The Chinese have a proverb that shows a wisdom missing from Ministers’ recent comments: “Time is money, and it is difficult for one to use money to get time.”

I often remember the hotel breakfast room, and wonder how many mothers, in how many in cities in China miss their daughters, whom they could not afford to keep, through fear of the potential effect. How many young men live without women in their lives who would want to, but find the gender imbalance a barrier to meeting someone. How many are struggling to care for elderly parents.

Not all costs can be measured in money.

The grandmother I met on the station platform last Wednesday had looked after her grandchild for half the day and has him overnight weekdays, so that Mum can first sleep and then work a night shift stacking shelves. That’s her daughter’s second shift of the day. She hardly sees her son.  The husband works the shelf-stacking third shift to supplement his income as a mechanic.

That is a real British family.

Those parents can’t work any harder. Their family is already at breaking point. They take no state welfare.  They don’t qualify for any support.

Must we be so driven to become ‘hard working families’ that our children will barely know their parents? Are hungry pupils to make do as best they can at lunchtime? Are these side effects children must be prepared to pay if their parents work ever harder to earn enough to live and earn their ‘dignity’ as defined by the Secretary of State for health?

Dignity is surely inherent in being human. Not something you earn by what you do. At the heart of human rights is the belief that everybody should be treated equally and with dignity – no matter what their circumstances.

If we adopt the Ministers’ be-like-the-Chinese mantra, and accept human dignity is something that must be earned, we should ask now what price have they put on it?

MPs must slay the dragon of spin and demand transparency of the total welfare budget and government spend with its delivery providers. There is a high public cost of further public spending cuts. In order to justify them, it is not the public who must work harder, but the Treasury, in order to deliver a transparent business case what the further sacrifices of ‘hard working families’ will achieve.

 

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[1] ResearchEd conference, Nick Gibb, Minister of State at the Department for Education

[2] New Statesman

[3] https://www.opendemocracy.net/ournhs/jen-persson/why-is-government-putting-health-watchdogs-on-leash-of-%E2%80%98promoting-economic-growth

[4] The Sun: George Osborne party conference speech with 25 mentions of builders: “We are the builders”, said Mr. Osborne.

[5] Arms exports to authoritarian regimes and countries of concern worldwide The Committees

[6] The Drum: Li Ka Shing and British investment

[image: Wassily Kandinsky ca 1911, George and the Dragon]