VISABILITY (INC.) VISION GUIDELINES FOR DRIVING POLICY AND PROCEDURE

POLICY

1.0 INTRODUCTION AND SCOPE A person who drives when unfit to do so because of a vision impairment, places himself/herself, any passengers, and other road users at a serious safety risk. During the course of conducting VisAbility’s normal activities, staff have contact with people who have a vision impairment and have an opportunity to address with them, this important issue. This policy primarily applies to Vision Management staff.

2.0 STATEMENT 2.1 Information Provision - General VisAbility will ensure that it informs every new client of the risk of criminal and common law liability for anyone who drives and whose vision loss makes them unfit to do so.

2.2 Mandatory Reporting In accordance with the Western Australian Road Traffic (Authorisation to Drive) Regulations 2008 Part 4 r.65, Duty to reveal things that might impair ability to drive “If a person who holds a driver’s licence becomes affected by any driving impairment …the person is required, as soon as practicable, to inform the Director General in writing of the impairment”.

2.3 Information Provision - Specific If VisAbility knows of a client who is driving when unfit to do so, it recognises and concedes to the individual his/her legal duty to report his/her condition to the Department of Transport.

However, in such cases, VisAbility will take a pro-active approach and follow up by:  taking steps to address this issue with the person concerned;  advising his/her referring medical practitioner; and  maintaining documents as a record of these actions.

6 March 2014

Dr Clare Allen Effective Date Chief Executive Officer

First Adopted 2003: Reviewed May 2006; Aug. 2006; 2012, 2013

VisAbility (Inc.) 1 Vision Guidelines for Driving Policy and Procedure PROCEDURE

1. INTRODUCTION The following procedures support the provision of the Vision Guidelines for Driving Policy. They are to be implemented to ensure that appropriate steps are taken to help protect the safety of clients, other road users and pedestrians.

2.0 NOTIFICATION The following applies If a client assessed at the Low Vision Centre does not meet the Austroads guidelines and makes it known to a staff member that (s)he is still driving.

2.1 Low Vision Centre Low Vision Centre staff will provide the client with:

2.2.1 Client Notification A notification will be provided to the person (Appendix 1) that:  describes vision-related conditions that render a person unfit to drive; and  mentions the potential risk of insurance non-coverage; and  suggests a medical and / or social work follow up; and  informs the person that a form of photo ID is available as an alternative to a driver’s licence.

2.2.2 Mandatory Reporting of Medical Conditions Frequently Asked Questions Fact Sheet This Department for Planning and Infrastructure fact sheet may be obtained from the Department’s website (Appendix 4). It outlines: medical conditions that may affect the ability to drive safely and the responsibility of a person so affected to notify the Driver Licensing Authority.

2.2 Issued by the Service Co-ordinator The Service Co-ordinator will provide a feedback letter to people who are eligible VisAbility Services. The version provided will depend upon whether the person has accepted (Appendix 2) or declined (Appendix 3) receipt of VisAbility Services. A copy of the letter will also be provided to each person’s referrer/s.

The feedback letters can be modified, depending upon the specific circumstance, with text removed as appropriate. Appendix 2 includes a service plan and both letters will make reference to driving eligibility if VisAbility is aware that the person is driving when (s)he does not meet the Austroads Guidelines.

2.3 Senior Management Should a staff member deem an individual circumstance may warrant further escalation, then they should report the incident to the Executive Manager: Operations for investigation.

VisAbility (Inc.) 2 Vision Guidelines for Driving Policy and Procedure

APPENDIX 1 Vision Assessment and GUIDELINES for DRIVING

Dear ……………..

The rules about health and driving are developed by medical experts and agreed to by all Driver Licensing Authorities in the country.

Austroads guidelines1 state that a person is not fit to hold an unconditional license (private standards) –

 “if the person’s uncorrected visual acuity in the better eye or with both eyes together is worse than 6/12” (p.119)  “if the binocular visual field does not have a horizontal extent of at least 110 degrees within 10 degrees above and below the horizontal midline, or if there is any significant visual field loss (scotoma) within a central radius of 20 degrees of the foveal fixation or other scotoma likely to impede driving performance.” (p.120)  “if the person is monocular”. (p.120)  “if the person experiences any diplopia (other than physiological diplopia) when fixating

1 Assessing Fitness to Drive: for commercial and private vehicle drivers. Medical standards for licensing and clinical management guidelines March 2012 Austroads Publication No. AP-G56-12

VisAbility (Inc.) Vision Guidelines for Driving Policy and Procedure 3 Appendix 1 objects within the central 20 degrees of the primary direction of gaze.” (p.121)

We are bound to inform you that at today’s assessment (___/____/___) you did not meet the guidelines for driving as outlined above.

Your best corrected visual acuity was:

RE: ______LE: ______

Binocular (or Both Eyes Open): ______

Your field of vision (if relevant) was:

RE: ______LE: ______

Should you continue to drive and have an accident, when aware that you do not meet the guidelines, you could be ineligible for personal and/or third party insurance cover.

You may wish to discuss this with your Ophthalmologist or General Practitioner who may provide counselling, and in some circumstances may provide information to the Driver Licensing Authority, to determine whether a conditional licence is appropriate. You are urged to discontinue driving until you have spoken to your doctor and an application for a conditional licence has been approved.

VisAbility (Inc.) Vision Guidelines for Driving Policy and Procedure 4 Appendix 1 The Social Work staff of VisAbility for the Blind are also available to provide emotional support and practical advice, to assist you and your family overcome the problems associated with the loss of your driving licence. The staff are aware of various services and strategies that may assist with independent travel.

If you would like an alternative form of photo identification you may apply for a Proof of Age Card, available from the Department of Planning and Infrastructure - Licensing Services. If you have access to the internet a Proof of Age Card application is available to download from http://www.transport.wa.gov.au/licensing/21276.asp

Signed: ______OPTOMETRIST Low Vision Centre

Signed: ______CLIENT

VisAbility (Inc.) Vision Guidelines for Driving Policy and Procedure 5 Appendix 1 APPENDIX 2 17 March 2012

Mrs Jane Marple 16 Sunny Terrace Fremantle WA 6056

Dear Mrs Marple

Arising from our recent conversation, the following referrals have been made for services at our organisation. Staff will contact you to make arrangements.

A membership fee of $20 is payable at your first appointment.

Low Vision Centre assessment to determine your current level of vision and to look at aids to help improve your ability to read or to do other tasks: e.g. craft, watching TV.

An Occupational Therapy Visit in your home to provide practical advice and suitable equipment to safely perform everyday tasks. These might include: using the telephone, writing, shopping, working in the kitchen and using TV remotes.

An Orientation and Mobility Assessment to identify how we can best train you to move around confidently and safely, using low vision aids where appropriate. Training will address minimising risks, such as tripping, as well as how to use stairs, cross

VisAbility (Inc.) 6 Vision Guidelines for Driving Policy and Procedure Appendix 2 roads, travel independently and catch public transport to specific locations.

Social Work Support to provide emotional support, access care and community services or help you obtain pensions and other entitlements.

A Technology Assessment to look at a range of equipment that can help with reading or accessing information. This equipment may include electronic magnifiers or computer software for screen magnification.

Confident Living- Leisure and Recreation program. You will be contacted to discuss leisure options that might interest you such as: craft, discussion groups and sports activities.

Support Groups. We will contact you before these commence to see if you can attend. The Living Well Group provides information about eye conditions, how to make the most of your vision and available services that might help you. Safe without Sight covers strategies for personal safety, including simple self defence.

Talking Book Library provides a wide range of talking books and a regular large print crossword service.

A Travel Pass will be posted to you. The Taxi Users Subsidy Scheme information and application forms are enclosed.

VisAbility (Inc.) 7 Vision Guidelines for Driving Policy and Procedure Appendix 2 This section stays in letter if client has legal blindness According to the eye information we have received, you may be eligible for benefits, such as a pension. Information about this is enclosed, along with a copy of your eye information, should you wish to approach Centrelink or the Department of Veterans Affairs.

This section stays in letter if client indicates they are driving Please be aware that, according to the eye information provided to VisAbility, it appears you do not meet Austroads National Driving Guidelines. However, during our conversation, you have mentioned that you are still driving. Please discuss this with your doctor, who may support your application for a conditional license.

You are welcome to visit our onsite shop, where you might find something useful from our special range of aids and equipment for people with vision loss. Opening hours are Monday to Thursday 9.00am – 3.30pm, and Friday 9.00am – 12:30pm.

I have enclosed information about VisAbility services, and you are welcome to contact us on 9311 8202, should you require more assistance in the future.

Name……………. Service Coordinator cc: referrer VisAbility (Inc.) 8 Vision Guidelines for Driving Policy and Procedure Appendix 2 APPENDIX 3

17 March 2012

Mrs Jane Marple 16 Sunny Terrace Fremantle WA 6056

Dear Mrs Marple

During our recent conversation, we discussed VisAbility services, which you decided you did not wish to use at this time.

This section stays in letter if client has legal blindness According to the eye information we have received, you may be eligible for benefits, such as a pension, which is free of income test. Information about this is enclosed, along with a copy of your eye information, should you wish to approach Centrelink or the Department of Veterans Affairs.

This section stays in if the client is driving Please be aware that, according to the eye information provided to VisAbility, it appears you do not meet Austroads National Driving Guidelines. However, during our conversation, you have mentioned that you are still driving. Please discuss this with your doctor, who may support your application for a conditional license.

VisAbility (Inc.) 9 Vision Guidelines for Driving Policy and Procedure Appendix 3 You are welcome to visit our onsite shop, where you might find something useful from our special range of aids and equipment for people with vision loss. Opening hours are Monday to Thursday 9.00am – 3.30pm, and Friday 9.00am – 12:30pm.

I have enclosed information about VisAbility’s services, and you are welcome to contact us on 9311 8202 should you require assistance in the future.

Yours faithfully

Name Service Coordinator.

(cc. referrer)

VisAbility (Inc.) 10 Vision Guidelines for Driving Policy and Procedure Appendix 3 APPENDIX 4 The Government of Western Australia Department of Transport Frequently Asked Questions Mandatory reporting of medical conditions Q: What is Mandatory Reporting of medical conditions? A: Mandatory Reporting of medical conditions is the legislative requirement of all licence holders to notify the Department of any long term or permanent medical condition they suffer from, if they haven't previously notified the Department. Q: Why is medical mandatory reporting legislation in place in Western Australia? A: On 17 March 2008, Western Australia implemented the mandatory reporting of long term of permanent medical condition process which is a road safety initiative. The legislation was put in place due to recommendations made from a Coroner's inquest into the death of a WA driver. The death occurred when a Driver who was suffering from a medical condition which impaired their ability to drive, caused a traffic accident. Q: What constitutes a medical condition? A: Any physical disability or mental disorder that is likely to impair a person's ability to control a motor

VisAbility (Inc.) 11 Vision Guidelines for Driving Policy and Procedure Appendix 3 vehicle is what is referred to as a permanent or long term medical condition. A range of medical conditions, as well as certain treatments, may impair a person's ability to undertake the complex task of driving a motor vehicle. These conditions may impair the driver's perception, judgment, response time and reasonable physical capability. Some examples of conditions that do need to be reported are provided on our website. Q: I already do medicals for my driver's licence. Am I still required to advise Department of my medical condition? A: No, if you have already notified the Department in the past of your medical condition, you don't have to notify the Department again. Q: I did a medical assessment for my driver's licence previously; do I have to do another one? A: If you have already notified the Department in the past of you medical condition and completed a Medical Assessment Form (M107A) a Senior's Declaration Form (M108A) with your medical practitioner, you will not be required to notify the Department again. If you are currently required to undertake regular medical assessments with your medical practitioner as a condition of holding a driver's licence, these assessments will continue.

VisAbility (Inc.) 12 Vision Guidelines for Driving Policy and Procedure Appendix 3 The new Mandatory Reporting requirements will not have any effect on any scheduled assessments you may already have or require in the future. Q: Should I report a medical condition even if I have not experienced any symptoms for some time? A: Yes. You are required to inform the Department whether you have a long term medical condition that may affect your driving even if the symptoms are under control. In many instances, upon a health professional's advice, you would most likely be able to continue driving, but it is important that the information has been reported. Q: I only have a vehicle licensed in my name but not a current or valid licence. Do I still need to report a medical condition? A: No. Only valid Western Australian Driver licence holders need to report. Q: Do I need to complete the form if I have no medical condition to report? A: No. Q: I have only just recently completed a medical assessment for the Department; do I need to complete this form? A: If your condition or treatment has changed, since then, yes.

VisAbility (Inc.) 13 Vision Guidelines for Driving Policy and Procedure Appendix 3 Q: How will my insurance be affected if I don’t report my condition and have an accident? A: There may be ramifications however you will need to check with your individual private insurance company. Q: Will the Department provide the information to insurance companies? A: No. No information is given to insurance companies or third parties. Q: Will this make insurance premiums higher? A: You will need to check with your individual private insurance company. Q: Will I have to provide updates every year? A: Updates are required when there has been a change in your previously notified condition or treatment. It may or may not be a period of 1 year. Regular medical reviews or assessments may be requested by the Department. Q: I’m not sure if my medical condition is reportable? A: Please call 1300 852 722 or see your doctor to find out? Q: I need to wear glasses or contact lenses for driving; do I have to tell the Department?

VisAbility (Inc.) 14 Vision Guidelines for Driving Policy and Procedure Appendix 3 A: Yes, you are required to advise of your need to wear suitable visual aids whilst driving, if you have not previously notified the Department. These details will then be updated on your driver's licence. Q: When I report my medical condition, how will my licence be affected? A: How your licence is affected by the declaration of your medical condition depends on the condition itself and the action taken by the Department in determining your fitness to hold a driver's licence. You may be asked to: • Undertake a medical assessment with your health professional, or • Undertake a practical driving assessment, or • Your licence may be amended requiring you to only drive under certain circumstances, or • Your licence may not be affected at all. The Department will notify you in writing of the status of your licence. Q: How can I manage my driving if I have a medical condition? A: Your health professional may suggest limitations or restrictions to your driving, such as: • Daylight driving only • Driving an automatic car only • To take medication as prescribed • Wear suitable visual aids whilst driving.

VisAbility (Inc.) 15 Vision Guidelines for Driving Policy and Procedure Appendix 3 This acknowledges you are still medically fit to drive - but under certain conditions. In this situation, the Department will condition your licence and you will need to drive according to the restrictions or limitations that have been imposed. Q: How long will my licence be subject to conditions? A: It depends on your medical condition and how long it needs to be monitored. This decision will be reviewed if the Department receives advice from your medical practitioner as to the status of your condition. Prior to the renewal of your driver's licence, you may be required to undergo a medical assessment of your fitness to drive. Q: Who is a health professional? A: A health professional can include such people as a: • Doctor • Specialist • Occupational therapist • Physiotherapist. These people are qualified to check if you are medically fit to drive. If required, they will complete a medical certificate reporting on your fitness to drive and send it to the Department. Q: What will happen if I don't notify the Department?

VisAbility (Inc.) 16 Vision Guidelines for Driving Policy and Procedure Appendix 3 A: It is an offence not to notify the Department of your medical condition, and the penalty for committing this offence is currently $500.00 as at 1st January 2013. Q: Will I lose my licence? A: It is possible; however this is not the case in most instances.

VisAbility (Inc.) 17 Vision Guidelines for Driving Policy and Procedure Appendix 3