Pilots are often frustrated when their aviation medical examiners (AMEs) tell them that the protocols that we must comply with at the time of the FAA exam are just a bit different than how we handle things between FAA exams. This can be confusing for everyone involved.
At the time of the exam, a pilot must meet all aeromedical standards. These are outlined in FAR Part 67. These standards are then referenced in various FAR sections and in the general information sections throughout the FAA website. All of this information is available to pilots.
The medical standards include hard and fast, measurable parameters for things such as vision and hearing. The FAA is further given the mandate and authority to rule on any medical condition that it deems relevant to aviation safety. Also included in the FARs are protocols to determine how to proceed toward a special issuance authorization of a medical certificate when a formally disqualifying diagnosis is discovered in a pilot.
The ”specifically disqualifying” diagnoses include cardiac disease requiring treatment, diabetes requiring medication, substance abuse and dependence, and several other conditions, including neurological and psychiatric. There are only 15 specifically disqualifying conditions noted in the regulations.
The “generally disqualifying” conditions include any and all of the many thousands that exist, not referenced specifically in the regulations, but in the opinion of the FAA might compromise aviation safety. Some of these include kidney stones, sleep apnea, thyroid disorders, cardiac arrhythmia, blood clots, glaucoma, and countless others.
Other than for a few permanently disqualifying conditions such as epilepsy (a seizure disorder that is ongoing and recurrent) and certain psychiatric disorders such as bipolar disorder, for most other conditions, once the pilot is recovered and stable, FAA medical certification is possible through the special issuance protocols. As I have noted previously, over 99.9 percent of pilots applying for a medical certificate will ultimately be approved, even if some do require a comprehensive evaluation process.
As an aside, and a topic for another discussion, many mood disorders such as depression requiring medication have been approvable for many years through the special issuance process.
At the time of the exam, a pilot must meet all applicable standards—and, if needed for a previously disclosed concerning diagnosis, have an FAA authorization letter permitting the AME to issue the certificate.
In essence, the pilot must be fully capable of leaving my office with their coveted new medical certificate and going straight to the airport to fly a trip. I cannot issue a medical certificate to a pilot who does not meet all of the standards but states that they should do so soon. Pilots on occasion have argued that it is acceptable for me to issue a medical certificate in advance of their achieving “stability” of a medical condition in question because they “are on vacation” and won’t fly until the condition is improved. It doesn’t work that way.
I have had pilots arrive at my office, limping on crutches with a cast on one of their legs. They tell me that they need their medical now because they want to fly as soon as the orthopedist or podiatrist removes the cast and affirms that the pilot has normal strength and range of motion. I reluctantly inform these pilots to return to my office once they have fully recovered and could actually operate the controls of the aircraft and participate in an emergency evacuation if it were to be needed.
A frustrating and more complicated example of this for pilots is to arrive for an FAA exam having recently had a cardiac stent placed. The pilot jubilantly tells the AME that the cardiologist said they are “good to go.” However, neither the pilot nor the cardiologist knew that cardiac disease requiring treatment is a specifically disqualifying condition that requires a formal waiting period before even beginning the follow-up testing and application process for a special issuance authorization.
Another simpler example is that of a pilot who very clearly does not meet the vision standards but tells me they have new glasses on order. I again, reluctantly, inform the pilot to return when they have their new glasses.
There are no provisions in the regulations that permit an AME to enter an exam that shows that the pilot did not meet the standards but that their healthcare provider “promises” they will soon. Any AME who issued a certificate in that kind of circumstance would very quickly receive a call from the FAA to discuss what the heck the AME just did.
If a pilot is on the “sick list” for severe sinusitis or other respiratory infection and obviously could not act as a crewmember until recovered, they should not present to their AME’s office expecting to have a medical certificate issued. The pilot should also wait until they have recovered.
While it is clear that, at the time of the FAA medical exam, there is not much “slack” available in the AME’s decision-making process, what happens between medical exams? The pilot is not going to be in touch with their AME every day and may not need their next FAA exam for another six, 12, or 24 months—or even up to five years in some cases—depending on their age and the class of medical certificate they need.
A pilot is expected to medically self-assess at all times, as per the general guidelines in FAR 61.53 (prohibition on operations during medical deficiency). Somewhat similar to FAR 91.3 (responsibility and authority of the pilot in command), these are brief yet powerful and all-encompassing directives. A lot of responsibility is placed directly on the pilot. A pilot must determine if they are fit to fly on any given day.
You will notice that FAR 61.53 does not mention the FAA itself, the pilot’s AME, or any outside consultants. The pilot must determine if they are fit to fly. While at times it is prudent for the pilot to seek the counsel of their treating physician, AME, or consulting aeromedical advisor, the ultimate decision is placed on the pilot as to whether they are fit to fly.
The AME’s decision at the time of the FAA exam is “regulatory.” In fact, the actual exam is the only time that an AME’s opinion is regulatory. At all other times, the AME’s opinion, along with opinions from outside consultation services, are advisory only. The FAA, however, can issue a formal opinion at any time. That opinion is the final word and is regulatory.
In the next blog in this series, I will explain how we deal with some of the questions and nebulous situations that arise, which can at times be confusing to the pilot, the AME, and even to the FAA.
An important take-home point is that the formal medical standards and FAR 61.53 always apply. Please take your responsibilities to aeromedical ethics seriously, because you could be challenged if something happens that brings your medical qualifications into question.
Dr. Robert Sancetta is a former DC-10 captain with 11,000 flight hours. He has worked as a Senior AME since 1993 and is appointed as AME Consultant to the FAA Federal Air Surgeon.
The opinions expressed in this column are those of the author and not necessarily endorsed by AIN Media Group.