In February, I discussed aspects of the FAA medical standards as outlined in FAR Part 67. Considerations of how the FAA applies these standards were also introduced, along with the FAA’s general mandate to adequately ensure the safety of flight. The FAA has the prerogative to review, consider, and at its discretion formally rule on virtually every medical condition that is presented to it, along with upholding the numerous cut-and-dry standards that exist in the regulations.
The differences between the “specifically disqualifying” and “general disqualifying” medical diagnoses are also important to understand. Remember that a specifically disqualifying condition requires documented stability (meaning to the FAA’s satisfaction) and the granting of a “special issuance authorization” before resumption of flight status.
A take-home point is that the aviation medical examiner (AME) has very little flexibility at the time a pilot applies for a medical certificate. All medical requirements must be met at the time of examination. If a medical condition is not “stable,” it potentially limits the AME’s ability to issue a medical certificate.
For the AME to be able to issue the certificate, a pilot must be stable, feel “fit to fly,” meet all applicable medical standards, and essentially be qualified to leave the AME’s office and immediately fly a trip as a required crewmember.
But what do we do between FAA medical examinations? It might be six to 12 months before a professional pilot next visits the AME. What do we do with medical conditions that arise in the interim? This is where a confusing combination of regulations, artistry, flexibility, and common sense comes into play.
If a pilot does not feel fit to fly, it is that pilot’s responsibility to follow FAR 61.53 and remove themselves from flight status for the time being. If the circumstances are confusing to the pilot, they may also seek advice from their AME or any aeromedical consultants.
How does the pilot know when it is OK to return to work after a medical situation?
If the pilot simply had the flu, an ear infection, or other minor and self-limited illness, then typically that pilot may return to work once feeling improved. I remind all pilots to be ethical about this and to avoid exposing fellow crewmembers or passengers to any illness that might still be contagious.
Once fully recovered after an orthopedic or hernia surgery, typically the pilot does not need to be cleared by the FAA before returning to work. That said, a complicated spinal procedure that was necessitated due to serious neurological complications of a back injury, for example, should be reviewed with the pilot’s AME or outside aeromedical advisors. Use some common sense here. Any surgery definitely should be reported at the pilot’s next FAA examination.
What about conditions that will require a special issuance authorization?
As previously noted, if the condition was specifically disqualifying (diabetes or heart disease requiring treatment, cardiac valve replacement, substance abuse or dependence, to name a few), then the pilot would need to be cleared per a special issuance authorization before resuming flying (even if the illness was successfully and fully treated in the interim between scheduled FAA examinations).
There are also numerous generally disqualifying conditions that must be reviewed and approved by the FAA before the pilot’s next medical certificate can be issued. Common examples include cardiac arrhythmia (atrial fibrillation and its cousins), certain cancers, any condition that requires long-term anticoagulation (blood thinners), and a host of others. An educated opinion from the AME or aeromedical advisor is useful in these situations.
Somewhat in a class of its own is obstructive sleep apnea. Once the pilot is stable on their treatment, most cases of sleep apnea can be reviewed and approved by the AME without waiting for the FAA to give its blessing, even though this condition will then be followed under special issuance.
Afterward, upon reviewing the data, the FAA will usually grant a special issuance authorization that formally outlines follow-up requirements. This is one of the few conditions that will ultimately require a special issuance when the AME can issue the initial medical certificate to that pilot without waiting for the FAA review process.
As with many other special issuance conditions, typically the future issuances simply require the AME to review appropriate data, issue the certificate, and then send the data to the FAA afterward.
For the specifically disqualifying conditions, after the initial special issuance is granted, the usual protocol is that the (typically annual) recurring medical data must be sent to the FAA well in advance of the pilot’s next medical examination. The FAA reviews that data and—hopefully—grants an updated authorization before the next examination date.
This procedure, while annoying, cannot be avoided for a number of medical conditions. As tedious and frustrating as this may be, for the most part, the pilot will continue to fly without further interruption.
A disappointing pitfall that is sometimes encountered is when a pilot has a new medical condition, one that is considered treated and stable by the healthcare providers involved in the actual care, and the pilot is then surprised when the AME states that they cannot yet issue the medical certificate when the pilot arrives for their scheduled FAA examination.
Whether the condition requires a formal special issuance or not, the pilot simply did not know that there would be complications before their next medical certificate could be issued. This is where an interactive AME or aeromedical consultant could have been used for some proactive advice.
To issue the certificate, sometimes the AME simply may need to obtain appropriate documentation (examples include kidney stones or glaucoma) and then the medical certificate can be issued without delay. Other times, the AME must give the pilot the unfortunate news that they need to wait for a special issuance to be granted by the FAA before the AME can issue the certificate.
As is no secret, waiting periods for FAA reviews can take several months. If the AME had known about the condition in advance of the medical certificate examination date and submitted the requisite documentation to the FAA, sometimes the special issuance authorization is received in a timely fashion, thereby reducing or eliminating the delay for the pilot to receive their subsequent medical certificate.
This further illustrates that if a pilot has a question about their upcoming certification, obtaining some sage advice proactively is a good idea. I am not intending to berate pilots, but rather to offer some timely advice.
I have also had pilots who were quite surprised when I could not issue their medical certificate at the time of the exam, appealing to me, “I reported the condition (or medication)” on their application. One problem with the application process—beginning years ago with the old-fashioned written forms and continuing to this day with the online MedXpress platform—is that simply reporting a condition or medication does not inform the pilot proactively that things are suddenly more complicated and that there are potentially hoops to jump through.
The FAA cannot, of course, know in advance what new medical conditions a pilot might experience. However, at the time of the MedXpress application, it seems to me that it would not be too difficult to at least give the pilot a bit of advance warning that there may be work to be done, based on some keywords that the pilot enters. I continue to lobby for this enhancement to the process.
To the agency’s credit, the FAA website has been improved to make information on medical conditions and medications a bit more accessible to pilots. Sometimes it takes some patience to find what is being searched for, but the amount and clarity of the information has been greatly amplified in recent years.
One improvement that is great for both pilots and AMEs is that there are more thorough explanations regarding the type of documentation that will be required for a given medical condition and whether the AME can issue the medical certificate or not. Sometimes the website clearly states that an “FAA decision is required,” but at least we can find that out beforehand. This holds true also for medications (to be discussed further in my next blog).
In Part 3 of this series, I will discuss what we do when it is noted on the review of required documentation that an additional medical condition or medication that will raise the proverbial eyebrows at the FAA is uncovered. Sometimes the pilot knew about the situation but genuinely felt that it would not be concerning, and other times the impact of the medical documentation seems to come as a surprise to the pilot.
And, dare I say, there have been times when a pilot simply hoped that nobody would find out about the other aspects of their medical status. I’ll provide some tips on how to make the reporting process just a bit less complicated and frustrating.
When medical complications occur, typically all is not lost. Regardless of how the medical condition(s) came to the attention of the AME, other than for a very few specifically disqualifying conditions, usually we can find a path to certification for the pilot. It might be a bit of a challenge—one that could involve a period of grounding—but in the majority of cases, the pilot eventually returns to the skies.
The opinions expressed in this column are those of the author and not necessarily endorsed by AIN Media Group.