Dos and don'ts in preparing a special issuance (waiver) packet

August 19, 2013

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Warren Silberman

Warren Silberman

  • Former Manager, FAA Aerospace Medical Certification 
  • Doctor of Osteopathic Medicine 
  • Expert in Aerospace/Preventive Medicine 
  • Pilot since 1986

If you develop a medical problem during the time period that your current FAA medical certificate is in effect, you need to go to AOPA's Medical Certification section and see if the condition will require a special issuance waiver. You also can check the Guide for Aviation Medical Examiners on the FAA's website. Now that it is online and is regularly updated, this is a great resource in addition to the AOPA website.

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Obtain all the required medical records from your physicians. If you had surgery, obtain the operative report. If the surgeons removed any tissue, obtain the pathology report on the analysis of the specimen. If you were hospitalized, obtain the hospital admission, discharge summaries, and any consultation reports that physicians performed. Based upon the specifics of your condition, the FAA may request additional information later. AOPA’s Pilot Protection Services is a marvelous resource for pilots in this situation and can save you lots of time and frustration in your dealings with the FAA. You definitely should speak to the medical certification specialists and, if indicated by the specialist, join the Pilot Protection Services program to receive specific guidance for your particular situation.

The FAA requires “current information,” meaning the reports and evaluations can be no older than 90 days when the FAA receives them.  A word to the wise: Get all the evaluations and tests just as the FAA requests! Do not attempt to cut corners. Do not allow your treating physician to convince you that “FAA doesn’t need that for your condition,” do some other test, or have the test performed in a fashion that’s different from the way the FAA has requested without at least checking with AOPA's medical certification specialists or calling customer service at the FAA's Aerospace Medical Certification Division. There are aeromedical reasons why the FAA wants the tests done in a particular way; not providing exactly what is requested will absolutely delay the issuance of your medical, and may result in an outright denial. Also, the FAA will always accept any testing over and above what they asked for. For example, if you are asked to provide a “plain” Bruce protocol exercise stress test and your doctor decides to do a more sensitive nuclear exercise perfusion scan, the FAA will accept that more sensitive test for medical certification consideration.  

Do not send anything to the FAA until you can send everything that’s required. Sending in an incomplete packet will result in delays. The FAA letter may include a specification sheet that details exactly what they want to see, so I recommend using that sheet as a checklist and marking off each item as you complete it. 

The FAA cannot work a special issuance request unless you have a current medical application on file. The FAA application is valid for as little as six months for a first class medical and as long as 60 months for a third class medical. It is generally a good practice to apply for the lowest class of medical required for the privileges you plan to exercise. It’s possible that your medical application will expire before the FAA reviews your case and clears you for a new medical. If that happens, you will receive a letter informing you that you may submit a new application and see your AME for a new FAA physical examination for the class that you require. The AME will be authorized to issue you a certificate at the time of examination.

One last reminder is an "airman regulation," Part 61.53, which in simple English tells the airman that he or she should not fly if that person has a known medically disqualifying condition or is placed on a known disqualifying medication, treatment, or therapy.

Learn more about the AOPA Pilot Protection Services program.