November 18, 2013
By AOPA Communications staff
Nov. 18, 2013
Contact: Steve Hedges
Frederick, MD – The Aircraft Owners and Pilots Association (AOPA) Monday expressed significant concern about the Federal Aviation Administration’s (FAA) proposed obstructive sleep apnea (OSA) policy and the adverse effects the policy will have on general aviation pilots.
AOPA will ask the FAA to suspend the implementation of the policy indefinitely because:
• The general aviation accident data does not support the new policy;
• No public comment period was offered;
• The policy will significantly add to the existing FAA medical certification backlog.
“The FAA has failed to demonstrate the justification for this proposed new policy when it comes to general aviation,” said Rob Hackman, AOPA’s vice president for regulatory affairs. “We object to the FAA’s apparent decision to make this policy without any sort of public comment period. The FAA is already staggering under the load of reviewing tens of thousands of medical applications from pilots working through the agency’s special issuance process. This new policy could add thousands of applications to that process, increasing wait times and delaying the FAA’s handling and issuing of medicals -- thus preventing pilots from flying.”
The proposed policy, as described by Federal Air Surgeon Fred Tilton in a recent FAA medical bulletin, would initially affect pilots who have a body mass index of 40 or more.
Those pilots, Tilton wrote, “will have to be evaluated by a physician who is a board certified sleep specialist.” Those diagnosed with OSA must be treated before they acquire a medical certificate, Tilton wrote.
Tilton also stated that, “we will gradually expand the testing pool by going to lower BMI measurements until we have identified and assured treatment for every airman with OSA.”
A person’s body max index is determined by dividing weight by height squared (in inches) and multiplying that amount by 703.Those with a BMI lower than 18.5 are considered underweight, with 18.5–24.9 normal weight, and 25-29.9 overweight and those over 30 are obese.
Apnea is a disorder in which breathing stops and starts during sleep, disrupting sleep and resulting in fatigue. Tilton writes in his memo that, “OSA inhibits restorative sleep, and it has significant safety implications because it can cause excessive daytime sleepiness, cognitive impairment,” and other issues.
Specifically, the FAA’s action follows a 2009 NTSB safety recommendation after the crew on an airline flight in Hawaii fell asleep during the flight. That flight resulted in a safe landing with no injuries or fatalities.
Using a data-driven process for its analysis of fatal GA accidents, the General Aviation Joint Steering Committee (GAJSC) Loss of Control Working Group found no evidence of sleep apnea as a causal or contributing factor in any of general aviation accidents it studied. AOPA is a member of that committee.
Air traffic controllers will also be included in the new scrutiny, Tilton wrote, but added that the FAA must overcome “logistical details” before it proceeds with controllers.
Since 1939, AOPA has protected the freedom to fly for thousands of pilots, aircraft owners and aviation enthusiasts. AOPA is the largest aviation association in the world. With representatives based in Frederick, Md., Washington, D.C., and seven regions across the United States, AOPA provides member services that range from advocacy at the federal, state, and local levels to legal services, flight planning products, safety programs and award-winning media products. To learn more, visit www.aopa.org.
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