SI Authorization Letter Interpretation

Introduction to the Airman Medical Certification Process —SI Authorization Letter Interpretation

SI Authorization Letter InterpretationThe Federal Aviation Regulations, Part 67, Subpart E, allows the Federal Air Surgeon latitude to consider persons with serious medical conditions for a discretionary medical certificate, or special issuance authorization. An authorization is required when the applicant for medical certification is considered unable to meet the medical standards prescribed in Subparts B, C, and D of Part 67.

A discretionary issuance carries with it additional requirements for more frequent reevaluation and testing to determine that the condition for which the authorization is issued has not progressed to a point that public safety will be endangered during the time the authorization is in effect. An authorization differs from a Statement of Demonstrated Ability (SODA) in that a SODA is issued for a disqualifying condition that is static or non-progressive, such as a loss of vision in one eye or limb amputation.

Even though an Authorization may require reexamination every six or twelve months, the date of renewal of your FAA medical application and physical examination does not change.  It is still required every six months if age 40 or older, or every 12 months if under age 40 for a First-class medical; every 12 months for a Second class medical for all ages; and every two years if age 40 or older, or every five years if under age 40 for a Third-class medical.

Following is the text of an FAA Authorization letter with explanation and interpretation (in italics) of what the authorization is stating.

Dear Mr. Member:  PI# 100111

I have reviewed the information submitted by you in support of your request for an airman medical certificate.  The medical evidence reveals a history of myocardial infarction and coronary artery disease requiring coronary artery bypass surgery.  You are ineligible for third-class medical certification under Section 67.111(a) (1) (3), 67.211(a) (c), and 67.311(a) (c) of the Federal Aviation Regulations (FARs).

The letter must state the medical history presented to the FAA.  Because of the disqualifying conditions, the medical regulation that makes the condition disqualifying must also be stated.  Section 67.111 details the requirements for a First class medical, 67.211 for Second class, and 67.313 for Third.  The parenthetical numbers refer to the specific medical condition, in this case, myocardial infarction and coronary heart disease.

However, based on the complete review of the available medical evidence, I have determined that you may be granted authorization for special issuance of Third-class airman medical certification under Section 67.401 of the FARs.

Your Aviation Medical Examiner is authorized by this letter to issue you a third-class medical certificate bearing the limitation “NOT VALID FOR ANY CLASS AFTER APRIL 30, 2008” provided you are found to be otherwise qualified.

Despite your disqualifying condition, the Federal Air Surgeon has found that your current medical condition does not put you at an unacceptable risk that would endanger public safety during the time the authorization will be in effect (April 14, 2007 through April 30, 2008).  For our purposes, assume this pilot’s last FAA medical examination was more than two years ago, and he will be reapplying for a new medical with his AME this month.  It is usually best to undergo a current FAA flight physical at the same time you are providing the FAA with medical records in support of a special issuance request.  That way, the periodic reexamination (usually at yearly intervals) will come in the same month that your regular FAA medical examination is due according to FAR 61.23.

This Authorization expires on April 30, 2008.

Only the authorization expires one year from now.  The FAA physical examination done by your AME is still valid for twenty-four or thirty-six months as specified in 61.23, so you will not need to go back to your AME until April, 2008. (Assume also that this pilot is over age 40 and requires a new medical examination and application every 24 months.)

Consideration for a new Authorization will be contingent upon the following, performed in accordance with the enclosed specifications:

On or about March 1, 2008:

  1. A current cardiovascular evaluation and current lab work.
  2. A current radionuclide scintigraphy exercise stress test.

If there have been no significant adverse changes in your medical status, you have complied with all conditions of certification described in your Authorization, and I am satisfied that the duties permitted by our medical certificate can be performed without endangering public safety, the Medical Appeals Branch may then grant you a new Authorization for an additional time.  You will still be required to have your regular third-class physical examination at the frequency prescribed under the provisions of CFR 61.23.

In order to avoid a lapse in certification, the necessary testing should be completed near the date noted above and forwarded in one package to the following office.

Medical Appeals Branch, AAM 320
Aeromedical Certification Division
FAA Civil Aeromedical Institute
Post Office Box 26080
Oklahoma City, OK 73126
Medical Appeals Branch, AAM 320
Aeromedical Certification Division
FAA Civil Aeromedical Institute
6700 S. Mac Arthur Blvd. B-13
Oklahoma City, OK 73169

The FAA will allow you to send your renewal information up to 90 days prior to the expiration date of the authorization.  Even though the letter indicates 60 days is enough lead time, we suggest you take the full 90 days to allow for delays in getting testing done, receiving final reports from the doctor’s office, and other last minute delays that always seem to pop up.  Make copies of everything for your own files in case something gets lost, which does happen occasionally.  Send the information yourself; don’t depend on someone else to get the information to the FAA.  Either address will work, but the best way to send information is by overnight or registered mail to the South Mac Arthur Blvd. address.  Regular first class can go to the PO Box number.

You must promptly report any adverse changes in your medical condition to the FAA Medical Appeals Branch, AAM 320.

Because your medical is at the discretion of the Federal Air Surgeon, there is an implied “automatic invalidation” of the authorization if you have an “adverse” change in your medical condition.

Use of the above reference number and your full name on any reports or correspondence will aid us in locating your file and expediting a reply to you.

Sincerely,

Warren S. Silberman, D.O.
Manager, Aeromedical Certification Division
Civil Aeromedical Institute

           
Be sure to use the PI number assigned you at the top of the letter.  This is your unique ID for the FAA to identify you among the one million-plus medical records on file. 

 

Updated October 27, 2009