Teaching without a medical
Flunking your flight physical doesn't have to ground you as an instructor
Believe it or not, some of us CFIs are getting a little long in the tooth and starting to worry about passing our next FAA flight physical.
To prepare for the physical, we try to lose a few pounds by exercising a little and cutting down on cheeseburgers and beer. And, of course, we get new glasses. On the day of the physical, as the doctor straps the blood pressure cuff around our arm, we imagine tranquil scenes with rainbows and bunny rabbits running through grassy fields. Most of the time this doesn't work, so we trot out our story about "white coat syndrome" and tell the doctor he's scaring us and that's why our blood pressure is elevated.
But even if we pass the physical this time, deep down we know that it's just a matter of time before we will no longer qualify for an FAA medical certificate. But many CFIs don't understand that a lost medical certificate doesn't automatically mean our instructing days are over.
I attended a convention of older pilots a few weeks back, and I was amazed at the number of CFIs in the crowd who were no longer actively teaching. There might have been millions of hours of combined flight time in that room, ranging from military aviation to airline flying to crop dusting - vast amounts of knowledge and experience that were essentially going to waste. I was even more amazed at the reasons these experienced pilots weren't teaching anymore. Some had liability concerns, but many said they had lost their medicals or could no longer qualify for a second class FAA medical. When I told them that they didn't need a second class - or, or for that matter, any medical certificate - to teach, they looked at me as if I were from another planet.
Let's take a close look at the medical certificate requirements for CFIs: Begin with FAR 61.3(c)(2)(iv.). It tells us that you are not required to have a medical certificate to teach, provided you are not acting as pilot in command or as a required pilot crewmember. This rule is repeated in FAR 61.23(b)(5) under "Operations not requiring a medical certificate."
Now, before you leap into the cockpit four days after a heart transplant, let's look at the type of instruction that you can legally conduct without a medical certificate. The FAA looks upon the CFI as a teacher, not a pilot, but if you don't possess a current medical certificate you can't be in a teaching situation where you must act as pilot in command. This means the person you are teaching must be fully qualified to act as PIC and current in the aircraft. Also, you can't be a safety pilot, but more about that later.
Under this regulation, you are not required to have an FAA medical certificate to give flight reviews, checkouts, or two of the three hours of the flight portion of the Wings program, assuming your student is qualified to act as PIC. You may also provide instruction toward the commercial and flight instructor certificates, or even toward a multiengine instructor rating, provided you do not have to act as PIC. And, obviously, you may give ground instruction or instruction in a flight simulator or flight training device without an FAA medical certificate.
You may not give private pilot training because the student is not qualified to act as PIC except when he or she is flying solo. If a pilot's flight review has expired, you may not legally give a flight review or training toward the FAA Wings program because you would be in a position of acting as PIC.
What about giving instrument instruction with the pilot using a view-limiting device? When giving hood time to a student, the CFI becomes a safety pilot and therefore is a required pilot crewmember. This means that you cannot provide instrument training without a medical certificate under simulated IFR conditions. However, you may give instrument training to an IFR-qualified and current pilot in actual conditions, assuming the pilot is fully qualified to act as PIC under these circumstances. No safety pilot is required in IMC, so the CFI is not a required pilot crewmember and there is no requirement for a medical certificate.
At the pilots' convention I mentioned earlier, there was an urban legend floating around that you needed a second class medical certificate to teach; some of the instructors there opined that you couldn't accept money for training without a second class medical. FAR 61.23(a)(3)(iv) tells us that a person must hold at least a third class medical certificate when exercising the privileges of a flight instructor certificate if the person is acting as the PIC or serving as a required pilot crew member. A second class medical isn't mentioned, nor is it noted in the eligibility requirements for flight instructors in FAR 61.183. There is no reference to the circumstances under which you cannot accept money for flight instruction.
This myth probably emerged from a seemingly logical thought process that starts with the requirement for a second class medical in order to be paid as a commercial pilot or ATP. Since you can't be a flight instructor without a commercial or ATP certificate, the reasoning goes, you can't accept money without a second class medical. The logic is sound, but it just isn't true. When you instruct, you aren't being paid as a pilot; you're being paid as a teacher.
I caution those who routinely apply for a second or even first class medical certificate when they don't require it. A friend of mine would always apply for a first class medical certificate although he only required a third class. He was a Rambo type who prided himself on his physical conditioning and relished a tofu and fruit diet. Once we went to the aviation medical examiner together for our physicals. He went for his traditional first class, and I opted for my normal third class, feeling lucky to get it. The AME discovered that my friend had a minor eye problem, and he was disqualified for a first class medical certificate. When you have a disqualifying condition, you are not just bumped down to the next lower class; you walk out of the doctor's office with no medical certificate at all. That day I got my third class, but my friend had no medical at all and had to reapply. The lesson learned here is not to apply for a class of certificate higher than you need. A third class is all that's required to be a flight instructor.
This should be good news to those of us who truly enjoy imparting our knowledge and experience in aviation to fledgling pilots and those looking to improve their skills. Even if you no longer qualify for a medical certificate, there are many opportunities to continue to practice your craft and actively contribute as long as you are able.
Richard Hiner retired from the AOPA Air Safety Foundation as vice president of training. He can be contacted at [email protected].
By Richard Hiner