Staying Certified

At some point during their flying years most pilots are faced with the fear of losing their medical certificate. This apprehension is reinforced by misconceptions about the intent of medical certification and the perceived complexity of the FAA bureaucracy. Many pilots and doctors do not understand the aeromedical standards, the potential impact certain medical problems can have on safe flying, or the ultimate certifiability of most medical conditions. However, it is the pilot's obligation to prove to the FAA that his or her medical disorder is acceptable in flight.

FAA medical certification process

The FAA is mandated to protect the public from medically unsafe pilots through the federal aviation regulations (FARs) and medical certification. The current "Medical Standards and Certification" regulations are found in FAR Part 67, which was extensively revised in 1996 (see " Jogging to a Different Medical Standard," May 1996 Pilot). The aviation medical program within the FAA is directed by the federal air surgeon in the Office of Aviation Medicine. A branch of that office, the Civil Aeromedical Institute (CAMI) in Oklahoma City, Oklahoma, is primarily responsible for the medical certification of airmen. The FAA physicians in Oklahoma City, together with regional flight surgeons, manage the national civilian aviation medical examiner (AME) system.

AMEs are practicing, licensed physicians. The AME makes the initial determination about whether an applicant meets the medical standards for the issuance of a medical certificate. It is important to remember that AMEdards for the issuance of a medical certificate. AMEs have authority to do only one of three things: they may certify healthy pilots, they may deny certification, or they may defer the certification decision to the FAA physicians in Oklahoma City. AMEs are authorized to conduct examinations for second and third class certificates, while senior AMEs may also evaluate applicants for first class medicals.

Certification of pilots with medical problems

Approximately 460,000 applications for airmen medical certification are received and processed each year. All applications, regardless of the results, are sent to the FAA's Aeromedical Certification Division in Oklahoma City. This office receives more than 2,000 applications per day. For healthy applicants without medical problems, this is the end of the certification process until the next examination is due. If, however, some abnormality is found during the examination, obtaining a medical certificate can become a frustrating and time-consuming process of working through bureaucratic obstacles. There is a processing delay of two to three months to review problem medical cases in Oklahoma City. Contrary to popular belief, the intent of the FAA is not to ground pilots for insignificant medical reasons. Yet, the FAA is obligated to ensure that pilots do not have a medical condition which may while operating an aircraft jeopardize the safety of the public and the pilot. The FAA wants pilots to be fit to fly at the time of their examination and for the specified duration of their certificate.

While some pilots will never be medically certifiable, there are certainly means by which most aviators with medical problems can safely return to the skies. Of the total number of applications received in Oklahoma City every year, only about 0.1 percent are given final denial of certification for medical reasons. However, the inherent complexity of the bureaucracy within the FAA, inadequate preparation of files, and administrative errors may all result in frustrating certification delays for the pilot who is not completely healthy. Ultimately, incomplete paperwork or failure to comply with the FAA's requests for additional supporting material — and not the pilot's medical condition — accounts for the majority of all denials and delays in medical certification.

The first step an applicant with a known or suspected medical problem should take is to carefully select an AME. The AME is a key player in medical certification. Some AMEs will defer applicants for even simple medical problems rather than expend the time and effort needed to assist pilots beyond the initial medical exam. Deferrals by their very nature will, at a minimum, result in time-consuming paperwork. An interested AME who is familiar with the requirements and expectations of FAA aeromedical regulations can work with the pilot and the FAA to obtain certification for even those pilots with a less-than-perfect physical examination. Aggressive and interested AMEs are best found by word of mouth. Local pilots and aviation organizations may be able to recommend an AME who is knowledgeable in the certification process and aviation medicine and also experienced in working directly with the FAA.

Sometimes it may be helpful to choose an AME who is also a pilot. Approximately half of the more than 5,000 designated medical examiners in the United States are pilots. An AME who is also a pilot may better understand an aviator's passion for flying and may be more willing to expend the extra time and effort to protect a pilot's medical certificate.

If an AME finds that an applicant is in less-than-perfect physical condition, he has the authority to issue a certificate, providing that the applicant adheres to certain limitations. The most common example of this is the requirement for glasses or contact lenses to correct poor vision. In this case, a limitation will be listed on the front of the medical certificate, stating that "the holder must wear corrective lenses." In some instances, a check flight may be required for an in-flight evaluation of a pilot with a medical or physical defect before a limitation is placed on the certificate. The limitation is a part of the medical certificate, and its conditions must be followed when flying.

Pilots with medical disorders that are not necessarily detrimental to safe flying may obtain a medical waiver or a statement of demonstrated ability (SODA). The SODA and waiver are means by which an applicant who does not meet the specific standards of FAR Part 67 may continue to fly. SODAs are granted at the discretion of the federal air surgeon — not by the AME — if a medical problem is static or nonprogressive, allows performance of airman duties without endangering public safety, and is not likely to cause impairment after the certification is granted. A SODA does not expire and, once granted, an AME may issue a medical certificate at subsequent examinations if the condition described on the SODA has not adversely changed.

Medical problems that are not severe but might interfere with performance of piloting duties by sudden and unexpected impairment, incapacitation, or distraction require that additional data be submitted to the FAA by either the pilot or his physician before a medical certificate can be issued. Examples of such medical problems include hypertension (high blood pressure), kidney stones, and ulcers. Each case is individually evaluated by the FAA. If the supplemental medical data shows that the medical condition is stable or well-controlled (for example, if approved medications keep the blood pressure of a hypertensive pilot within acceptable limits) and is acceptable in flight, then the pilot will be certified to fly.

This is an area where the AME may play a vital role in avoiding unnecessarily long delays in certification for relatively minor problems. Ultimately, obtaining the additional medical data for certification is the responsibility of the pilot. However, an AME willing to act on behalf of the applicant can make a big difference. Before the scheduled appointment, the applicant should determine from the AME or other informed sources what supplemental material will be necessary to obtain or retain a medical certificate for any known medical conditions. AMEs not knowledgeable in the expeditious handling of problem certificates may cause tremendous amounts of time to be lost waiting for the FAA to respond to submitted paperwork, only to learn that additional paperwork is needed to support the application. Ideally, the AME collects all the necessary data, organizes it in a neat file, and submits it to Oklahoma City in one package. By having the correct medical tests performed and obtaining the appropriate paperwork initially, much time can be saved when the FAA physicians review the file. Additionally, the AME should inform the pilot and his treating physician which medications are accepted by the FAA for treatment of specific medical disorders. If the medical problem is straightforward and the file is complete with acceptable medical data, the AME may actually be able to obtain certification from the FAA over the telephone, provided that the pilot's file is sent immediately to the FAA. If properly handled by the pilot and the AME, most of these certification problems can be resolved within a few weeks.

AOPA's Medical Certification Department may also be extremely helpful in avoiding unnecessary delays in these situations. Its specialists are available to answer most questions regarding the certification process. They also can anticipate what materials the FAA needs for various medical problems in advance of FAA requests. They will compile the necessary medical data into organized files for submission to the FAA with an explanatory cover letter. This is one of the most popular and sought-after services available to AOPA members.

Another organization working hard to help pilots with medical problems is the Civil Aviation Medical Association (CAMA). Comprised mostly of AMEs, CAMA emphasizes education of all AMEs so that they may become more comfortable with certification of tougher medical cases. It is hoped that this will decrease the number of deferred applications and thereby help to reduce the backlog in Oklahoma City. Senior AME members of CAMA who have expertise in handling problem medical certification issues are willing to act as consultants for other AMEs who may be less comfortable with these issues. If your AME wishes to defer your application, ask him or her to contact CAMA first.

An additional resource for pilots with medical problems is the Flying Physicians Association (FPA), members of which are physician pilots, many of whom are also AMEs. If necessary, AOPA's Medical Certification Department can put you in contact with AMEs who are members of CAMA or FPA and who have a very high success rate in obtaining medical certification for pilots with medical conditions requiring such assistance.

Preparation on the part of the pilot with a known medical problem is critical. Prior to the flight physical, the AME or an AOPA medical specialist should be contacted so that any required tests needed for specific medical problems can be obtained for the AME to review. Certification issues related to uncomplicated new or ongoing medical conditions can further be simplified by bringing a letter from the treating physician to the AME at the time of the flight physical. The treating physician should indicate in this letter that the medical problem of concern is under good control and not likely to cause incapacitation, that the results of recent supporting laboratory tests are acceptable (include results of all tests), and that any medications prescribed are not causing significant side effects. The timing of the medical should also be discussed to avoid "down time" resulting from FAA processing requirements. In most instances, with proper documentation, the AME will be able to issue your medical certificate at the time of the examination. In order to issue the certificate, the AME may need to call the regional flight surgeon or CAMI in Oklahoma City. A knowledgeable AME will not defer medical certification for simple medical conditions without at least making a call to Oklahoma City or the regional flight surgeon.

There are some medical disorders for which the AME must "mandatorily deny" medical certification to the applicant. Currently, the diagnosis of any of the following conditions disqualifies an applicant for a medical certificate of any class: diabetes mellitus requiring insulin, myocardial infarction (heart attack), angina pectoris or other signs of coronary heart disease, cardiac valve replacement, permanent cardiac pacemaker or other implanted cardiac devices, psychosis or bipolar disorder, behavioral or other mental disorders, seizures (epilepsy), disturbance of consciousness or transient loss of control of nervous system function without a satisfactory medical explanation, and substance dependence or substance abuse.

An airman who is medically disqualified for any reason may be considered by the FAA for grant of an authorization for special issuance of a medical certificate. The authority to grant a "special issuance" is delegated only to the federal air surgeon, the manager of the Aero-

medical Certification Division of CAMI, and each regional flight surgeon. The AME cannot grant a special issuance. Such a certification after denial may be issued to an applicant who does not meet the medical standards but can show that performance of the duties authorized by the class of medical certificate applied for will not jeopardize aviation safety. Approximately 1 percent of all medical applications, or about 4,600 per year, end with medical certification based on a special issuance. Remember that consideration for recertification may be given in the case of any disqualifying medical condition. In fact, authorizations have been granted for all classes of medical certificates and for almost all disqualifying conditions.

In order to determine if a special issuance can be granted, the FAA may authorize a special medical flight test, practical test, or medical evaluation. More medical data is almost certainly required. Although the FAA specifications and requirements are straightforward, failure to respond to the agency's requests is one of the most common reasons for delays in the recertification process. Again, help from an AME who is willing to put together an organized and complete package of requested materials will tremendously speed up a potentially lengthy process. The FAA also considers the class of medical certificate for which the pilot has applied. How the applicant intends to use the medical certificate is important. The FAA has accepted the concept that in the exercise of private pilot privileges, the pilot should be free to assume reasonable risks that are not acceptable in the exercise of commercial or airline transport pilot privileges.

It may be as long as several months after the requested materials are sent to the FAA before the file is evaluated by an FAA physician. The FAA will then make one of several conclusions based on the data available. The agency physicians may request yet more information, they may deny certification because the data is inadequate to determine whether certification is safe, they may deny certification because the FAA believes the medical condition to be significantly hazardous for flight, or they may certify the pilot with certain limitations. There may be a time limit of validity of the special issuance. Special follow-up medical tests, examinations, or evaluations may be required to periodically assess the stability or progression of the medical condition. Certain operational limitations may also be imposed. At the end of any specified validity period, the pilot must again show to the satisfaction of the FAA that the duties authorized by the class of medical certificate requested can be performed without endangering public safety.

If a pilot is deemed not safe to fly, the FAA will send a letter of denial. If you are denied, there are several appeals options. Most pilots actually still have good potential for being certified. Before taking any further action, obtain competent medical and possibly legal advice regarding the ability to safely fly with your given medical condition. The FAA does provide an appeals process that is essentially never-ending if the pilot can continue to provide additional information proving that he or she is an acceptable risk in flight.

By better understanding the medical certification process, you can stay a step ahead of the FAA and actually assist your AME or primary physician in keeping you certified. FAA medical certification need not be a stressful situation. However, as pilot in command, you must take the initiative of understanding your options and your responsibilities. That also means taking the appropriate steps that you alone can control in order to better the odds of staying healthy.

Ingrid E. Zimmer-Galler, M.D., is a vitreo-retinal surgeon at the Wilmer Eye Institute of Johns Hopkins Hospital in Baltimore. An instrument-rated private pilot, she owns a Beech V35B Bonanza and is currently restoring a 1939 Piper J-3 Cub.