Warren Silberman
- Former Manager, FAA Aerospace Medical Certification
- Doctor of Osteopathic Medicine
- Expert in Aerospace/Preventive Medicine
- Pilot since 1986
A limitation on a medical certificate generally means that an airman has a medical condition that prevents the pilot from meeting the minimum medical standard, and the only way he or she can gain medical certification for the class of medical requested is to have that “limitation” placed on the medical. For example a person who does not meet standards in the class requested for their vision without having to wear eyeglasses would have a limitation: MUST WEAR CORRECTIVE LENSES. Or an airman who can’t hear a conversational voice at six feet and must wear hearing aids in order to pass the FAA hearing examination would have a limitation placed on his or her certificate: MUST WEAR HEARING AMPLIFICATION.
A restriction limits the operational privileges of the airman certificate and/or the duration of the medical certificate. The FAA, however, may not place such a “restriction” on a first class medical certificate as a result of a legal case that the FAA lost some years ago (Delta Airlines vs. FAA).
The FAA may restrict a second class medical certificate for a number of reasons. A “restriction” may be placed on a second class medical certificate when the airman does not meet the standards for “full” second class privileges due to some medical condition that may present an unacceptable risk for some operations, but not for others. These are some examples of restrictions that have been placed on a second class medical certificate:
- VALID ONLY FOR AIR TRAFFIC CONTROL DUTIES
- VALID FOR BANNER TOWING
- VALID ONLY FOR AGRICULTURAL FLYING
If an airman has a restriction on a second class medical certificate, the language of the limitation will also state, “Full Third Class privileges.” The FAA does not restrict a third class medical certificate because of the language in the Part 67 medical standards that allows a higher level of risk for noncommercial pilots carrying one or more passengers but not for hire (Recreational or Private Pilot privileges).
In some situations the FAA will issue what it calls a limited second class medical certificate. Technically, all the restrictions mentioned in the above paragraph imply that the second class medical certificate is a “limited” one. The most common restriction placed on a limited second class medical is “LIMITED SECOND-CLASS: NOT VALID FOR CARRYING PASSENGERS OR CARGO FOR COMPENSATION EXCEPT FOR A FULLY QUALIFIED TWO-PLIOT CREW/FULL 3RD-CLASS.” This means that the airman may not fly for pay, except if there is another pilot in the aircraft who is “fully rated” in that aircraft and who does not carry such a restriction. This type of restriction is given for certain medical situations.
If this article does not help with your concerns about this issue and you want answers to your questions on medical certificates, you need to phone AOPA Pilot Protection Services' Medical Certification Section.
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I was asked recently to explain to our members about what kinds of restrictions one can see on a medical certificate. First let me explain the difference between a limitation and a restriction.
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