Medical Self Certification 2.0

By now, many of you have heard and read of the joint AOPA/EAA initiative to request an exemption from the FAA that would, if accepted, allow pilots flying recreationally to be able to do so with a valid driver’s license, provided there is no knowledge of a medical deficiency that would make the person unsafe to exercise those privileges.  This exemption request is the most current in a series of similar requests made by AOPA over the last 10 years or so. 

The current request for exemption, which is different from a petition for rulemaking, capitalizes on a number of factors that haven’t been available before.  One is the success of the Light Sport self certification initiative that came into being in 2004.  We now have some tangible data from the Light Sport experience that bears out the notion that medical self certification, at least for the Sport Pilot segment of General Aviation, doesn’t diminish aviation safety. 

To date, the data reflect that there have been no LSA accidents that were associated with a medical incapacitation.  There have been light sport accidents, to be sure; however, these accidents have been demonstrated to be transitional type mishaps associated with pilots who were scaling down to LSA from normal category Part 23 certificated airplanes and who were insufficiently familiar with the significantly different aerodynamic performance characteristics of light sport airplanes compared to the “heavier metal” they were accustomed to flying.

Another important consideration in these tough economic times is that the government is reaching high and low to save money, and the cost to pilots and to the federal government of administering 3rd class medical certification is nothing to sneeze at.  Based upon FAA’s data compiled during the review in 2007 that led to the extension of duration of first and third class medical certificates, we have calculated that easing the medical certification requirements under the exemption request could save pilots more than $240 million over 10 years, and over $8 million in savings for the federal government over the same time period.

The exemption, if granted, would allow pilots to operate aircraft up to 180 horsepower, single engine, fixed gear, under day, VFR conditions, with one passenger.  By adding the power limitation up to 180 HP, the GA fleet would be expanded by 50,000 or so airplanes that could be flown under the driver’s license self certification provision. 

In any encounter with the FAA, the initiative being asked for has to demonstrate an equivalent or greater level of safety than what is currently in place.  The argument against doing something different often is, “there is no data to support it.”  There is rarely, if ever, any data to support something that’s never been done before.  In 1996, when the FAA Federal Air Surgeon decided to consider insulin dependent diabetics for special issuance medical certification, that had never been done before, either.  Industry, the American Diabetes Association, and the FAA gathered the opinions of the best qualified experts in medicine, including researchers, physicians, nurse practitioners, and other health care providers, and opened up the docket to comments from the public, and the support was overwhelmingly positive, despite the fact that no pilot had ever flown “legally” while using insulin.  Since that policy took effect fifteen years ago, I’m not aware that there has been a single accident attributed to in-flight medical incapacitation as a result of a pilot’s use of insulin.  The data gathering came after the bold decision was made to change the policy. 

The same situation resulted more recently when the FAA began allowing medical certification for pilots using antidepressants (SSRIs).  A much newer program, in effect just since April, 2010, relied again on the opinions of leading clinicians and researchers, and very limited data compiled from other countries that had been certifying pilots with depression and on medications for some time, to arrive at the conclusion that the policy could be changed without compromising aviation safety.  Again, as in the case of insulin treated diabetics, the FAA Federal Air Surgeon had to make the case to his bosses in the FAA and Department of Transportation without an overwhelming body of strong data to support the move. 

Even though there are less than 30 pilots currently certified under this new program, the FAA is following them closely, so again, the real data comes after the decision is made to make the change.

We believe the same logic should apply with our request for an exemption to expand the drivers license self certification opportunity, and we even have some a priori data to work with from the LSA experience.  We recognize that there are many aviation medical examiners that really aren’t comfortable with allowing pilots with potentially significant medical conditions to fly without “medical supervision.”  We hear those concerns, and we get it. 

However, keep in mind that self certification still means that the pilot has to determine he/she is safe to fly every time they get in the airplane, just like we’ve always done.  We would hope and expect that every pilot would be conscientious about seeing a physician for periodic physical exams.  That only makes sense, especially in an aging pilot population.  The need for a medical certificate to fly should not be the motivation for staying healthy.  Rather, staying healthy should be the motivation itself for seeing your family physician for an “annual body inspection.”

And, if the exemption is granted, part of the cost of playing will be participation in an online educational course that will provide some insights into what “self certification” really means.  The course content, which is still being developed, will also include an overview of common medical conditions that could lead to possible incapacitation, and training about the effects of altitude on medication usages.   

We believe the time is right to rejuvenate general aviation and get more pilots flying again, but doing it safely.  One of the best ways to improve safety is to fly more proficiently, and proficiency comes from flying in the system. 

Hopefully, the FAA will see it that way and grant us the exemption.  Then the burden will be on us to prove that we can maintain that equivalent level of safety without the regulatory burden of a medical certificate for those operations covered under the exemption request.

When we file for the exemption early next year, we’ll be calling on your help to support the request.  I’ve added a link below that will allow you to sign up to receive updates on the progress, and we’ll also let you know when the docket opens so you can send your own comments.

Gary Crump
Director, Medical Certification Services

AOPA Pilot Information Center  |  AOPA Medical Services Program

13 Responses to “Medical Self Certification 2.0”

  1. tajburrowyho says:

    If you take medications for depression is no impediment to work or to carry out its responsibilities.
    logically, if it is authorized by the authorities.

    Taj Burrow Yho

  2. hank says:

    I think scaling down the 3rd class medical requirements is a great idea! But your initiative above shows a great lack of initiative . . . Why only 180 hp? Why not anything not “high performance”? Why no retract? Why day-only VFR?

    This is a great opportunity, and you should ask for everything you can get. You will not get the whole enchilada, but by asking for “more” you have some bargaining room. Right now, if you give up anything at all, you’re right back at LSA–no gain at all.

    Raise your sights and shoot higher! 180 hp, fixed, day-only VFR, pilot + 1 passenger is a very small step forward. Be bold, step out and ASK FOR SOMETHING!

  3. MJ Bouquet says:

    I guess I still believe in the old school way of things since I’m over 55. I don’t even believe in the Light Sport Pilot Certificate and I stay current as a flight instructor. A person wants to fly, get a Private Pilot License…Period. This is not a game. Flying is serious business for those in the sky as well as those on the ground we could harm. We have come up with ideas to dodge the medical standards simply to fly what is called Light Sport Aircraft. Then we find ways to save the money by not getting a medical and using a drivers license. I just renewed my drivers license and there was not a damn thing I did from a medical standpoint to renew it except check my eyes. I’ve been checking my eyes to renew my drivers license ever since I started driving. We have Aviation Standards. This has nothing to do with driving down the highway. You will not have my support for this “self certification” idea that is floating around.

  4. Vagablue says:

    The third class, and any medical for that matter, is like a vehcle inspection, only relevant on the day it is performed. Every day in between relies on the integrity and “common sense” of whether the pilot thinks he/she is well enough to fly. I wouldn’t have thought there are many pilots (a largely responsible group) who would be “stupid” enough to fly if they thought they might become incapacitated and crash as the statistics prove.

  5. Rod says:

    My guess is that Mr. Bouquet has never had a treatable and stable medical condition that the FAA required tests costing thousands of dollars. Tests that are not deemed necessary by the treating physician and not covered by insurance.

  6. Daniel J says:

    Please adress 61.303b when advancing this proposal. I have had my medical denied for retained kidney stones and am forever stuck in this regulation. I may experience a kidney stone problem once every 2 or 3 years and know enough to not fly when symptoms are present. My experience has never evidenced an immediate incapacitation because of kidney stones. There is always a period of several hours warning that problems are developing. The current ruling is discriminatory in that many sport pilots who succesfully operate on a DL have the same condition, but have not applied for and been denied a 3rd class medical.

  7. Carl Stahl says:

    I agree with Rod that Mr. Bouquet has never needed a special issue license. If he did he would see how expensive and time consuming the
    medical required by FAA is and nothing good comes from it. I do not think a Sport Pilot is going to try and fly with a med problem any more
    than an FAA medical licensed pilot will. After the medical is granted, all flying is self certified.

  8. Joe says:

    The drivers license should have always been the requirement for a private pilot Class 3 medical, not for hire but pleasure, as the average private pilot flys 30 hours a year. By law the DMV requires Doctors to report any serious medical conditions.

  9. Curtis P.... Heimberg says:

    Thank-you AOPA.
    You and the EAA have know for ages, that this medical does not in any way shape or form accomplish what it purports to. It is from your data and the data of the industry, that the conclusions reached, have been inescapable that this is so.
    I love what you are doing.
    If a rule works for it’s intended purpose, there is no reason to ever remove it. This rule has never to my knowledge ever worked for it’s stated purpose.
    Curtis P…. Heimberg

  10. Todd says:

    Thanks AOPA! its organizations like this that we need. This is a wonderful plan and I hope it happens. I will support this and continue to support AOPA! The medical is so over rated and costly that aviation is declineing because of it, I dont know anybody in the aviation community that would fly knowing they could not do it safely. YOU HAVE MY VOTE!

  11. Frank says:

    I am a commercial pilot with instrument, multiengine and flight instructor training. I can read this blog and feel the pain eminating from all who post and others who are reading. We all share one thing in common, love of flight, and hate to see anyone or anything stand in our way. I had a class II medical that was lowered to a class III on a medical wavier for type II diabetis in 1994 appx. All after preparing to teach others in my retirement years. The hurdles for me were expensive and time consuming and I finally gave up and quit after several years of the struggle. Along came light sport. I took up restoration of antique aircraft and entered a whole new and challanging time in my life. In addition, I probably have the only 1948 PA 15 totally restored in 2005 to like new that has all the latest equipment and is IFR certified (practice only). The only things I really miss are aerobatic flight, flight in the soup and night flight, which brings me to the topic at hand. In my oponion anyone who has mastered the flight regime at any time in his or her life has a great respect for the life of others wether inside or outside of the aircraft and would never risk their safety. If someone is going to be a risk factor to others they arent going to care whether or not they have a medical certificate (case in point – barefoot bandit). In my oponion the best alternative is the current trend toward a drivers license for III class pilots, without a restriction on the aircraft they have been flying all along (no commercial privleges).

  12. John T says:

    Everyone is welcome to their ideas and comments. That’s what makes our country great. The good ol’ days are gone and there are so many more conditions that are diagnosed by doctors now, that we never heard of before. In the good ol’ days smoking was the popular and advertised thing to do. Certainly not healthy. I actually had an examiner tell me once that if I was taking aspirin, I wasn’t allowed to fly. We have airline pilots on flights that are legally drunk. So what exactly does that medical exam get anyone? It’s just a snapshot in time, but the minute you walk out that door you certify yourself to fly or not to fly. You don’t have to be a superhuman to pilot a C-172, but you have to have the skills and common sense that we used to get what really matters, and that’s our license to exercise those skills.
    Woah, what if they required a medical to drive a car???

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