Getting FAA Certified When You Don’t Meet the Standards


You may have a “history or diagnosis” of one of those specific disqualifying conditions or otherwise fail to meet Part 67 standards but now present no special risk. Perhaps you had a heart attack but then underwent heart surgery, quit smoking, went on a low cholesterol diet, and are following a good exercise regimen so that you are now no more likely to have another heart attack than anyone else of your age. Maybe you were able to beat an alcohol or drug habit. Maybe the history or diagnosis was erroneous (doctors are human and sometimes make mistakes too). Or perhaps the Federal Air Surgeon has disqualified you because in his opinion your condition, medication, or current course of treatment is incompatible with safe flying. Your treating physicians may strongly disagree with the Federal Air Surgeon’s opinion. Shouldn’t you be free to fly? Yes, and if you can convince the FAA that despite your medical history you are now fit to fly, you can.

Statement of Demonstrated Ability (SODA)
Pilots who have a static disability that is not expected to worsen may be certified through a process referred to as a Statement of Demonstrated Ability (SODA).

Let’s start with the easiest ones: vision and hearing problems. If your vision doesn’t meet FAA standards without eyeglasses or contact lenses but does with these lenses, all that may be required is for your AME to add this limitation to your medical certificate: “Holder shall wear correcting lenses while exercising the privileges of his/her airman certificate.”

If you failed the color vision test, you may be able to get your medical certificate by arranging a test to determine whether you are able to distinguish between the red, green, and white of the control tower light gun that would give you directions in the event of a radio failure. If you can, you get your medical certificate even if your color vision isn’t perfect. If your hearing is below standards but you can demonstrate that you can still hear and understand ATC instructions and flight deck conversation, you should be able to get your medical certificate, although it may have a limitation on it requiring you to use a noise-canceling headset while flying.

If you have a below-the-knee amputation of a leg, but have a prosthetic limb which generally enables you to function normally, and your AME is of the opinion that this would present no problem with operating the aircraft’s controls, she has authority to issue you a student pilot certificate with the limitation “For Student Pilot Purposes Only” to enable you to take a checkride with an FAA examiner. If you pass the checkride by demonstrating that you are in fact able to operate all of the aircraft’s controls despite your disability, you will be issued a SODA.

Special Issuance
If your problem is a history or diagnosis of one of the specific disqualifying conditions listed above, but you can prove that in spite of that history you are unlikely to become suddenly incapacitated while flying (or to fly irresponsibly), you may obtain an FAA medical certificate by “special issuance.” The burden will be on you and your doctors to convince the Federal Air Surgeon that you are now an acceptable risk to flight safety. If you succeed, the Federal Air Surgeon has the discretionary authority to issue you any class of medical certificate by special issuance, even though you don’t meet the letter of the law. Long a tedious, time-consuming, and frustrating bureaucratic process, the Federal Air Surgeon has delegated special issuance authority for certain medical conditions to the AME under new published guidelines called “Certificates an AME Can Issue (CACI).” This allows an AME the discretion to issue a medical certificate to applicants with arthritis, asthma, glaucoma, chronic hepatitis C, hypertension, hypothyroidism, migraine and chronic headache, pre-diabetes and renal (kidney) cancer. This delegation has simplified and expedited certification for many airmen, and this list is likely to continue to expand.

One exception to the possibility of certification through the special issuance process is the diabetic who requires insulin injections to control the disease. The FAA long considered insulin-treated diabetes mellitus (ITDM) absolutely disqualifying for any class of medical certificate. No special issuance medical certificates of any class were granted to individuals with ITDM. In response to a petition from the American Diabetes Association, the FAA has opened third-class aviation medical certification by special issuance to individuals with IDTM who haven’t experienced any further complications, such as heart or kidney disease, neurological abnormalities, or vision problems. The conditions for special issuance to individuals with ITDM, which include stringent monitoring requirements, are available on the FAA’s website. This change has opened up the joy and freedom of personal flying (under a student, recreational or private pilot certificate) to hundreds of such individuals, at this writing. Flight operations by these individuals are, however, limited to the United States, as ICAO has yet to adopt comparable rules. It continues to be the FAA’s position that individuals with ITDM still pose too great a risk of sudden incapacitation to allow first or second-class medical certification as would allow them to carry passengers for hire.

Periodic renewal of medical certificates issued under this special issuance process, once as slow and cumbersome as getting the first special issuance, is now being expedited under the FAA’s “Quick-Cert” program.

This program is part of the Federal Air Surgeon’s goal to provide “same-day medical certification” to qualified applicants.

According to the NTSB, medical causes are a factor in only about 2.5 percent of civil aviation accidents in the United States. The safety record of pilots operating under specially issued medical certificates has proven every bit as good as that of the general pilot population over the years, so this increasingly enlightened and humane process of personalized evaluation is likely to remain a feature of aviation medical certification.

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