ADD medication denial

[Jeff Oslick]

Bull hockey. It's published. Here it is....

No, Bruce, I'm referring to the raw information used to establish the criteria for eligibility, in medical terms, and the scientific reasoning for how these criteria are established.

For example, the EPA (and the various state agencies I work with) are required to provide statistically valid studies and criteria for setting clean up levels for environmental contaminants, based on toxicity and carcinogenic risk. This information is pretty easy to find on the EPA (and other) websites. Is there such information, readily available, for medical eligibility determination for various conditions?

 

[Matthew]

I've always assumed that my personal doc was working for me and what was in my best medical interest. And that my AME was working for the FAA and their procedures - not neccesarily what was in my best interest. Each has a different person to answer to.

 

[bbchien]

Okay. So tell me if this makes it any better. I'd bet you cannot understand this sheet. Does that point out the problem?

 

[RJM62]

Okay. So tell me if this makes it any better. I'd bet you cannot understand this sheet. Does that point out the problem?

I am at least vaguely familiar with most of those tests -- enough, at least, to understand why FAA requires them.

I probably said this before, but it is my position that FAA is not in the wrong for requiring the tests. School districts and the clinicians they hire are in the wrong for not requiring the tests before handing out ADHD diagnoses and prescribing pills. Quite frankly, I'd be all for prosecuting those jokers. They think it's a trivial thing to medicate away the futures of an entire generation of kids.

-Rich

 

[Jim Logajan]

I am at least vaguely familiar with most of those tests -- enough, at least, to understand why FAA requires them.

I probably said this before, but it is my position that FAA is not in the wrong for requiring the tests. School districts and the clinicians they hire are in the wrong for not requiring the tests before handing out ADHD diagnoses and prescribing pills. Quite frankly, I'd be all for prosecuting those jokers. They think it's a trivial thing to medicate away the futures of an entire generation of kids.

-Rich

I read the document the doctor posted; I recognize some of the tests. (The references it lists are not easy to come by - I checked.) But the document doesn't seem to answer the kind of questions I think Jeff is thinking of, such as:

How far outside the norms must an applicant be for the FAA to deny a medical? How was that threshold established? What is considered unacceptable risk and how was it established? What statistical or other observational data exist to support the answers to the above questions?

Objective scientific justification for the criteria and process being used may not be possible for neuropsychological problems, but that doesn't mean the FAA shouldn't try to produce that justification - or at least explain why it can't produce it but that it still needs to perform those evaluations to the best of their abilities.

(FAA medicals appear to exist based on the general proposition that if an individual becomes a member of a group that has a higher probability of causing harm to others while engaged in an activity, then that individual can be banned from that activity. That general proposition is one that can lead to obvious impairments to even the most innocuous individual liberty.)

 

[Jeff Oslick]

I read the document the doctor posted; I recognize some of the tests. (The references it lists are not easy to come by - I checked.) But the document doesn't seem to answer the kind of questions I think Jeff is thinking of, such as:

How far outside the norms must an applicant be for the FAA to deny a medical? How was that threshold established? What is considered unacceptable risk and how was it established? What statistical or other observational data exist to support the answers to the above questions?

Objective scientific justification for the criteria and process being used may not be possible for neuropsychological problems, but that doesn't mean the FAA shouldn't try to produce that justification - or at least explain why it can't produce it but that it still needs to perform those evaluations to the best of their abilities.

(FAA medicals appear to exist based on the general proposition that if an individual becomes a member of a group that has a higher probability of causing harm to others while engaged in an activity, then that individual can be banned from that activity. That general proposition is one that can lead to obvious impairments to even the most innocuous individual liberty.)

These are exactly my concerns. I'm concerned about the validity of this process in the aeromedical regime in the same way that I'm critical of many practices in my own industry (environmental remediation). I typically see one or a small number of tests, often done a long time ago, typically done on animals that may or may not represent human physiological responses, are extrapolated far and wide in an attempt to create a "risk" based number.

 

[Jeff Oslick]

Okay. So tell me if this makes it any better. I'd bet you cannot understand this sheet. Does that point out the problem?

Bruce, the point is not whether I can understand the significance of the various tests, it is whether the information and decision-making rationale being used by a public agency, supposedly for public safety reasons, can be independently verified by other experts. This is not just for initial certification, but also for how the criteria for various tests required for SIs are established.

When the EPA promulgates a new regulatory cleanup concentration, all the information is put out for public review and comment, and the affected persons and industries have a fair opportunity to comment, and potentially change, a proposed rule. It should be AOPA's job to do this for the pilot community; unfortunately AOPA has sold-out and now receives income based on an opaque medical certification process.

 

[bbchien]

Bruce, the point is not whether I can understand the significance of the various tests, it is whether the information and decision-making rationale being used by a public agency, supposedly for public safety reasons, can be independently verified by other experts. This is not just for initial certification, but also for how the criteria for various tests required for SIs are established.

What make you think they cannot be? We have reams of primary data, statisically scoree on every such evaluation. In fact when one is borderline, FAA sends these out to outside experts routinely, for concurrence or dispute. And the reams of test performance answers (the actual tests themselves) go as well. Just because one cannot understand what is being done, does not make the process unfair, or non transparent. Don't confuse the two.

You can hire your own Neuro-Psychologist. In fact I know some very good ones. The discussions are quite reproduceable and interesting. I am seeing an 17 year old airman, in 6 days for whom the community guy's opinion was overruled in his FAVOR by the FAA external consultant (we hired him). That will be an "issue in the office" situation.

I cannot conduct clincial Psychology 301 on a website. (IN fact I'm only probably qualfiied to give 101, if that).

I'm AM glad a few of you can recognize the names of some of the tests.

When the EPA promulgates a new regulatory cleanup concentration, all the information is put out for public review and comment, and the affected persons and industries have a fair opportunity to comment, and potentially change, a proposed rule. It should be AOPA's job to do this for the pilot community; unfortunately AOPA has sold-out and now receives income based on an opaque medical certification process.

I have nothinn to say to Craig Fuller. Many of you youl will remember that I resigned in 2011 and have been a not-silent critic.
****
And no they don't have to publish "rules" for this. In fact the RULE that makes diabetes defined as a disqualifying condition, almost bunged up CACI (conditions AMEs can issue). The agency got around it by defining metformin NIDDM + HbA1c<6.5 as "PRE-diabetes". AMEs can since April 8, just issue that.

The empowering legislation gives the FAS the power to issue conditions for which "best medical opinion" can support equivalent safety.

Trouble is, most guys hire community based psychs, no neuro residency, they aren't up to snuff, and they bung it. And then the airman says, "it's SO unfair!!. CHEAPER (some take insurance and can't possibly do the job in the $490 paid by Blue Cross).

In reality, you can use any unqualified guy you want. The agency will just deny you if the work is not up to snuff. And that is what happened in the case of the airman I'm going to issue next week.

It happens that I am JUST expert enough to see proper use of normed statistical data in use to undertand that is is.

Here's an example: Say a guy has an IQ of 130, but his auditory and verbal attention performance scores are only in the 50th perctiled normed to 130. His executive processing scores are in the 40th percentile? Dos he have ADD? There is near 100% concurrence on this point between experts. He does not. His 40th percentile (x 1.3) is still above the population norm.

Now say his has and IQ of 100 and he has the same scores., in verbal and autditory processing, normed to 100. Does he have ADD? Wel this depends on the relative strengths in the other areas. If they have some weakness proabably not.

A cut and dry: IQ of 110. An auditory processing score at the 20th percentile. He's well below norms. The only kicker would be is if his executive processing speed was above normal. Then we wouldn't know what to think. This guy likely gets an SI and comes back next year.

So class, how did I do? Jeff's expectation that he be donated enough tools to understand the process, is not part of the federal equation. Just undertand that there is very good concurrence among those truly qualified, and it is NOT arbitrary. And it is understandable. But your perception that is is not, is intimately related to not having ANY IDEA of how the heck this is done. "try to do this one by yourself" is a fools errand. Why do you think engineers hire doctors, Doctors hire lawyers, etc....

BTW I encourage all here to volunteer at Dr. Gary Kay's presentation (the current "father" of Applied Clinical Neuropsychology) at OSH to take Cogscreen AE, esp. if you are a robust older pilot. He is trying to strengthen the statistical "normal" group and needs about 50 more.

Dr. Kay just got another airman of mine out of denial/deferral hell, though it'll take a while. He posts here.

 

[Jeff Oslick]

Bruce,

Let's move off of the clinical psychology issues, which likely offer more gray area than most conditions, and onto something closer to home for me and generally more common. Where would one find the FAA's statistical basis for evaluating the aeromedical risk due to a kidney stone?

 

[bbchien]

Bruce,

Let's move off of the clinical psychology issues, which likely offer more gray area than most conditions, and onto something closer to home for me and generally more common. Where would one find the FAA's statistical basis for evaluating the aeromedical risk due to a kidney stone?

Jeff, No, I took a good 20 minutes to create that post 48. do me the honor of READING IT. READ IT.

I'll deal with stones tomorrow. You picked the wrong one to discuss. The Stone protocol is dead on rational. I'm not going to write 5 chpaters in one night. Worse, I have posted the protocol here. There are THREE ways to certify an airman with a stone.

 

[Jeff Oslick]

Jeff, No, I took a good 20 minutes to create that post 48. do me the honor of READING IT. READ IT.

I'll deal with stones tomorrow. You picked the wrong one to discuss. The Stone protocol is dead on rational.

Bruce, you are taking my tone as confrontational, and that is not my intent. I'm trying to understand the process that FAA Aeromedical uses. I do appreciate your contributing to my knowledge. I'm not pretending to be an MD, but I am a scientist, and I understand the scientific method quite well. I've also have a fair amount of experience, both academic and professional, with regulatory policy making.

I know the "ways" to certify with a stone, that was not my question.

 

[Jim Logajan]

So class, how did I do?

Very nice and informative; I appreciated the details and the time spent. I have placed "Aeromedical Psychology" by Kennedy and Kay into my Amazon wish list; I may buy it when it is published at the end of July.

I'd be curious to know what FAA documents or other texts you referred to (mentally or physically) while you composed those example scenarios.

 

[Palmpilot]

Jeff, No, I took a good 20 minutes to create that post 48. do me the honor of READING IT. READ IT.

I read it, and I thought it was very informative. Thank you.

 

[Jeff Oslick]

BTW I encourage all here to volunteer at Dr. Gary Kay's presentation (the current "father" of Applied Clinical Neuropsychology) at OSH to take Cogscreen AE, esp. if you are a robust older pilot. He is trying to strengthen the statistical "normal" group and needs about 50 more.

I'm confused on the intent of this request. How can self-selecting "robust" pilots be used to define a "normal" group? This phrasing somewhat implies an intent to bias the data collected, which I would not think is the intent of the study.

 

[bbchien]

I'm confused on the intent of this request. How can self-selecting "robust" pilots be used to define a "normal" group? This phrasing somewhat implies an intent to bias the data collected, which I would not think is the intent of the study.

He'll be asking you a short medical history and looking to see that you Medical Cert doesn't have "not valid for any class after" on it. I think any 70 year old who braves RIPON and FISKE by definition has some robustness about him. That's called "selecting" for robustness. I'm sure his office wil lcomb out, after the fact, a/m who have recent violations, or disciplinary actions after age 70.....he's no idiot.

The idea is to expand "n" in the database on the 70 something pilot set so that the norms can be narrowed.

Jeff, I thought about writing a dissertation on stones. But I would have to teach you Renal Metabolism 201. I AM qualified to do that, but that's a huge exogesis of how calicum is metabolized in the body, which is necessary to understand why the "3 methods" are appropriate.

That's a LOT of work, as was last night's post. I think I am going to punt as teaching medical physiology here is just too ambitious.....

The REASON your post is confrontational is that is presumes that the FAA, and that I have an OBLIGATION to educate you enough so that you can understand. That's quite a presumption.

 

[Palmpilot]

I hope he doesn't think you have that obligation, but perhaps he feels that the FAA has an obligation to make the reasoning behind its eligibility standards public. (As for me, I'm not taking a position on whether that is feasible.)

 

[bbchien]

I hope he doesn't think you have that obligation, but perhaps he feels that the FAA has an obligation to make the reasoning behind its eligibility standards public. (As for me, I'm not taking a position on whether that is feasible.)

I don't believe that's feasable unless you have been to medical school.

I mean to teach a chapter on renal physiology/calcium metabolism after completing a chapter on neuropsychology....I have real pilots to take care of..... sigh.

 

[Jeff Oslick]

The REASON your post is confrontational is that is presumes that the FAA, and that I have an OBLIGATION to educate you enough so that you can understand. That's quite a presumption.

Bruce, I absolute do not think you have any obligation to post anything, anytime, about anything. You provide a valuable service to the community, and I respect you for that. I fully respect you for just saying you don't want to get into the weeds on a technical topic, that is perfectly fair. I apologize if it seemed I was pushing specifically on you for answers. What I was hoping was that perhaps there would be a public resource on the FAA website that provided more information than I was seeing. Perhaps it is there and I just haven't found it.

My overall point was that it *appears* to me that FAA Aeromedical is not as transparent in their decision making as other federal agencies. I think some or most of that may be because Aeromedical doesn't have to provide cost/benefit analyses for their decisions because they are presumed to fall under the "threshold" $ amount that triggers such analyses.

 

[bbchien]

Bruce, I absolute do not think you have any obligation to post anything, anytime, about anything. You provide a valuable service to the community, and I respect you for that. I fully respect you for just saying you don't want to get into the weeds on a technical topic, that is perfectly fair. I apologize if it seemed I was pushing specifically on you for answers. What I was hoping was that perhaps there would be a public resource on the FAA website that provided more information than I was seeing. Perhaps it is there and I just haven't found it.

It is there, and if you are a doctor you can understand it. For example, look at these TWO protocols. I have no problem knowing which one they want, and folks are always saying, "why the expensive one?". To know that, you have to understand the array of conditions being evaluated....

My overall point was that it *appears* to me that FAA Aeromedical is not as transparent in their decision making as other federal agencies. I think some or most of that may be because Aeromedical doesn't have to provide cost/benefit analyses for their decisions because they are presumed to fall under the "threshold" $ amount that triggers such analyses.

That is because they have NO ZERO ZILCH NADA obligation to educate the public to the level of a physician, and aeromedical has said so, and they don't have the resources to do so.

For example, look at this requrements sheet. It's pretty plain what needed. I'm sure glad some participants here recognize the names of some of these tests....[Intended Irony].

Jeff, with all due respect, you may be one of the few that understands the scientific method (generally lacking in our 30 somethings) but, but much more is requried. To understand the discussion you need to have the knowledge database, which takes about four years of continuous study to do.....and that is why attorneys hire doctors. There is NO PUBLIC resource for that. It's expensive (both time and $$s) and called medical school.

In short you give yourself more credit than you should. "Everybody's a doctor!" In fact, in our state, we're about to make clinical psychologists into doctors- not by education, but by legislation! And only the very rare neuropsych has even had a residency!

 

[Jeff Oslick]

Bruce, I appreciate the references, and accusing me of being a 30-something (I'm a few years past that milestone).

I do not doubt for a moment that it requires significant medical expertise to diagnose conditions that may affect an airman. I'm under no illusion that I could be such an expert. What I do know quite a bit about is environmental health risk assessment and statistical analysis.

The piece of the aeromedical puzzle that I don't see, that I think would be required for proper risk assessment of *some* common conditions, are studies that evaluate, directly, how different medical conditions are specifically correlated to a risk of in-flight incapacitation. I don't need to be a doctor to interpret an accident/incident report. Now, for heart conditions, I can see the direct correlation of a heart attack causing incapacitation. Same for stroke. I'm sure I could think of others, but those are the big two. I'm not debating the value of BP limits and other cardio-vascular screening requirements, etc.

Again, back to the kidney stone issue, I've searched far and wide in the accident and incident databases and haven't found a single conclusive case where a stone was directly attributable as a causal factor in an actual incident or accident. I'm quite certain there are tens of thousands of pilots who have experienced their first kidney stone *after* first being certified. If it was an in-flight incapacitation risk, you'd expect to see something in the incident/accident data. Yes, they hurt like an SOB, but if your life depended on it, you're going to keep flying through the pain.

I'm absolutely no expert on cancer, but again, I don't, as a layman, see a lot of folks just keeling over suddenly from it common skin cancers. This really seems like one where self-certification in consult with a personal physician makes a whole lot more sense than either the AME or a bureaucrat in the FAA needing to see some "magic words" in the official file. It just seems the SI process goes overboard collecting data and delaying certifications, oft times for not a lot of good reason. And, yes, I know you've work hard to improve this situation for various conditions. Your work is appreciated by the community.

I'm not going to debate the ADHD issue anymore here, other than to say that if the FAA doesn't figure out a more reasonable (less expensive and less onerous) method for discounting many of the very significant percentage of "just write the script" diagnosis that have been issued in the last couple decades, we're just finding another way to kill off general aviation by unnecessarily reducing the pool of interested pilots. BTW, where do you think Howard Hughes would test on the ADHD scale?

I get it that Congress has screwed around in the process for a number of conditions, but it does seem like there is substantially more that Aeromedical could do to make our life easier and their work easier, without measurably impacting aviation safety, nor concerning their congressional masters. Maybe I'm completely off my rocker here and these types of risk assessment data exist and valid risk assessment have been done to justify all of the rules. If they do exist (for the example conditions I've listed), I'd be interested in seeing it.

 

[Jim Logajan]

It is there, and if you are a doctor you can understand it. For example, look at these TWO protocols. I have no problem knowing which one they want, and folks are always saying, "why the expesnive one?". To know that, you have to understand the array of conditions being evaluated.... That is because they have NO ZERO ZILCH NADA obligation to educate the public to the level of a physician, and aeromedical has said so, and they don't have the resources to do so.

So? When the FAA proposed ADS-B in this NPRM, the FAA had no obligation to educate the public about electronics and radio communication standards either, but they were obligated to publish the relevant technical standards so those members of the public who were trained in the appropriate fields could provide feedback. The ADS-B NPRM referenced a highly technical document over 1000 pages that any idiot could have tried reading and commenting on during the comment period. Sure, you could look it over and say "Dammit Jim, I'm a doctor, not a radio communications engineer!" but the NPRM process would have allowed you to seek help from an expert who wasn't on the payroll of the FAA so you could understand it and then comment on it intelligently!

Also, with ADS-B the FAA was required to issue an Initial Regulatory Flexibility Analysis (guide here) like this revised one for ADS-B that attempts to quantify the affect any proposed rule change has on the economics of small entities.

There may be an informal feedback mechanism to aeromedical, but is there any formal mechanism equivalent to the NPRM process? My complaint is that there doesn't appear to be one, but changes to medical standards sure by god do impact the common airman since they have all the force of regulations.

For example, look at this requrements sheet. It's pretty plain what needed. I'm sure glad some participants here recognize the names of some of these tests....

(The MMPI test and its variants is rather famous, or infamous, even to people like me who otherwise had no interest in such things.)

As to the two spec sheets - neither one contains any quantified (or other) justification for the risk assessment claim made at the very top of each:

• "Mental disorders, as well as the medications used for treatment, may produce symptoms or behavior that would make an airman unsafe to perform pilot duties."
• "Attention-Deficit/Hyperactivity Disorder (ADHD), formerly Attention Deficit Disorder (ADD), and medications used for treatment may produce cognitive deficits that would make an airman unsafe to perform pilot duties."

For example - based on what you haven't said, it seems there is currently no legal mechanism stopping aeromedical from suddenly and unilaterally making the ingestion of any amount of Ibuprofen cause for grounding unless one gets a SI - and their spec sheet and justification could be as simple as this:

• "Taking Ibuprofen may produce an increase risk of heart attack that would make an airman unsafe to perform pilot duties."

Without public disclosure of how they quantified that risk and what level of risk they were using as a threshold for enactment of that regulation-by-medical-proxy, they could (and probably have) created lame-brain special issuance criteria.

Your attacks on our lack of medical expertise is absolutely irrelevant - all I want is for aeromedical to publish its justifications and determination criteria for public critique. (For example, the main reference in those two specs is a book that wont be published for another 3 months!) Pilots like me don't need medical expertise so long as we know where we can borrow or hire it (so we can respond and hopefully change the what aeromedical decides.) There are doctors who are also pilots who have the needed expertise that affected pilots could hire as experts, who then could intelligently contest aeromedical's decisions during the justification and spec writing phase if only aeromedical could be made to follow modern regulatory practice. All the evidence shown so far indicates they operate carte blanche.

 

[bbchien]

Jeff, I'm not going to do that fool's errand. The Commerce Act of 1953 empowers the FAS to determine this on "best medical opinion".
(1) I can tell you that it exists for CAD and the stress treadmill to 90% of Vmax. That's is "Circulation Research" in the last 90's, a large cohort of men who were able to do that, and followed for FIVE YEARS.

(2)That's why we insist that Cancer not be metastatic- there are no incapacitation curves for many of the subtypes.

(3) The brain metastasis rate for Melanoma beyond 0.75 mm basement membrane depth and Clark Level 6 is about 1% a year- and it presents with a seizure.

On and on it goes.....

So? When the FAA proposed ADS-B in this NPRM, the FAA had no obligation to educate the public about electronics and radio communication standards either, but they were obligated to publish the relevant technical standards so those members of the public who were trained in the appropriate fields could provide feedback. The ADS-B NPRM referenced a highly technical document over 1000 pages that any idiot could have tried reading and commenting on during the comment period. Sure, you could look it over and say "Dammit Jim, I'm a doctor, not a radio communications engineer!" but the NPRM process would have allowed you to seek help from an expert who wasn't on the payroll of the FAA so you could understand it and then comment on it intelligently!

uh.......that's a capital appropriation requirement, Jim......

Also, with ADS-B the FAA was required to issue an Initial Regulatory Flexibility Analysis (guide here) like this revised one for ADS-B that attempts to quantify the affect any proposed rule change has on the economics of small entities.

There may be an informal feedback mechanism to aeromedical, but is there any formal mechanism equivalent to the NPRM process? My complaint is that there doesn't appear to be one, but changes to medical standards sure by god do impact the common airman since they have all the force of regulations.

Well the panel convened in January to alter the Cardiovascular requirements sure was a formal gathering....But I guess becuase you we're aware of it, it doesn't count. We were.

(The MMPI test and its variants is rather famous, or

Oh. Excuse me. You've heard of the MMPI. Care to tell me what it actually measures? I guess you've also become a neuro psychologist.....

As to the two spec sheets - neither one contains any quantified (or other) justification for the risk assessment claim made at the very top of each:

• "Mental disorders, as well as the medications used for treatment, may produce symptoms or behavior that would make an airman unsafe to perform pilot duties"Attention-Deficit/Hyperactivity Disorder (ADHD), formerly Attention Deficit Disorder (ADD), and medications used for treatment may produce cognitive deficits that would make an airman unsafe to perform pilot duties."

• (4) Look up the F&DA sheet on Ritalin. The number of cases of side effects/denominator in the clinical trial will surprise you. And the Mfr wasn't even looking with a good tool.

For example - based on what you haven't said, it seems there is currently no legal mechanism stopping aeromedical from suddenly and unilaterally making the ingestion of any amount of Ibuprofen cause for grounding unless one gets a SI - and their spec sheet and justification could be as simple as this:

• "Taking Ibuprofen may produce an increase risk of heart attack that would make an airman unsafe to perform pilot duties."

• (5)There's an F&DA letter out on this someplace. That is less than a few in 15,000 over a ten year period.

Without public disclosure of how they quantified that risk and what level of risk they were using as a threshold for enactment of that regulation-by-medical-proxy, they could (and probably have) created lame-brain special issuance criteria.

Be careful for what you wish. Dr. Arlene Sanger at Medial standards is the keeper of the data. She is pretty much all the agency can finance. When that appropriation gets bigger, there will be an army of even tougher standards. Their latest recruit was FAS Larry Wilson, of the Kansas City office. Thing just got worse for midwestern airmen.

Every time I have called and asked for the underpinnings of a standard, I have usually been given a reference, but when not, always the rationale. Call 'em up Jim, the conversation will devolve rapidly into, "I don't think this man is equipped to understand the answer", because you don't even understand the language. They will AFAIK even do this for an a/m's non AME personal physician, though such calls must be RARE. Physicians hardy have the time to go to that bathroom these days.

That huge dissertation I wrote last night on neuropsychology (post 48) would be told to you as "population meaned cognitive skill category deficits are relevant to pilot performance". If I had posted that instead, you would have found that most unsatisfying: BECAUSE YOU WOULD NOT HAVE UNDERSTOOD IT.

And Mr. Oslick would not have considered that an answer. But it contains the entire post in one sentence.

Your attacks on our lack of medical expertise is absolutely irrelevant

So all the publically available information I quoted above, you expect us to point out to you.....see below for the appropriation to make that happen....

- all I want is for aeromedical to publish its justifications and determination criteria for public critique. (For example, the main reference in those two specs is a book that wont be published for another 3 months!)

That's absolutely infantile. You're behaving like a 2 year old. See below. Besides it's already out there. You have to know where to look. I just gave you # (1)-#(5) off the cuff.

Pilots like me don't need medical expertise so long as we know where we can borrow or hire it (so we can respond and hopefully change the what aeromedical decides.)

Then why don't you hire it. I'm actually hired in a case before the FAS right now.....What you really mean, is "you want it for free". The airman hired me (NOT free) to argue from data.....and it might change medical standards (though I doubt it, were arguing the man fits in a different classification than he was placed/evaluated.

There are doctors who are also pilots who have the needed expertise that affected pilots could hire as experts, who then could intelligently contest aeromedical's decisions during the justification and spec writing phase if only aeromedical could be made to follow modern regulatory practice. All the evidence shown so far indicates they operate carte blanche.

Circular logic! You don't understand what appears to be carte blanche, so you say that the justification isn't out there. It's all out there, YOU just have to know where to look. I just gave a few examples (FIVE in fact). You are in the position of saying, "i don't understand it, so I'm calling the SI criteria arbitrary.....Then you say, "hire the experts...." but then I say to you , "provide the appropriation".

Well, Jim, do some research. I'm not going to do it for you. And have your representative vote some resources so FAA can do this.

It is one thing to demand, it is quite another to provide the resources for that demand. Docs generally understand the risk rationale, but the heck I'm going to do that for you.

Reminds me of the infantile 2 year old who demands that "it be provided" but doens't provide the means to do it. You know why we dont' have photos on our pilot certificates? CONGRESS demanded it but didn't provide the line item to do it.

And THAT IS ALL. You guys need to just BAG it. I am, expect no further responses from me. You are free to have the last word, it'll make you feel better. I close now with a quote from AggieMike:

 

[Unregistered]

Sorry, what were you saying?

 

[Unregistered]

He was saying.....Squirrel!