FAA adds another hoop for medicals

Henning said:
Not really different IMO. The >40 +17" is already the diagnosis for morbid obesity, same as a diagnosis for CAD. If you have CAD, you now have to prove that you don't have debilitating effects from CAD. In the same way, this is requiring you to show that you don't have debilitating effects from morbid obesity, eg Sleep Apnea.
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Where does it stop though, if the goal is to get everyone with OSA then eventually everyone will have to pay for the testing to fly.
 
Skylane81E said:
Where does it stop though, if the goal is to get everyone with OSA then eventually everyone will have to pay for the testing to fly.
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Most likely when they make their way down to the point of diminishing returns. If you start with a group that is known will have a high proportion, as they are, and when you have those in compliance add another step down, so forth and so on, eventually you will get down to an addition where you find a statistically insignificant proportion of affected people. That's where you stop.
 
Once this goes into effect (at whatever level), I hope student pilots are told about it. Not going to be fun going to the AME the day you expect to solo and getting hit with this.
 
ScottM said:
Can somebody please let us know how many aviation accidents are the result of undiagnosed sleep apnea? It would also be nice to know that same statistic for violation or at least stretching of crew rest requirements to compare the two.
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Hush now, go back to sleep. ;)
 
Unregistered said:
So here's a question:

Let's say a pilot fits both of these criteria (BMI > 40 and neck > 17"). Do they have to self ground, get a study done for OSA, and then the SI?
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That raises another question:

Has the FAA ever published a list of items that they want pilots to self-ground for? OK, stuff that's explicitly listed in Part 67 is obvious. SOME things that would fall under the General Medical Condition section may be obvious too, but there could be a lot of stuff that the average pilot might not have reason to know would be disqualifying.
 
Henning said:
Well, since the DOT also has this program already in effect for truck drivers, I'd say to answer your question of evidence I would suggest you look and see what they came up with as I'm sure the Teamsters likely challenged this matter as well and I doubt DOT overcame the challenge without some evidence of fact.
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If there is data from the trucking industry, that would certainly seem to be applicable. From a brief Google search, it appears that there have been some studies, but I haven't looked at enough of them to form a conclusion. I do think that the FAA should present a list and assessment of the studies that have been done before going any further with this. The FAA is the Federal Aviation Administration, not the Ministry of Health.
 
ScottM said:
So you are asking for the proof of a negative? That is a logic fail and if it is what the FAA is doing shame on them. Bruce has posted some data that shows a correlation between BMI/neck size and sleep apena. But I have yet to see how any of this is fixing a problem that is affecting aviation safety. That is the question to ask, how much of a problem is sleeping in the cockpit, how many accidents has been caused by it and then we ask what causes the sleep problem. It may be something else other than this undiagnosed sleep apena thing. This is a simple science process.
Instead what it is looking like is someone who has a solution but has not yet defined what it is fixing.
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I think that's a valid question. Which brings up the question related to the events that supposedly triggered this: Were the pilots of the NWA flight that overshot MSP later shown to have undiagnosed OSA? How about the sleeping beauties in the tower at Reagan National??
 
I am always amused by the popcorn gallery who thinks that energy expended here means anything. Go fight among yourselves and make the planet right.

He HAS the authority to do this, it was granted in 1953.
"Normal natural health, or equivalent safety as determined byt he federal air surgeon on best medical advice".

No discrimination going on here, fellas. You can fly a 737 on a third class.
 
bbchien said:
I am always amused by the popcorn gallery who thinks that energy expended here means anything. Go fight among yourselves and make the planet right.
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I realize that discussions like this may be painful for medical professionals to watch, but if nothing else, many of us are gaining a better understanding of the issue, and of whether it's worth complaining to our representatives and/or AOPA, or if it's better to just go with the flow.

He HAS the authority to do this, it was granted in 1953.
"Normal natural health, or equivalent safety as determined byt he federal air surgeon on best medical advice".
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That doesn't seem to be in Part 67. Is that a statute that you're quoting, and if so, which one?

You can fly a 737 on a third class.
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Maybe that's part of the problem. On my driver's license, I can't drive trucks above a certain number of axles (and/or weight?), even if it's for non-commercial purposes.
 
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Palmpilot said:
That doesn't seem to be in Part 67. Is that a statute that you're quoting, and if so, which one?
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IIRC it's in the act that changed the CAR to the FAA. That would be about the time I was born....But it also existed in the legislation that created the CAR.
Maybe that's part of the problem. On my driver's license, I can't drive trucks above a certain number of axles (and/or weight?), even if it's for non-commercial purposes.
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Yes. Now, do you wish to create a FOURTH class medical? OMG.
 
It's a done deal. FAA can make it hard, or FAA can make it (relatively) easy. I hope AOPA and others wake up to that and put energy into keeping it simple.
 
bbchien said:
Yes. Now, do you wish to create a FOURTH class medical? OMG.
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I was thinking more in terms of a second class medical for aircraft above a certain size. But AOPA would have a fit.
 
Palmpilot said:
I was thinking more in terms of a second class medical for aircraft above a certain size. But AOPA would have a fit.
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The last thing we want is a larger bureaucracy, Richard. Seriously.
DFH65 said:
I just don't get why the AOPA doesn't fight to get rid of the SI and just make it a check box on the form that the AME can handle. If I have OSA and I show the AME that I am compliant check the box and move on. At least from what I have heard that the SI is not hard to get but if you are universally going to approve it let the AME do it.
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DFH, did you know that just last month I got a guy's record straight and got him on the Sleep Apnea SI. The AME in Georgia had been telling airmen,
(1) do you still have sleep apnea?
(2) Well, it's treated, isn't it?
(3) So do you still have it?
No, I don't think they're going to let the AMEs do it.
 
The part that kills me about this is that they announced this under the guise of preventing pilots from falling asleep on the job.....while they do absolutely NOTHING to address the divide between 121 pax carriers and cargo on rest rules. This is the same organization that thinks it is okay to fly a 747 with no sleep as long they only carry boxes.
 
Fearless Tower said:
The part that kills me about this is that they announced this under the guise of preventing pilots from falling asleep on the job.....while they do absolutely NOTHING to address the divide between 121 pax carriers and cargo on rest rules. This is the same organization that thinks it is okay to fly a 747 with no sleep as long they only carry boxes.
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Well, we owe that to the senator from Fed Ex.....
 
Unregistered said:
Great idea. Start with CDL and it should only take a month to create the new standard.
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In the fall of 2010 we had federal suppor t(and I will not out this person) for just that: Super light sport on a State CDL. Y'know what Craig Fuller said? He said, "we can't do that. It doesn't look proactive enough".

So in short, I proposed that 3 years ago. 'So long, fuller! good riddance!".

Well, guess what. He got real far trying to demand an exemption for 35,000, huh?.
 
bbchien said:
DFH, did you know that just last month I got a guy's record straight and got him on the Sleep Apnea SI. The AME in Georgia had been telling airmen,
(1) do you still have sleep apnea?
(2) Well, it's treated, isn't it?
(3) So do you still have it?
No, I don't think they're going to let the AMEs do it.
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If they don't trust their own AME's then what is the point of any of this? If it is simply a trust issue with the AME then somehow that needs to be addressed.

Having said that the reasoning the "bad" AME gives above in my view is not an unreasonable standard to follow. If the goal is to make sure that pilots are healthy and unlikely to become incapacitated for medical reasons in flight that logic should apply to almost anything. Do you have an issue? Is it properly addressed? Then it's not an issue.

If the point is to cover your butt in a congressional inquiry then I guess we are doomed. In reality the FAA giving it's blessing is just a control issue as the boots on the ground AME or the person's personal physician are certainly far more capable of judging a persons capacity for flight than someone looking at paperwork in OKC.


I think we can all agree that if the 3rd class was abolished planes would not start falling out of the sky on a daily basis the evidence of that is statistically pretty clear. This is not going to happen so why not keep the standards but eliminate all the hoop jumping. Let the trained pros do the work.
 
bbchien said:
In the fall of 2010 we had federal suppor t(and I will not out this person) for just that: Super light sport on a State CDL. Y'know what Craig Fuller said? He said, "we can't do that. It doesn't look proactive enough".

So in short, I proposed that 3 years ago. 'So long, fuller! good riddance!".

Well, guess what. He got real far trying to demand an exemption for 35,000, huh?.
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Again, AOPA taking the wrong stand on an issue... It's also coming home to bite them now that they took the wrong stand at helping Runway Finders and the rest fight the Patent Infringement lawsuit, and now they're looking at the same.

Back to this one though, since the CDL already has the SA issue in their scope of standards, all that going to a CDL medical would is speed the action of this issue up.
 
Fearless Tower said:
If AOPA is taking the wrong stand, then they are in good company. NBAA and EAA have also come out in opposition.

Still crickets from the unions though.
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Not surprising, it's simpler to just deny than to come up with a cognitive plan that achieves the required result with the minimum disruption. In the end they will lose their battle and the results will be suboptimal rather than negotiating for an optimal result.
 
Henning said:
Well, in those terms, everything about human aviation is in defiance of God, if God had meant us to fly we would be born with wings.
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LOL, if God had NOT meant us to fly, we would not have been born with the ability to design and build aircraft!
 
My money is that this is going to be overturned. There may be some remnant for AME's to advise a pilot to get tested, but that mandatory stuff went over like a fart in church. Hill's ****ed. Tenth floor is ****ed. ATO is saying they will have 15,000 SIs to issue because every ATCS is going to the local sleep center for a nickle diagnosis and enjoy some time off while they process it.

Good. These two are on some crusade that no one assigned them.
 
Henning said:
Not surprising, it's simpler to just deny than to come up with a cognitive plan that achieves the required result with the minimum disruption. In the end they will lose their battle and the results will be suboptimal rather than negotiating for an optimal result.
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Oh there is another plan to address fatigue....it's called crew rest rules. But unfortunately, it is easier to stick the bill for this on the pilots or taxpayers (if Obamacare is going yo cover any of it like Bruce suggested), than it is to fight the lobby power of FedEx/UPS.
 
It's been pointed out that truckers are having to do this, but according to yesterday's letter from AOPA to The Administrator, Congress has decreed that the truckers' mandate will have to go through the NPRM process:

"Just last month, a similar attempt to bypass the rulemaking process failed when Congress intervened after the Department of Transportation attempted to require sleep apnea testing for commercial truck drivers. Public Law 113-45 now requires the Federal Motor Carrier Safety Administration to use a formal rulemaking process if it wishes to require such testing."​

http://www.aopa.org/-/media/Files/AOPA/Home/News/All News/2013/November/Huerta OSA.pdf
 
Fearless Tower said:
Oh there is another plan to address fatigue....it's called crew rest rules. But unfortunately, it is easier to stick the bill for this on the pilots or taxpayers (if Obamacare is going yo cover any of it like Bruce suggested), than it is to fight the lobby power of FedEx/UPS.
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This isn't about normal fatigue that rest can cure. The problem with OSA is that during the rest period oxygen deprivation occurs and increases the fatigue as well as doing other damage. I bunked with a big guy way back who snored like a freight train and there were times when I'd hear him 'hitch' and stop breathing for minutes at a time. This was on Sperry Rail Service and when he'd be driving he'd sometimes fall asleep backing up 3 rail lengths, you had to be careful about giving him the 'all stop' and jumping behind the car to do the hand test because he might not stop.

That is why they want these guys on O2 while they sleep, so the sleep is effective at preventing fatigue. Crew rest does no good if you have sleep apnea, that's the problem they are trying to address.
 
Henning said:
This isn't about normal fatigue that rest can cure. The problem with OSA is that during the rest period oxygen deprivation occurs and increases the fatigue as well as doing other damage. I bunked with a big guy way back who snored like a freight train and there were times when I'd hear him 'hitch' and stop breathing for minutes at a time. This was on Sperry Rail Service and when he'd be driving he'd sometimes fall asleep backing up 3 rail lengths, you had to be careful about giving him the 'all stop' and jumping behind the car to do the hand test because he might not stop.

That is why they want these guys on O2 while they sleep, so the sleep is effective at preventing fatigue. Crew rest does no good if you have sleep apnea, that's the problem they are trying to address.
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Yet the is no proof that OSA has been a factor in aviation accidents while fatigue in General has.

That is my issue with this. I'm personally not affected (even at my heaviest, I haven't gone over 28). My issue with the way that the FAA is going about doing this is that the end doesn't justify the means. The biggest benefit of forcing folks to do sleep studies is for longer life. I see that as a bigger issue with OSA than an aviation safety one. The FAA might as well start requiring pilots who smoke to undergo lung exams.

In the professional setting, if a pilot has OSA bad enough that he is falling asleep in flight, it is going to be noticed. The odds of two pilots falling asleep because they both have OSA are MUCH smaller than the odds of two pilots fatigues from flying the same extended schedule and making fatal errors.
 
Fearless Tower said:
Yet the is no proof that OSA has been a factor in aviation accidents while fatigue in General has.

That is my issue with this. I'm personally not affected (even at my heaviest, I haven't gone over 28). My issue with the way that the FAA is going about doing this is that the end doesn't justify the means. The biggest benefit of forcing folks to do sleep studies is for longer life. I see that as a bigger issue with OSA than an aviation safety one. The FAA might as well start requiring pilots who smoke to undergo lung exams.

In the professional setting, if a pilot has OSA bad enough that he is falling asleep in flight, it is going to be noticed. The odds of two pilots falling asleep because they both have OSA are MUCH smaller than the odds of two pilots fatigues from flying the same extended schedule and making fatal errors.
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As I said, OSA prevents rest from relieving fatigue. Now, lets combine both minimum crew rest and no proper sleep and what can we predict for results?
 
Fearless Tower said:
Yet the is no proof that OSA has been a factor in aviation accidents while fatigue in General has.

That is my issue with this. I'm personally not affected (even at my heaviest, I haven't gone over 28). My issue with the way that the FAA is going about doing this is that the end doesn't justify the means. The biggest benefit of forcing folks to do sleep studies is for longer life. I see that as a bigger issue with OSA than an aviation safety one. The FAA might as well start requiring pilots who smoke to undergo lung exams. [Emphasis mine]
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EXACTLY!!

AS others have said, it's a precedence, and in the time it takes for Henning will think up another "this one time at band camp" anecdote, you can bet your bottom dollar the list of things we have to prove to the FAA will increase by leaps and bounds.
 
Henning said:
That is why they want these guys on O2 while they sleep, so the sleep is effective at preventing fatigue. Crew rest does no good if you have sleep apnea, that's the problem they are trying to address.
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CPAP isn't the same as O2, but has an affect. It applies a measured air pressure (determined during the sleep study) that is enough to keep your airway open. Because your airway stays open, there are no apneas (realistically, there are always a few but below the threshold for OSA) and your O2 saturation levels reach normal. Apneas result in poor O2 and CO2 levels. But the other problem is that the apnea causes gasping for breath, which interrupts sleep and bring you to an awake state. You may still be asleep, but an EEG shows you are in a stage 1 level (not really awake, but not really asleep.) You end up spending very little time at all in REM sleep - one of the deepest levels, where you dream and get the best rest. So, it messes with your O2 sats, and you will not get a restful sleep. This happens every night.

Many people who start CPAP therapy have very vivid dreams as their brains readjust to real REM sleep. I know I did.
 
Hmm.

My BMI is currently 37.7, down from a high of 39.6.
For me, a 40 BMI (Morbidly Obese) = 329 lb.
35 BMI (Severely Obese) = 288 lb.
30 BMI (Moderately Obese) = 246 lb.
25 BMI (Merely Overweight) = 205 lb.

Best shape I've ever been in my life at this height was when I first reached this height and was on tour with a drum and bugle corps the entire summer, rehearsing and performing. Heckuva great workout, and we were fed healthy food. At that point - Again, *just* having grown to my adult height - I weighed 180, for a BMI of 21.9. I had so little body fat, you could see the blood vessels standing out on my arms, and you could see my ribs too. But, if I'd lost another 28 lbs. I'd have still been considered healthy.

I've suspected some possible issues with OSA in the past when I was at my peak weight - But that's because I was told I snored a lot, and occasionally, I'd snort and wake myself up as I was falling asleep. I've never felt really tired during the day, and can easily go for 20 hours after a good night's sleep before I start to feel tired.

What I really dread is a possible diagnosis of "mild" OSA. That's the worst of all. If your problem is more severe, you get a CPAP and you get your SI. If they don't decide it's bad enough for the machine, you get to do the maintenance of wakefulness test like one friend of mine. He described it to me, and it sounds like even someone with no OSA at all who got a great night's sleep would have trouble staying awake!

I also don't look forward to the time, cost, and hassle of getting the study done - I just happen to have an 18" neck, so despite my BMI being a few points lower than they're casting the net right now, I'm gonna have to do it. This really does seem like a witch hunt.
 
This pretty much sums up my problem...

The medical establishment has acknowledged major shortcomings of BMI. Because the BMI depends upon weight and the square of height, it ignores basic scaling laws whereby mass increases to the 3rd power of linear dimensions. Hence, larger individuals, even if they had exactly the same body shape and relative composition, always have a larger BMI. Also, its assumptions about the distribution between lean mass and adipose tissue are inexact. BMI generally overestimates adiposity on those with more lean body mass (e.g. athletes) and underestimates excess adiposity on those with less lean body mass.
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So, if you're tall and muscular, you're screwed when it comes to BMI...
 
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