More Change at FAA medical

[Anthem]

Right. And what is so magical about a 3rd class compared to a BM that the 3rd should allow this? Especially considering the number and types of SIs given for a 3rd. A 3rd class isn't typically preventing people from flying due to medical conditions; it's merely (?) causing them to spend lots of money and have unneccesary tests for the privilege.

It definitely weeds out quite a few. There isnt much difference if at all in the SI process for 1st and 2nd class either. So are you advocating getting rid of those as well ?

That's one of the big problems with OKC: lack of imagination. Try stretching yours a bit. Look at the data we have from BM and SP and use it to draw meaningful, fact-based conclusions, rather than simply defaulting to "I cannot imagine..."

You dont have data that substantiates any position. Any data you have is flawed if you change the parameters of attaining whatever mythical set of standards that you are proposing. You cant use your data across the board because it has eliminated a significant portion of the "problems" from your statistical sample. If you use the current set of "data" - that doesnt fit the narrative that you want. If it does - then guess what - lets not change anything.

 

[Half Fast]

you dont have data that substantiates any position.

Bunk.

https://www.faa.gov/sites/faa.gov/files/PL_114-190_Sec_2307_Effects_Regulatory_Changes_to_Medical_Certification_Certain_Small_Aircraft_Pilots.pdf

From the "Findings In Brief" section

Despite the facts that:

• BasicMed pilots are older on average than airmen maintaining third-class certification and the​

pre-implementation third-class population.​

• BasicMed allowed more than 18,000 airmen to conduct operations in aircraft that qualify for​

BasicMed. These airmen did not hold a medical certificate in the six months prior to qualifying for​

BasicMed and would not have been permitted to operate any aircraft other than balloons, gliders​

or light sport aircraft without a medical certificate.​

• Over half of BasicMed airmen had their last medical certificate examination between three and​

five years prior to registering for BasicMed, and 67 percent of BasicMed airmen had expired​

medical certificates at the time of registering for BasicMed.​

• BasicMed airmen are much more likely to have required a Special Issuance. Referencing the​

meaning and purpose of a Special Issuance, this reflects a potentially elevated risk of​

incapacitation among the BasicMed population in the context of reduced FAA oversight...​

Nevertheless,

• No difference was found in the risk of BasicMed and third-class airmen having an aviation​

accident from the start of BasicMed in 2017 through the end of 2019.​

• No difference was found between accident-involved BasicMed and third-class airmen in the​

phase of flight in which their accident occurred.​

• No difference was found between accident-involved BasicMed and third-class airmen in fatal​

versus non-fatal outcomes.​

• No difference was found between fatally injured BasicMed and third-class airmen in autopsy​

findings.​

We also read that

• When restricted to medically related death, BasicMed airmen had an age- and Special-Issuance-​

adjusted risk of mortality over the study period 53 percent higher than airmen who maintained​

third-class certification.​

• BasicMed airmen had an age- and Special-Issuance-adjusted risk of death from stroke or​

myocardial infarction three times the risk for airmen who maintained third-class certification.​

These conditions pose an increased risk of sudden incapacitation.​

• BasicMed airmen had twice the age- and Special-Issuance-adjusted risk of death from cancer​

than airmen who maintained third-class certification.​

That would seem to indicate that things like stroke or myocardial infarction are statistically insignificant in the context of aviation accidents, since they're more likely for BM pilots yet there was no difference in risk of accidents between BM and class 3.

 

[Anthem]

Bunk.

https://www.faa.gov/sites/faa.gov/files/PL_114-190_Sec_2307_Effects_Regulatory_Changes_to_Medical_Certification_Certain_Small_Aircraft_Pilots.pdf

From the "Findings In Brief" section

Despite the facts that:

• BasicMed pilots are older on average than airmen maintaining third-class certification and the​

pre-implementation third-class population.​

• BasicMed allowed more than 18,000 airmen to conduct operations in aircraft that qualify for​

BasicMed. These airmen did not hold a medical certificate in the six months prior to qualifying for​

BasicMed and would not have been permitted to operate any aircraft other than balloons, gliders​

or light sport aircraft without a medical certificate.​

• Over half of BasicMed airmen had their last medical certificate examination between three and​

five years prior to registering for BasicMed, and 67 percent of BasicMed airmen had expired​

medical certificates at the time of registering for BasicMed.​

• BasicMed airmen are much more likely to have required a Special Issuance. Referencing the​

meaning and purpose of a Special Issuance, this reflects a potentially elevated risk of​

incapacitation among the BasicMed population in the context of reduced FAA oversight...​

Nevertheless,

• No difference was found in the risk of BasicMed and third-class airmen having an aviation​

accident from the start of BasicMed in 2017 through the end of 2019.​

• No difference was found between accident-involved BasicMed and third-class airmen in the​

phase of flight in which their accident occurred.​

• No difference was found between accident-involved BasicMed and third-class airmen in fatal​

versus non-fatal outcomes.​

• No difference was found between fatally injured BasicMed and third-class airmen in autopsy​

findings.​

We also read that

• When restricted to medically related death, BasicMed airmen had an age- and Special-Issuance-​

adjusted risk of mortality over the study period 53 percent higher than airmen who maintained​

third-class certification.​

• BasicMed airmen had an age- and Special-Issuance-adjusted risk of death from stroke or​

myocardial infarction three times the risk for airmen who maintained third-class certification.​

These conditions pose an increased risk of sudden incapacitation.​

• BasicMed airmen had twice the age- and Special-Issuance-adjusted risk of death from cancer​

than airmen who maintained third-class certification.​

That would seem to indicate that things like stroke or myocardial infarction or statistically insignificant in the context of aviation accidents, since they're more likely for BM pilots yet there was no difference in risk of accidents between BM and class 3.

Again, you're data is suspect and wrong. just like I and the other docs have mentioned. Your BM data is using a set of data from an already cleared set. There is/was a pre-requisite of having already passed a class 1/2/3 medical before you were eligible for BM. Therefore, many repeated alcoholics, drug use, mental health (bipolar, spectrum, major depression, suicidality), coronary/stroke, and other disqualifying factors) have all been previously eliminated, or the few that passed were accepted with passable standards. Yes. they dont have to maintain that standard every year, but they had to have passed it the first time -which is a significant barrier (look at all the posts here). When you open it up to just everybody with a drivers license (which the above subset group all probably possess) without that first gate, then that data becomes significant. Since you dont have it - your data isnt relevant for what you are proposing and arguing over.

So your data that is saying there isnt a statistical difference between basicMed and class 1/2/3 incidents at the current time with the current restrictions is somewhat valid - though Dr Chien argues that there are significant aviation related issues that regular non aviation docs are not familiar with for higher altitude, G's, etc.. But nonetheless - the data is not valid or statistically accurate or can be successfully extrapolated for what the "just having a license" crowd is arguing for what they want BM with just a drivers license to be is. That data above is comparing 3rd class against ex-third class (or 1st/2nd as well) who have evolved to BM. Thats the comparison. You think that would be the same if opened up to anyone with a drivers license compared to 3rd class ? I call bull.....

Its like saying - Im going to use the commited crime per 100000 people statistical rate, but Im going to eliminate all the previous criminals from that data. So yes, your data is bunk.

 

[Half Fast]

Your BM data is using a set of data from an already cleared set. There is/was a pre-requisite of having already passed a class 1/2/3 medical before you were eligible for BM.

True, but a large number of those BM pilots had expired medicals from many years prior. I am not convinced that an old expired medical means anything in terms of the screening you’re worried about.

And I’ll point out that SPs do not even get that screening. Are SPs crashing at a higher number as a result?

You think that would be the same if opened up to anyone with a drivers license compared to 3rd class ? I call bull.....

I say bull to your bull.

I think any difference would be statistically insignificant, and I point to SP as rationale for that conclusion.

 

[Anthem]

True, but a large number of those BM pilots had expired medicals from many years prior. I am not convinced that an old expired medical means anything in terms of the screening you’re worried about.

And I’ll point out that SPs do not even get that screening. Are SPs crashing at a higher number as a result?

Again, your data is flawed. Many potential sport pilots have already been eliminated because they attempted a class 1/2/3 medical. Most didnt know that failing that medical eliminated them from holding sport. Again, first gate of entry stopped the largest potential risk factors from proceeding with sport.

If you dont think there is any difference, lets get rid of all class 1/2/3 medicals - including for airline pilots. Because there isnt a need for them, right ?

I say bull to your bull.

I think any difference would be statistically insignificant, and I point to SP as rationale for that conclusion.

And again, sport isnt wide open. You fail a medical - which the majority of people think is the first step and undertake, sport is eliminated. Also the sampling size for sport is quite small. So again, you need complete data from an open enrollment to anyone with a drivers license to substantiate your data. That isnt available or present, here nor another country.

"statistically insignificant" ? really. Open to just DL - all takers. Statistically insignificant ? I doubt any sane person would make that assertion. Which makes your argument bull. So again, for someone who always likes to point out deficiencies - your trying to extrapolate and use data that is missing the greatest potential risk factors. Convenient to twist statistics to fit by eliminating the largest potential issues. Again, see my felon quote above.

 

[Half Fast]

You fail a medical - which the majority of people think is the first step and undertake, sport is eliminated.

A majority?! Really? I don’t know where you get this stuff, but it’s bull.

I can see you’re stuck in a traditional FAA medical box. No point in further discussion. The class 3 emperor simply has no clothes, but you’ll continue to see elegant attire.

 

[Anthem]

A majority?! Really? I don’t know where you get this stuff, but it’s bull.

I can see you’re stuck in a traditional FAA medical box. No point in further discussion. The class 3 emperor simply has no clothes, but you’ll continue to see elegant attire.

Picking other parts to hang your hat on to, huh ? You're quitting because you cant pull up actual data to substantiate your claims.

As for majority - I am reasonably certain there are MORE pilots eliminated from contention because of medical that would like Sport privileges than their are actual Sport pilots. Otherwise the constant warning of - be careful with the medical or you will eliminate sport possibility wouldnt be there. There are very few SP pilots, and there is a reason for that. (though that number will probably grow with MOSAIC) - but the number that were eliminated and dont have access to Sport - continues to climb.

I see you're stuck in making arguments without the statistics to back it up. No further discussion necessary because you cant and dont have the data to do it.

 

[Jim_R]

A majority?! Really? I don’t know where you get this stuff, but it’s bull.

I can see you’re stuck in a traditional FAA medical box. No point in further discussion. The class 3 emperor simply has no clothes, but you’ll continue to see elegant attire.

Anthem has pointed out specific flaws in the logic you are using:

1) Everyone who holds a Class 1/2/3/BM has successfully passed a Class 1/2/3 exam at some point in their past. That eliminates some potential candidates who would have gotten through if the bar was lowered to "anyone who holds a DL". That's just a simple fact, and it skews the data. You cannot just wave your hands and ignore it if you are trying to responsibly consider valid conclusions that can be drawn from the data available.

2) At least some candidates who could have gotten a SP lost that chance by trying to get a Class 1/2/3 first, and failing. Anthem suggests that it's possible that most people have tried for a Class 1/2/3 first rather than going straight to SP, so it's possible that many people have been screened out. We don't have specific data for that, so who really knows for sure, but it's not credible to think that number is zero.

Those are facts, and you should acknowledge their existence and the effects they have on your argument if you want to be credible. Ignoring them or claiming that anyone who points them out has a "lack of imagination" is a poor way to counter their existence.

 

[UTLonghorn_1979]

For better or worse, we'll never know how many accidents that would have been caused by mental or physical health were prevented because the would-be pilots were screened out via the FAA medical cert process.

Not necessarily true. We have no idea how many pilots are hiding or lying on the applications. The application and screening are only as good as the applicant’s honesty on the application.

 

[Jim_R]

Not necessarily true. We have no idea how many pilots are hiding or lying on the applications. The application and screening are only as good as the applicant’s honesty on the application.

That doesn't change my original assertion. It only identifies additional uncertainty about a different conclusion.

 

[Half Fast]

Anthem has pointed out specific flaws in the logic you are using:

1) Everyone who holds a Class 1/2/3/BM has successfully passed a Class 1/2/3 exam at some point in their past. That eliminates some potential candidates who would have gotten through if the bar was lowered to "anyone who holds a DL". That's just a simple fact, and it skews the data. You cannot just wave your hands and ignore it if you are trying to responsibly consider valid conclusions that can be drawn from the data available. Yes, it may have eliminated some candidates who could not have received an SI, but I believe that number to be very small based upon the FAA's own statement that over 99% of applicants eventually receive a medical. Furthermore, the required Class 3 exam could have taken place 20 years ago! How good is that? In the study I cited, 2/3 of the BM pilots had expired medicals, so any "screening" was out of date. To say there is "no data" is incorrect; we have data sufficient to infer that the pre-req has little value. To get the exact data desired would require actually granting BM to pilots without the first FAA medical, and that's currently prohibited by law. SO, when considering whether to change that law, we have to use data what we have. I think that data is sufficient to try eliminating the pre-req.

2) At least some candidates who could have gotten a SP lost that chance by trying to get a Class 1/2/3 first, and failing. Anthem suggests that it's possible that most people have tried for a Class 1/2/3 first rather than going straight to SP, so it's possible that many people have been screened out. We don't have specific data for that, so who really knows for sure, but it's not credible to think that number is zero. I don't think it's credible to believe that "a majority" were screened out of SP. In fact, I think it's more likely that the SP group is biased toward people that would require an SI but aren't willing to go to the trouble and expense. I know that was my personal case when I first got a SP ticket.

Those are facts, and you should acknowledge their existence and the effects they have on your argument if you want to be credible. Ignoring them or claiming that anyone who points them out has a "lack of imagination" is a poor way to counter their existence. Now, I will still counter that clinging to the status quo in light of the credible evidence I've cited is ridiculous and shows an unwillingness to consider what the data is telling us.

Okay, I'll state this one more time. It is my contention that the 3rd class pre-req for Basic is not necessary. What data we have seems to indicate that the pre-req has little to no value. See my comments above.

I've cited data from which we can infer that the class 3 pre-req has little value for BM. Conversely, I've seen no data that shows the class 3 is warranted as a BM pre-req; merely a lot of hand-wringing speculation and mock horror at the thought of letting such people into cockpits of GA aircraft.

 

[Anthem]

Okay, I'll state this one more time. It is my contention that the 3rd class pre-req for Basic is not necessary. What data we have seems to indicate that the pre-req has little to no value. See my comments above.

I've cited data from which we can infer that the class 3 pre-req has little value for BM. Conversely, I've seen no data that shows the class 3 is warranted as a BM pre-req; merely a lot of hand-wringing speculation and mock horror at the thought of letting such people into cockpits of GA aircraft.

Where in the world are you jumping to the conclusion that the pre-req has little value for BM? Of course you are arguing not having that prereq. But the no value part and you stating that you have data just shows how your argument is rife full of problems. Just by having that there you have eliminated suicidal, bipolar, serious spectrum, adhd applicants. Your lack of seeing that and using your problematic data to justify it - seems to lack any sort of common sense. I mean where in the world is there any data that shows the pre-req having little value ? Because the current group has similar data ? Then how are you justifying removing that as having no relevance ? Really ?

Jim was nice enough to point it out even more obviously. But your lack of comprehension that a first level filter, filtering out almost all the more problematic applicants - as not being relevant is kind of mind boggling. And if that’s truly the case - then there shouldn’t be any class medicals by inference because you don’t see any statistical difference to a group that has no data.

You keep arguing and pointing out that you have the data. Point out the actual data that is relevant - that means you can’t eliminate an entire group that most people think will have the largest issue. It’s certainly not going to be less. So again - you argue for data - point out and justify it. Not some “seems to indicates” which no one with a sane mind would jump to the same conclusion.

 

[UTLonghorn_1979]

That doesn't change my original assertion. It only identifies additional uncertainty about a different conclusion.

That's true. And it is a certainty that there is an unknown and statistically significant number of the flying population, including major airline pilots, currently flying with mental health issues (anxiety, ADD/ADHD/depression/etc.) and aren't reporting them to AME's. If this was not the case, there would not be such a focus on addressing this within the FAA to make it "safe" and encouraging pilots to get help before they mentally break.

Anthem has pointed out specific flaws in the logic you are using:

1) Everyone who holds a Class 1/2/3/BM has successfully passed a Class 1/2/3 exam at some point in their past. That eliminates some potential candidates who would have gotten through if the bar was lowered to "anyone who holds a DL". That's just a simple fact, and it skews the data. You cannot just wave your hands and ignore it if you are trying to responsibly consider valid conclusions that can be drawn from the data available.

2) At least some candidates who could have gotten a SP lost that chance by trying to get a Class 1/2/3 first, and failing. Anthem suggests that it's possible that most people have tried for a Class 1/2/3 first rather than going straight to SP, so it's possible that many people have been screened out. We don't have specific data for that, so who really knows for sure, but it's not credible to think that number is zero.

Those are facts, and you should acknowledge their existence and the effects they have on your argument if you want to be credible. Ignoring them or claiming that anyone who points them out has a "lack of imagination" is a poor way to counter their existence.

The point is that if you had a valid class 1,2 or 3 on or after July 15, 2006 you can qualify for basic med. So a pilot that was 50 in 2006 is now 68 and can be flying under basic med. A lot can change in 18 years

Virtually every pilot I know flying under basic med KNOWS they would not be issued a class 3 without SI if at all so went the basic med route.
Hell, there are tons of post on this forum advising pilots that would not qualify for class 3 at next renewal to just go to basic med. This population has no statically significant different accident rate vs. class 3.

So many on this forum are okay that people that once held a medical in 2006 or after but would not be issued a class 3 are flying twins, turboprops, etc., but go ballistic thinking about making it more lenient for class 3 or eliminating it outright.

Again, my issue isn't with the standards, it's the timeline to get SI and the expense as well as inability for second professional opinions to have any impact on the FAA's decision.

 

[Half Fast]

Where in the world are you jumping to the conclusion that the pre-req has little value for BM?

As I explained above - because the class 3 exam is in most cases outdated, and may in fact be quite old, and because the SP population does not exhibit all the problems that seem to terrify you. It doesn't seem that you bother reading what I write, so why should I bother explaining further?

The perfect data set you seek would be illegal to obtain unless we change the law first, so you've settled for a catch-22 situation.

I mean where in the world is there any data that shows the pre-req having little value ?

You continue to ignore SP, and just wave your hands around it to say that it somehow doesn't count. Rubbish.

And what data do you have that shows the pre-req is necessary, besides your own fearful speculation?

 

[Anthem]

As I explained above - because the class 3 exam is in most cases outdated, and may in fact be quite old, and because the SP population does not exhibit all the problems that seem to terrify you. It doesn't seem that you bother reading what I write, so why should I bother explaining further?

The perfect data set you seek would be illegal to obtain unless we change the law first, so you've settled for a catch-22 situation.


You continue to ignore SP, and just wave your hands around it to say that it somehow doesn't count. Rubbish.

And what data do you have that shows the pre-req is necessary, besides your own fearful speculation?

And I continue to tell you. Your sp data is f’ing incomplete. You have eliminated all the people who attempted and failed to get a medical that are not under sport. It’s a filtered subset of a group of pilots that is NOT the entire drivers license at.

Using such data to justify a position wouldn’t be accepted by any medical, aviation or legal authority. But you continue to spout off on it.

That's true. And it is a certainty that there is an unknown and statistically significant number of the flying population, including major airline pilots, currently flying with mental health issues (anxiety, ADD/ADHD/depression/etc.) and aren't reporting them to AME's. If this was not the case, there would not be such a focus on addressing this within the FAA to make it "safe" and encouraging pilots to get help before they mentally break.

The point is that if you had a valid class 1,2 or 3 on or after July 15, 2006 you can qualify for basic med. So a pilot that was 50 in 2006 is now 68 and can be flying under basic med. A lot can change in 18 years

Virtually every pilot I know flying under basic med KNOWS they would not be issued a class 3 without SI if at all so went the basic med route.
Hell, there are tons of post on this forum advising pilots that would not qualify for class 3 at next renewal to just go to basic med. This population has no statically significant different accident rate vs. class 3.

So many on this forum are okay that people that once held a medical in 2006 or after but would not be issued a class 3 are flying twins, turboprops, etc., but go ballistic thinking about making it more lenient for class 3 or eliminating it outright.

Again, my issue isn't with the standards, it's the timeline to get SI and the expense as well as inability for second professional opinions to have any impact on the FAA's decision.

And your argument justifies NOT opening it up further. Because if you believe there is an issue with people who last had a medical 18 years ago is an issue - then maybe we shouldn’t allow it, right ?

But seriously - if you introduce a large group of disqualifying conditions people in your the flying pool - let’s say bipolars, Autistic, or anxiety without clearing some set of hurdles - you can’t say that it will be safer. I’m involved with a lot of high school kids. There are kids that just shouldn’t be flying - period.

And I noticed that after pointing it out - that your issue isn’t just timelines. You’ve now also included other things….

 

[Half Fast]

And I continue to tell you. Your sp data is f’ing incomplete.

I disagree, but y'know, in the real world, sometimes we have to move forward with incomplete data. The perfect and complete data set you seek is illegal to obtain. We would have to change the pre-req law first.

You have eliminated all the people who attempted and failed to get a medical that are not under sport.

You seem to think that's a significant number, but you've shown nothing whatsoever to justify that conclusion. I argue the contrary; there are people who would require an SI or have disqualifying conditions that choose to avoid a medical by going with SP. You believe the SP population is a cleaner population; I believe it is biased toward those who can't get a medical.

Using such data to justify a position wouldn’t be accepted by any medical, aviation or legal authority. But you continue to spout off on it.

First of all - baloney. Second of all, it's not necessary to have the position accepted by "any medical, aviation or legal authority." It's only necessary to have it accepted by Congress, who made the BM law in the first place without data even as good as what we have today. In fact, the pre-req only came about at the insistence of one (now deceased) Senator.

But you will continue to insist that we must have a perfect and complete data set (illegal though it would be) prior to making a change. This is a condition known as paralysis.

 

[UTLonghorn_1979]

And your argument justifies NOT opening it up further. Because if you believe there is an issue with people who last had a medical 18 years ago is an issue - then maybe we shouldn’t allow it, right ?

But seriously - if you introduce a large group of disqualifying conditions people in your the flying pool - let’s say bipolars, Autistic, or anxiety without clearing some set of hurdles - you can’t say that it will be safer. I’m involved with a lot of high school kids. There are kids that just shouldn’t be flying - period.

And I noticed that after pointing it out - that your issue isn’t just timelines. You’ve now also included other things….

No, it argues for more parity between BM and class 3 medical certification.

What other things?

 

[Anthem]

No, it argues for more parity between BM and class the medical certification.

What other things?

Your previous assertion was that you only cared about timelines. And it being less than 6 months or something I believe. I pointed it out that I doubt that was the case - that I bet cost is also in there. You have no conveniently included time AND cost as what you have an issue with- which is different than your earlier assertion.

And I would agree with you that there is parity between him and medical certification. That while there might be a bit more risk - it may not be that big. HOWEVER - which is the caveat I keep pointing out - that’s with the prior medical class requirement that has eliminated many problem cases. Whether because of outright disqualification or whether because they were not willing or able to go through and pass it.

Also - there are significantly more and a capable planes in class 3 than others - whether by weight, by passenger count, by altitude. A Cessna 414/421 wasn’t eligible to be flown by anyone on BM. If that opened up - as dr Bruce opined above - there are issues with certain groups which “approved” by a personal pcp has no idea of the risk factors posed at altitude or higher Gs. But we seem to place blind faith that a doctor would know these things and is ok to approve.

 

[UTLonghorn_1979]

Your previous assertion was that you only cared about timelines. And it being less than 6 months or something I believe. I pointed it out that I doubt that was the case - that I bet cost is also in there. You have no conveniently included time AND cost as what you have an issue with- which is different than your earlier assertion.

And I would agree with you that there is parity between him and medical certification. That while there might be a bit more risk - it may not be that big. HOWEVER - which is the caveat I keep pointing out - that’s with the prior medical class requirement that has eliminated many problem cases. Whether because of outright disqualification or whether because they were not willing or able to go through and pass it.

Also - there are significantly more and a capable planes in class 3 than others - whether by weight, by passenger count, by altitude. A Cessna 414/421 wasn’t eligible to be flown by anyone on BM. If that opened up - as dr Bruce opined above - there are issues with certain groups which “approved” by a personal pcp has no idea of the risk factors posed at altitude or higher Gs. But we seem to place blind faith that a doctor would know these things and is ok to approve.

I figured anyone with familiarity of the SI process would know about the cost side. So yea, cost and timing…how unreasonable.

I’m not asking for lower requirements for class 3, I’m stating, just like Half Fast, that a class 3 medical exam from 2006 is just as valid a qualifier TODAY as a GP’s physical TODAY for a brand new pilot to qualify to also fly under BM as is just as valid as a pilot operating under SP TODAY.

Exactly what test are we talking about that would identify risk factors for high altitude or higher Gs that the class 3 med AME does? Honest question.

 

[Anthem]

I figured anyone with familiarity of the SI process would know about the cost side. So yea, cost and timing…how unreasonable.

I’m not asking for lower requirements for class 3, I’m stating, just like Half Fast, that a class 3 medical exam from 2006 is just as valid a qualifier TODAY as a GP’s physical TODAY for a brand new pilot to qualify to also fly under BM as is just as valid as a pilot operating under SP TODAY.

Exactly what test are we talking about that would identify risk factors for high altitude or higher Gs that the class 3 med AME does? Honest question.

Just clarifying a missing point.
You can argue that it is a qualifier. However you are conveniently ignoring the applicants that have been eliminated and are now eligible under your new plan because he (and presumably you) are arguing for releasing that qualifier. As for GP physicals - thats a real ****show on the "alternative fronts" which would/could be exploited. As I said - look at medical mj cards issued by doctors. Anyone can pay $100 for a doctor consult and have that signed. Ive seen it happen.

Read Dr Chien above. He said coronary issues that would normally disqualify until an AME passes it (via stress or whatever tests they requiore doing before getting your medical back after a cardio/pulmonary event that they do) vs just a doc saying - yeah, you're fit to bike, fly or whatever.

 

[Jon Wilder]

FAA announced at a grand rounds that eff. 1 Jan, if not everything that the FAA needs to approve the airman is present, they will issue a denial early. No more “please within 60 days send……”. It will be followed with a “for further consideration” letter. This locks the airman’s file for any issuance in the field.

The NTSB Safety Summit suggested doing the exact opposite! This is a step in the wrong direction. I also expect LOTS of complaints on this one. It's just them exerting more authority because they can.

According to briefings provided to aviation medical examiners this week, this change is being driven by the FAA’s legal interpretation of Section 801 in the FAA Reauthorization Act of 2024 (Public Law 118-63).

If we look that section up, it only has to do with amending the Pilot's Bill of Rights regarding the reexamination of airman certificates.

SEC. 801. REEXAMINATION OF PILOTS OR CERTIFICATE HOLDERS.
The Pilot’s Bill of Rights (Public Law 112–153) is amended
by adding at the end the following:
‘‘SEC. 5. REEXAMINATION OF AN AIRMAN CERTIFICATE.
‘‘(a) IN GENERAL.—The Administrator shall provide timely, writ-
ten notification to an individual subject to a reexamination of an
airman certificate issued under chapter 447 of title 49, United
States Code.
‘‘(b) INFORMATION REQUIRED.—In providing notification under
subsection (a), the Administrator shall inform the individual—
‘‘(1) of the nature of the reexamination and the specific
activity on which the reexamination is necessitated;
‘‘(2) that the reexamination shall occur within 1 year from
the date of the notice provided by the Administrator, however,
if the reexamination is not conducted within 30 days, the
Administrator may restrict passenger carrying operations;
‘‘(3) that if such reexamination is not conducted after 1
year from date of notice, the airman certificate of the individual
may be suspended or revoked; and
‘‘(4) when, as determined by the Administrator, an oral
or written response to the notification from the Administrator
is not required.
‘‘(c) EXCEPTION.—Nothing in this section prohibits the Adminis-
trator from reexamining a certificate holder if the Administrator
has reasonable grounds—
‘‘(1) to establish that an airman may not be qualified to
exercise the privileges of a certificate or rating based upon
an act or omission committed by the airman while exercising
such privileges or performing ancillary duties associated with
the exercise of such privileges; or
‘‘(2) to demonstrate that the airman obtained such a certifi-
cate or rating through fraudulent means or through an exam-
ination that was inadequate to establish the qualifications of
an airman.
‘‘(d) STANDARD OF REVIEW.—An order issued by the Adminis-
trator to amend, modify, suspend, or revoke an airman certificate

This deals with AIRMAN CERTIFICATES (Part 61/91)! It DOES NOT deal with MEDICAL CERTIFICATES (Part 67).

They're essentially trying to expand the scope of this section beyond what Congress will allow them to do. I suggest writing to the Congress Critters about this.

 

[UTLonghorn_1979]

Just clarifying a missing point.
You can argue that it is a qualifier. However you are conveniently ignoring the applicants that have been eliminated and are now eligible under your new plan because he (and presumably you) are arguing for releasing that qualifier. As for GP physicals - thats a real ****show on the "alternative fronts" which would/could be exploited. As I said - look at medical mj cards issued by doctors. Anyone can pay $100 for a doctor consult and have that signed. Ive seen it happen.

Read Dr Chien above. He said coronary issues that would normally disqualify until an AME passes it (via stress or whatever tests they requiore doing before getting your medical back after a cardio/pulmonary event that they do) vs just a doc saying - yeah, you're fit to bike, fly or whatever.

If 99% of those deferred ultimately are issued SI, then immediately allowed to move to
BM, then yes, I guess I am.

That or the FAA gets their crap together and processes deferrals/SI’s faster than 2 years.

 

[Anthem]

If 99% of those deferred ultimately are issued SI, then immediately allowed to move to
BM, then yes, I guess I am.

That or the FAA gets their crap together and processes deferrals/SI’s faster than 2 years.

Again. Numbers that are oft repeated. That number isn’t correct. That’s might be the number of special issuances “requested” - not the actual number denied. But people seem to keep repeating that. It’s when you go through and actually request to renew an existing or to say request an SI for OSA or something. Those requests end up being about 99 percent. Also, many SI's are not CACI approved, but data has to go to the FAA for them to issue for renewals, and those are also counted in the "success" column.

Also who knows the actual real number unskewed. In the last time they reviewed their own denials was 20+ years ago, and at that time they denied 8%. Their own documentation and training for AME's right now (quoted from wingmanMed) just says - "over 90% get certified" at the AME and are not deferred/denied.

The real number you need to concern yourself with is the number of actual denials as well as the number of deferrals that actually happened. Because the 1 percent number is the FAA uses AFTER the FAA has received ALL the information they requested. And even then, I imagine there are funny numbers in there to skew it to where they want. But if you are deferred early on, they request information and dont get it, it results in a denial and isnt counted. If you respond and at any time dont give them the information they are requesting - it doesnt count either. So if you think 99% of deferred applicants are eventually approved would be a reliance on bad data. Think about it - just the number of people who dont respond to a deferral and give up will easily exceed 1% - it might be 10%, 20%, of even higher. Not everyone who gets a deferral will continue down the path to the end. And if you realize how complete "99%" is and how difficult it is to attain - you'll realize that that number isnt correct or feasible in the same context of which you are speaking. So its a skewed number to say the least.

 

[UTLonghorn_1979]

Again. Numbers that are oft repeated. That number isn’t correct. That’s might be the number of special issuances “requested” - not the actual number denied. But people seem to keep repeating that. It’s when you go through and actually request to renew an existing or to say request an SI for OSA or something. Those requests end up being about 99 percent.

The real number you need to concern yourself with is the number of actual denials as well as the number of deferrals that actually happened. Because the 1 percent number is the FAA uses AFTER the FAA has received ALL the information they requested. And even then, I imagine there are funny numbers in there to skew it to where they want. But if you are deferred early on, they request information and dont get it, it results in a denial and isnt counted. If you respond and at any time dont give them the information they are requesting - it doesnt count either. So its a skewed number to say the least.

Well, at least you acknowledge that the FAA is full of CRAP in how they represent their approach and state that very few applicants are denied. Which I’ve stated in several posts. But you prove a different and troubling point…that the FAA creates a financial and timing burden to many applicants that they cannot overcome. So, many applicants that would eventually be issued SI are unable or unwilling to get to that point due to the costs and timing to do so. The barrier of entry for flying is already a luxury, the FAA makes that nearly impossible for many applicants that would otherwise be competent, thoughtful and safe pilots.

I’m not concerned about those that will ultimately be denied or those that should NOT be flying. I’m advocating a few things:
1. Make the deferral process less burdensome/utilize a tiered approach on evaluating the applicant based upon their level of medical certification and intended pilot mission vs. a 1 size fits all (i.e. social anxiety does not equal suicidal idealization or 1 DWI does not equal flying behind the yolk with a bottle of tequila, etc)

2. Get rid of the inability for pilots that can’t be issued class 3 medical to operate under SP privileges - it’s stupid that people can game the system, get a consult that tells them they would fail a class 3 then go operate under SP, but any reason for denial of class 3 (unless you spend in some instances $20K+ to get SI) can’t operate under SP.

3. Allow/mandate that certain current deferral reasons be issued SI by AME without deferral to OKC or DC. If the AME isn’t sure, allow applicant to have 2nd opinion/option to move to specialists like Dr. Chien that are more versed in certain fields. I.e., if all the reports come back to the FAA stating “recommend SI” then the AME can issue SI in office vs. it being sent to OKC/DC and sitting there for 8-12 months.

 

[Anthem]

Well, at least you acknowledge that the FAA is full of CRAP in how they represent their approach and state that very few applicants are denied. Which I’ve stated in several posts. But you prove a different and troubling point…that the FAA creates a financial and timing burden to many applicants that they cannot overcome. So, many applicants that would eventually be issued SI are unable or unwilling to get to that point due to the costs and timing to do so. The barrier of entry for flying is already a luxury, the FAA makes that nearly impossible for many applicants that would otherwise be competent, thoughtful and safe pilots.

I’m not concerned about those that will ultimately be denied or those that should NOT be flying. I’m advocating a few things:
1. Make the deferral process less burdensome/utilize a tiered approach on evaluating the applicant based upon their level of medical certification and intended pilot mission vs. a 1 size fits all (i.e. social anxiety does not equal suicidal idealization or 1 DWI does not equal flying behind the yolk with a bottle of tequila, etc)

2. Get rid of the inability for pilots that can’t be issued class 3 medical to operate under SP privileges - it’s stupid that people can game the system, get a consult that tells them they would fail a class 3 then go operate under SP, but any reason for denial of class 3 (unless you spend in some instances $20K+ to get SI) can’t operate under SP.

3. Allow/mandate that certain current deferral reasons be issued SI by AME without deferral to OKC or DC. If the AME isn’t sure, allow applicant to have 2nd opinion/option to move to specialists like Dr. Chien that are more versed in certain fields. I.e., if all the reports come back to the FAA stating “recommend SI” then the AME can issue SI in office vs. it being sent to OKC/DC and sitting there for 8-12 months.

Honestly, I agree with you on certain larger picture points. I disagree on the implementation of said points.

Do I think the FAA would benefit by being more streamlined ? Absolutely. At the same time, I almost think that the FAA intentionally wants some time on their side for certain things - whether thats DUI, SSRI, whatever. I think the time gives them a better track record to make their decision. The going beyond a year - yeah, I think thats way too much. 6-8 - absolutely ok since things can get complex.

As for costs, thats a double edged sword. They want someone they can trust that isnt going to be biased, that listens to their guidance. Doctors in the medical profession dont do that. Then there are those other docs that are essentially guns for hire. So in an ideal world, I kind of agree with you. In the implementation of said world - maybe not. I know for a fact that some have paid for an easy BM telemed thing. So essentially any thing from a non-trusted source can be purchased. AME's/HIMS AME/Senior ame - could theoretically fall under some dubious practices as well, but generally much less likely. And obviously there are AME's that are less stringent than others - sort of like DPEs - so there isnt a perfect world here.

The AME can issue for certain reasons. Even beyond the AASI ones that they do issue. Like for SSRI, they are allowed single instance, single diagnosis, less than a certain amount of time usage to be issued in house. Many are done that way that never do make it. So there is some leeway being given. Also, both of the new fast tracks can be issued on the spot if the applicant brings the required information - or within 14 days or whatever that timeframe is. So some things are "delegated" to AME's these days. And Ive heard many fast tracks are issued fairly quickly (within a few weeks) for those that didnt have all the required docs on initial consult as well. Kudos to them for that.

As for the Sport - thats a clusterf... As is some parts of BM which we've been discussing. The question is - do you allow someone that knowingly fails a medical to fly. Im not sure you do. If you know the person has BPD - and fails a medical - why are you allowing them in the air ? Yes I know that they can get there if they never apply - and thats a loophole in my opinion. I dont think they should or be allowed. In an ideal situation - I think that less information available to the general public is perhaps better. Not everyone should be flying (in my opinion). It isnt a right. Certain people are using that information beforehand (whether the consult, or not applying to retain Sport etc) to game the system. Maybe some of that solution is to prevent or not allow "consults" because only the better prepared ones and the ones that are advised utilize it. It catches a lot of people on the fly paper that are ignorant and havent done their homework. . . maybe by design. Maybe their should be an even lower class/standard of medical done by AME's for BasicMed AND Sport. Its not like AME's are overburdened and difficult to get appointments for (outside of the HIMS ones). And Sport doesnt bypass this either - so their isnt that loophole. Though congress has mandated BM to be by PCP, with prior medical class having not been denied, so that would have to change. Though technically a "consult" is actually not FAA endorsed, but is basically you hiring the doc for "consulting"' on the FAA medical. And Sport - well I think something more along medicals needs to be done especially with MOSAIC coming down the pipe.

But again, I agree with you on many larger topic items and issues. I dont agree on some of the implementation.

 

[jbarrass]

I get you don't trust the numbers and analysis of the FAA and the PP. That's fine, but many of us choose to use the best available (imperfect and flawed as it might be) data that exists (i.e. This NB: Direct .pdf link).

What I haven't seen is any concrete numbers or facts that show the current system works. Just a bunch of hypotheticals and scary what-if's. To move this along, can you share what actual numbers and analysis you are using?

In the absence of concrete evidence that it significantly protects the non-participating public, there should be a strong bias against a very expensive and intrusive Government program. I don't think the status quo meets that bar.

 

[Anthem]

I’m actually ok with where it’s at. Do I think it should be a bit faster ? Absolutely. But I’ll take what we have now - however flawed vs whatever free for all being proposed because some people are anti- government involvement, or it’s too costly or time consuming.

 

[FlyingBiscuit]

I’m actually ok with where it’s at. Do I think it should be a bit faster ? Absolutely. But I’ll take what we have now - however flawed vs whatever free for all being proposed because some people are anti- government involvement, or it’s too costly or time consuming.

Have you experienced a deferral?

 

[Anthem]

Have you experienced a deferral?

Yes. And I have an SI.

And have worked with many on initially getting their medical.

 

[Wheresmychute]

I’m actually ok with where it’s at. Do I think it should be a bit faster ? Absolutely. But I’ll take what we have now - however flawed vs whatever free for all being proposed because some people are anti- government involvement, or it’s too costly or time consuming.

How about the extremely simple answer and solution. Reduce the time it takes to process. Sure, you can say "The 6-8 months is required" or "It's a complicated process," but ultimately that's not the crux of the issue.

The issue is that the applications sit for months without being worked on. And that the FAA has no dedicated teams for specific groups of applicants (One team for drug history, one team for adhd, one team for depression/anxiety).

I'm in the process right now and its most definitely not okay where it's at. The issue is even compounded by basic med and first-class folks jockeying for attention. I'm intending to be a career pilot and need a first-class, I have more up for stake because flying is not just a hobby for me, and I would have much greater responsibility for the safety of others. But I see so much attention given to making basic med more efficient, while first class is snubbed.

Either way, BOTH can benefit from the FAA branching out a little. For mild cases give folk a 6-8 month wait, and then let a HIMS AME or even ordinary AME issue with supporting documentation (psychiatric evaluation) to determine that the pilot is no risk to themselves or others. Let AME's charge a nice chunk of money so they don't feel like they are left out of the profits gained from a lengthy SI process. That way the FAA will get more done for cheaper, they already have the AME's just amend some regulations and that's it.

 

[UTLonghorn_1979]

How about the extremely simple answer and solution. Reduce the time it takes to process. Sure, you can say "The 6-8 months is required" or "It's a complicated process," but ultimately that's not the crux of the issue.

The issue is that the applications sit for months without being worked on. And that the FAA has no dedicated teams for specific groups of applicants (One team for drug history, one team for adhd, one team for depression/anxiety).

I'm in the process right now and its most definitely not okay where it's at. The issue is even compounded by basic med and first-class folks jockeying for attention. I'm intending to be a career pilot and need a first-class, I have more up for stake because flying is not just a hobby for me, and I would have much greater responsibility for the safety of others. But I see so much attention given to making basic med more efficient, while first class is snubbed.

Either way, BOTH can benefit from the FAA branching out a little. For mild cases give folk a 6-8 month wait, and then let a HIMS AME or even ordinary AME issue with supporting documentation (psychiatric evaluation) to determine that the pilot is no risk to themselves or others. Let AME's charge a nice chunk of money so they don't feel like they are left out of the profits gained from a lengthy SI process. That way the FAA will get more done for cheaper, they already have the AME's just amend some regulations and that's it.

Totally agree. My issue is primarily with the timing. It makes no sense that the FAA makes an applicant, in order for deferral consideration, visit a HIMS AME and HIMS specialists (psychologists/neuropsychologists) that the FAA has already vetted as an FAA approved expert in the field, and that those experts can't just say "yay or nay" and then the HIMS AME/AME then issue in office based upon the specialists' recommendations. That would literally get the timing down to 30-60 days, which is the timing that the FAA required of the applicant to conduct such requirements.

It's a waste of time, effort and resources.

 

[DJTorrente]

a financial and timing burden to many applicants that they cannot overcome.

In a word: hazing. Every member of the "F8ck It! I'll get a motorcycle [or play golf]!" crowd does not represent an accident that OKC saved us from. If the SI statistics are correct, each is merely another 99/100ths of an aviator that OKC just drove away.

Imagine for just a moment that the same requirements were made of the >200,000,000 licensed motorists in this country and reassess whether OKC writ large represents a viable cost/risk balancing.

 

[Anthem]

In a word: hazing. Every member of the "F8ck It! I'll get a motorcycle [or play golf]!" crowd does not represent an accident that OKC saved us from. If the SI statistics are correct, each is merely another 99/100ths of an aviator that OKC just drove away.

Imagine for just a moment that the same requirements were made of the >200,000,000 licensed motorists in this country and reassess whether OKC writ large represents a viable cost/risk balancing.

Last time they reported (via an FOIA) statistics - the 3rd class denial rate was 8%. . . Prior to that, first class denials are generally double the 3rd class. . . so using that data - how is the 99% being factored? You know as well as I do that that is a funny and not reliable number. Because just the people who drop off and say "**** it" will easily exceed the 1% number

 

[UTLonghorn_1979]

In a word: hazing. Every member of the "F8ck It! I'll get a motorcycle [or play golf]!" crowd does not represent an accident that OKC saved us from. If the SI statistics are correct, each is merely another 99/100ths of an aviator that OKC just drove away.

Imagine for just a moment that the same requirements were made of the >200,000,000 licensed motorists in this country and reassess whether OKC writ large represents a viable cost/risk balancing.

Yep. The "we did X therefore we prevented Y" is illogical.
I guess we'll see what happens in the year 2100 when we're all driving flying cars.

 

[DJTorrente]

Yep. The "we did X therefore we prevented Y" is illogical.

It's the perfect corollary to the "Not on my watch" mindset. How many airplane crashes can one agency prevent? All of them -- just make sure no one flies.

I guess we'll see what happens in the year 2100 when we're all driving flying cars.

I don't have to wonder what would have happened if Henry Ford had to face the "Federal Automobile Administration" -- we have the front row seat. The Otto cycle was discovered in 1876; Ford Motor Company was able to build 14 million Model T's by 1927 -- one car (of just that one model) for every 10 US citizens, in less than 50 years.

It's been over 120 years since Kitty Hawk.

 

[TCABM]

Last time they reported (via an FOIA) statistics - the 3rd class denial rate was 8%. . . Prior to that, first class denials are generally double the 3rd class. . . so using that data - how is the 99% being factored? You know as well as I do that that is a funny and not reliable number. Because just the people who drop off and say "**** it" will easily exceed the 1% number

While it doesn’t include denials, the Medical Statistical Handbook is enlightening.

The summary indicates overall applications requiring an SI is increasing despite a younger average age for applicants across the board.

https://www.faa.gov/data_research/research/med_humanfacs/oamtechreports/media/2022_statistical_handbook.pdf

 

[Wheresmychute]

While it doesn’t include denials, the Medical Statistical Handbook is enlightening.

The summary indicates overall applications requiring an SI is increasing despite a younger average age for applicants across the board.

https://www.faa.gov/data_research/research/med_humanfacs/oamtechreports/media/2022_statistical_handbook.pdf

I think they are actually correlated. I have no studies to back this up but I've seen people here express similar thoughts, its simply that younger people today are more aware of medical issues in general. Younger people have been diagnosed more often with medical problems requiring an SI, and may be more willing to admit it and start the process. All of these would be your classic "diagnosed with ADHD in first grade," "I got depressed in high school," etc.

It's probably a driving reason why the FAA has done anything at all lately with the SI process. I don't see this trend changing anytime soon so the FAA needs to buckle up.

 

[TCABM]

I think they are actually correlated. I have no studies to back this up but I've seen people here express similar thoughts, its simply that younger people today are more aware of medical issues in general. ….

That’s covered on the section about SIs. Biggest SI driver is Drugs and Alcohol. Specifically alcohol related event.

 

[Tools]

I think they are actually correlated. I have no studies to back this up but I've seen people here express similar thoughts, its simply that younger people today are more aware of medical issues in general. Younger people have been diagnosed more often with medical problems requiring an SI, and may be more willing to admit it and start the process. All of these would be your classic "diagnosed with ADHD in first grade," "I got depressed in high school," etc.

It's probably a driving reason why the FAA has done anything at all lately with the SI process. I don't see this trend changing anytime soon so the FAA needs to buckle up.

There’s an organization specifically representing this group, the PMHC. It’s a different demographic to be sure. BUT, they KNOW how to get things done in DC. I’m pretty sure they’re directly responsible for some language in the most recent reauthorization.

 

[Dana]

There are very few SP pilots, and there is a reason for that. (though that number will probably grow with MOSAIC) - but the number that were eliminated and dont have access to Sport - continues to climb.

There may be few actual SP certificate holders, but there are many more holders of private or higher certificates who are "exercising Sport Pilot privileges" with an expired medical... some because they know they won't pass, and some just want the hassle. I suspect the number of those who were eliminated from SP (or basicmed) by unexpectedly failing a medical is very small in comparison.


It's ironic that we're using ICAO as a reason to justify keep the class 3, when most other country's (and thus ICAO's) aviation regulations were originally based on the US regs, often even down to the section numbers.