Question on CPAP compliance any AMEs in the house?

"Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period."

My take on that is that, yeah, you can do a 7 hr night after a 5 hr night and get an average of 6 over two nights. But, the way the data is displayed in a report might not show it that way, it might show that you were "compliant" on only one of those two nights.

Starting this year compliance has to be shown over a year and not just the most recent 90 days. Over 365 nights, 75% works out to showing that you were >6 hrs for at least 274 of those nights. That lets you get up to 91 high-speeds plus other nights with zero usage per year. My guess is that FAA probably doesn't want to see all 91 of those lumped together right at the time you are trying to renew the SI.
 
On the bright side this should go away with PBOR2. If your doc thinks your good your good unless the FAA writes in some rules to the contrary.
 
On the bright side this should go away with PBOR2. If your doc thinks your good your good unless the FAA writes in some rules to the contrary.
If so, it will only go away for those who would normally only need a third class. The commercial folks will still have to deal with it.
 
I'm mostly curious about the time requirement. Some of those guys are doing 'high speeds' where they fly a late night leg to an out station. Crash in the hotel for a few hours and then fly the first flight back to the hub in the morning. I don't think they even get 6 hours in the hotel on those trips.
But from what Jonesy posts, isn't that a choice when bidding? Maybe if you are really junior you could get stuck with it, but I know some senior people who bid stand-ups so that they can have free time during the day.
 
If so, it will only go away for those who would normally only need a third class. The commercial folks will still have to deal with it.
Hopefully the reduction in OK City workload will shorten the wait for those who still have to apply for an SI.
 
I'm mostly curious about the time requirement. Some of those guys are doing 'high speeds' where they fly a late night leg to an out station. Crash in the hotel for a few hours and then fly the first flight back to the hub in the morning. I don't think they even get 6 hours in the hotel on those trips.
It's an average. A value of zero destroys an average, as I learned in high school. It takes 9 100% to make up for one zero to still get an 'A'. Even getting 25% (guessing and getting 1/4 correct) on a test reduces your "need for 100%" value to 7, getting 50% (educated guesses) reduces that to 4 100% tests to get to 90%.

I guess what I'm trying to say is that if you want to get to 6 hour average, don't ever skip a night. There are two aspects of this requirement: Avg: 6 hours/night, 75% of the time usage.
So, if you normally get 8 hours of sleep per night (I wish... I usually get 6-7, but I work OK with that...), you'll need 3 days of 8 hours' usage to get 6 hours/75% if you skip one night. However, even if you have it on for 2 hours one night, you'll be at 6 hours after 2 8 hour nights, and at 100% compliance.

Bottom Line: Wear it
 
On the bright side this should go away with PBOR2.
One would hope... But like so many other SI conditions, we don't know for certain until the final rules are published.
 
It's an average. A value of zero destroys an average, as I learned in high school. It takes 9 100% to make up for one zero to still get an 'A'. Even getting 25% (guessing and getting 1/4 correct) on a test reduces your "need for 100%" value to 7, getting 50% (educated guesses) reduces that to 4 100% tests to get to 90%.

I guess what I'm trying to say is that if you want to get to 6 hour average, don't ever skip a night. There are two aspects of this requirement: Avg: 6 hours/night, 75% of the time usage.
So, if you normally get 8 hours of sleep per night (I wish... I usually get 6-7, but I work OK with that...), you'll need 3 days of 8 hours' usage to get 6 hours/75% if you skip one night. However, even if you have it on for 2 hours one night, you'll be at 6 hours after 2 8 hour nights, and at 100% compliance.

Bottom Line: Wear it
It is a binary. Either the night is compliant or it is not. 5 hours and 58 minutes is a 0. 15 hours is a 1.
 
It is a binary. Either the night is compliant or it is not. 5 hours and 58 minutes is a 0. 15 hours is a 1.
On my Sleepyhead report, I have a few 3 hour nights and I'm still showing 100%. I can forward it to you, if you like.

it may be that your software is calculating the numbers differently.
 
It is a binary. Either the night is compliant or it is not. 5 hours and 58 minutes is a 0. 15 hours is a 1.

I also think this is what FAA is asking for: is it >6 or is it not. But the FAA doc says:

"Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period."

So as long as you add up all the usage hours per year and divide it by total nights used, you'll get an "average hours per sleep period", and as long as the nights used is >75% per year, that's good. Maybe?

On my Sleepyhead report, I have a few 3 hour nights and I'm still showing 100%. I can forward it to you, if you like.

it may be that your software is calculating the numbers differently.

Sleepyhead has a configuration that lets you set the compliance value. I think it defaults to 4, but FAA wants 6. This counts the number of nights > 6. But I think that "compliance reports" do averaging, too. This might be an apples and oranges thing. I need to look more closely at the different reports and the data that are compiled and used.
 
Weird, my last visit, my AME approved my SI renewal right on the spot. When did the 365 rule go into effect? I saw my AME in March with a 90-day report.
 
I'm mostly curious about the time requirement. Some of those guys are doing 'high speeds' where they fly a late night leg to an out station. Crash in the hotel for a few hours and then fly the first flight back to the hub in the morning. I don't think they even get 6 hours in the hotel on those trips.

I'm not sure it has to be 6 hours continuously.. just in any 24 hr period... to count.. and that only has to happen 75% of the time.
 
Weird, my last visit, my AME approved my SI renewal right on the spot. When did the 365 rule go into effect? I saw my AME in March with a 90-day report.
Fairly recently. As @Matthew can tell you, it snuck up on him and me and others. We are so used to the older requirement, that our scan of the letter was "nothing has changed" when actually it did change. You might find your SI letter, check the date it was written, and thoroughly read the requirements.
 
Weird, my last visit, my AME approved my SI renewal right on the spot. When did the 365 rule go into effect? I saw my AME in March with a 90-day report.


My last AME visit was in October for a renewal. Got it issued in office. Sometime in January I got the standard letter from FAA (3 months had passed). Everything was fine, yada yada yada. Buried in there were the new requirements.

You got renewed in March under the old letter. When you get your new letter, read it carefully.
 
I received my initial SI in September last years (from a July 8 AME appt). My letter said a "annual cumulative report". I had to get my CPAP provider to generate four quarterly reports as they don't have an annual. FAA accepted it no questions asked. Just over two weeks from sending in my required paperwork to receipt of my new SI medical good through end of July 2017.
 
I received my initial SI in September last years (from a July 8 AME appt). My letter said a "annual cumulative report". I had to get my CPAP provider to generate four quarterly reports as they don't have an annual. FAA accepted it no questions asked. Just over two weeks from sending in my required paperwork to receipt of my new SI medical good through end of July 2017.
Which is the way to do it if your machine only does 90 days, AND you were aware of the change in reporting requirements.

What Matthew and I are experiencing is, we didn't notice the change, and we didn't grab the data every 90 days.
 
Which is the way to do it if your machine only does 90 days, AND you were aware of the change in reporting requirements.

What Matthew and I are experiencing is, we didn't notice the change, and we didn't grab the data every 90 days.

There is a break - once:
  • For persons with an established diagnosis of OSA who do not have a recording CPAP, a one year exception will be allowed to provide a personal statement that they regularly use CPAP and before each shift when performing flight or safety duties.
 
I mistakenly believed it was only the most recent quarter as well...too much reading aviation boards instead of actual letter, I suppose. My provider was able to go back and retrieve the previous quarters from their database for me. They just aren't able to produce a single report covering the entire year. I have no idea what time period my machine actually stores on the SD card. It is much easier to send an email requesting it and just get an email back. :D
 
There is a break - once:
  • For persons with an established diagnosis of OSA who do not have a recording CPAP, a one year exception will be allowed to provide a personal statement that they regularly use CPAP and before each shift when performing flight or safety duties.
Depending on how the PBOR2 SI items get written up, this exemption might just work out!
 
I also think this is what FAA is asking for: is it >6 or is it not. But the FAA doc says:

"Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period."

So as long as you add up all the usage hours per year and divide it by total nights used, you'll get an "average hours per sleep period", and as long as the nights used is >75% per year, that's good. Maybe?



Sleepyhead has a configuration that lets you set the compliance value. I think it defaults to 4, but FAA wants 6. This counts the number of nights > 6. But I think that "compliance reports" do averaging, too. This might be an apples and oranges thing. I need to look more closely at the different reports and the data that are compiled and used.
I'm trying to parse this one out:
(From the Guide for AME, page 252, at Download, Print, or View the Complete AME Guide


For CPAP/ BIPAP/ APAP: A copy of the cumulative annual PAP device report. Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period.

If it had said, "A copy of the cumulative annual PAP device report. Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period." then I wouldn't argue, but that "average minimum" throws me, as I've only heard it phrased, "minimum average," since the average is the direct object, and we'd want the average (i.e. 5,6,7 would be 6) to be 6 hours. However, minimum can't be average, since it is a discreet value (the minimum of 5, 6, 7 ... 2,000,000,000 is 5, and there is no "average minimum", it is the least of all values in a population), and discreet values, the value is the average.

This wording is just weird...
 
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^^^
Yep.

But what about this?

Day 1: You get 3 hrs, get up to pee, get 3 more hours. You had one sleep period and averaged a minimum of 6 hours.
 
^^^
Yep.

But what about this?

Day 1: You get 3 hrs, get up to pee, get 3 more hours. You had one sleep period and averaged a minimum of 6 hours.

Dude... do you have cameras in my house? :eek:

As for the requirements, I'm sure that the doctors write these requirements, then send them to a lawyer, who screws them up, and then the doctors are trying to figure out what they required. To belabor the point (hey, I'm an engineer, and we write this crap too...), if the "average minimum" is 6 hours, and that's the threshold (5:59 = not good), the only way that you'll ever have 6:00 as an average is if you consistently have 6:00 (and no more, because if you have 6:01 one night, you've skewed the average up, and it can never return to 6:00 until that number falls off) of sleep.

Day 2: You get 2:59, get up to pee, get 3 hours more, and go to work. At work (at 2pm), you go to the nap room (Texas Instruments had these...) with your CPAP and get another minute of sleep.

Compliant?

Anyway... I think I'll be sure to get those 6 hour minima of sleep, just so I don't have to argue with the FAA through letters. It's like playing a game of chess across continents in 1965, and your opponent has the ability to throw the board.
 
Last Fall in preparing for by AME visit I generated a compliance report...
I discovered that at some point my CPAP machine had lost the ability to know what time it is...
(Probably dislodged the real time clock battery by dropping it) so my compliance report was garbage.... IE every time it lost power it started over again on Jan 1st 1980....

So I bought a new machine and finished the report with 1 or 2 days to spare.
This time period included a European vacation with a 12hr time change.
There were times where I lay in bed in Spain wide awake waiting for the 6hr mark to get there....

So I've started gathering monthly data myself using the sleepyhead software so I have
continuous proof the monitoring is working.

This is complicated by the fact I have a machine for home, a travel machine and a machine in the RV.

I've had the CPAP for 6 years I've missed exactly 2 days other than a bike accident in 2014 that had me off for 10 as facial lacerations healed.

You'd think that ones 6 year past history and record would count for something....

As for my earlier comments on the SoClean, I don't use the humidifier, so it still make a difference in my respiratory health.

Really looking forward to having PBOR2 in effect so I can stop having to manage this data collection.




Paul
 
I like many others it appears, missed the "annual" wording when I got my SI letter last year. I travel in a motor home and for simplification purchased a used CPAP and put it in the motor home. That way all I had to take was my mask. This older CPAP however does not record the data so I have missing nights in which I really did use my CPAP. I have stopped doing that and take my newer machine everywhere now. I am near the 75% number. I was one of those guys that never needed more than 4.5 to 5 hours sleep. With aging that has changed but I see a CRAP load of nights that are above 5.75 hours, but under the required 6, most likely from having to go to the bathroom in the middle of the night. Hard to always factor that in. As for the wording, how can you have an average minimum? I understand an average, a median, a minimum and a maximum, but not an average minimum.

My sleepyhead statistics (Thanks for the tip Doc Bruce) show that I have an average of 6:31 per night and 78% usage over the past year, but based on the overview page I am at 74.9% of days at or above the 6 hour threshold. I have a couple months to go and should be able to get that number above 75%, but I am kicking myself for missing the wording.

Will be scheduling with the good Dr as soon as I have another annual test done as requested by the good ole FAA, god bless em.
 
I
For me, I'd make sure I have mine. The difference in days with it and without it are striking.

Yeah, Verily. Even two hours (4 vs. 6) is a big difference. I just wish I didn't have to feel like an astronaut every night with the air hose attached to my mask.
 
I like many others it appears, missed the "annual" wording when I got my SI letter last year. I travel in a motor home and for simplification purchased a used CPAP and put it in the motor home. That way all I had to take was my mask. This older CPAP however does not record the data so I have missing nights in which I really did use my CPAP. I have stopped doing that and take my newer machine everywhere now. I am near the 75% number. I was one of those guys that never needed more than 4.5 to 5 hours sleep. With aging that has changed but I see a CRAP load of nights that are above 5.75 hours, but under the required 6, most likely from having to go to the bathroom in the middle of the night. Hard to always factor that in. As for the wording, how can you have an average minimum? I understand an average, a median, a minimum and a maximum, but not an average minimum.

My sleepyhead statistics (Thanks for the tip Doc Bruce) show that I have an average of 6:31 per night and 78% usage over the past year, but based on the overview page I am at 74.9% of days at or above the 6 hour threshold. I have a couple months to go and should be able to get that number above 75%, but I am kicking myself for missing the wording.

Will be scheduling with the good Dr as soon as I have another annual test done as requested by the good ole FAA, god bless em.
The wording on that letter is a little obtuse.

They want to see 75% nights at >6 hrs (might be >= 6). Basically, if your usage for a night is <6 then that night doesn't count. Add up all the nights that are > 6 and if that's >75% of your total nights then you pass.
 
So, what do CPAP folks do for things like going camping?

Are there portable battery packs for CPAPs?
 
They do make portable CPAP's that use batteries that are about the size of a coke can. Not sure if they have the ability to provide humidification or not.
 
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