Friday, June 24, 2016

The FAA Revisited

Six years ago I was fresh out of college and attempting to begin my Aerospace career as an Army Flight Test Engineer. Little did I know how difficult it was going to be to obtain an FAA (Federal Aviation Administration) Class 3 medical just to fly aboard (not pilot) experimental Army aircraft. It took nearly six months of back and forth with the elusive FAA doctors in Washington, mountains of paperwork and heartache over the frustrating difficulty of a seemingly straight forward task before I was finally granted a Special Issuance Class 3 medical waiver.

In the spirit of tenacity, I recently looked up the Class 3 guidelines to see if anything has changed in the 3-ish years that I have been away from the Army. I was pleasantly surprised.

It appears the FAA has updated their hardline stance on Type 1's only being eligible for a Class 3. From the FAA website, "First and second class applicants will be evaluated on a case by case basis by the Federal Air Surgeon's Office." Essentially, at least how I read it, a well-controlled Type 1 can apply and potentially obtain a medical certificate that would allow them to be Pilot-in-Command of an airline transport.
Screen captures from faa.gov
This really is a huge step forward. Granted, I no longer have a need to maintain an FAA medical and therefore have not attempted to obtain a Class 1 or 2, but I imagine with enough paperwork and diligence someone can get through!

I actually had a hard time finding the legislation trace that allowed these new insulin-treated diabetes provisions. It looks like the FAA requested the American Diabetes Association to convene a panel of experts "to form recommendations for a protocol to identify a subset of pilots who use insulin who pose no great risk of incapacitation from hypoglycemia than any other pilot in the general population." The panel convened on June 27, 2014 and created guidelines for a policy to "permit the special issuance medical certification of certain insulin-treated applicants for first-, second-, and third-class medical certification." They go on to mention that the applicant will need "substantial documentation"...ha...I ended up sending them my entire medical record from 11-years-old on before they would issue me a third class. I'm just not sure where they are going to get all this extra paperwork from ;-)

My favorite paragraph from the report states, "The enormous progress in management of the disease justifies a change in FAA policy, which dates from 1949. [nerdy April note: 1949?!?!?!?! kthnxbye] That policy is that pilots with insulin treated diabetes may not receive first or second class medical certificates, thus barring them from commercial operations. While the 1949 ban was justified by the science that then existed, it is no longer justified by evidence based medicine."

The main point that the panel stressed is that airmen should be medically reviewed on an individual basis - and I think this is so, so important. Diabetes is not a "generalized" disease - it is an individual one. Not every Type 1 walks around with an insulin pump and continuous glucose monitor, because, they don't have to - treatment and management is extremely individualized. What management works for some doesn't necessarily work for all and what blood sugar ranges are recommended for some are not necessarily recommended for all. Heck, there are even a plethora of different types of insulin that react differently in patients bodies. We are all different, and so is our treatment, management and control of this disease. Can I get an Amen?!

A couple additional sections that highlight why I feel so strongly about this issue:

"The panel also considered the data from Canada's experience certifying pilots with insulin treated diabetes to fly since 1992 as well as the data from the United States allowing pilots to fly with third class medical certification, including solo operations, since 1996. The twenty years of data from these two countries indicate that there has never been a diabetes-related accident or incident involving a pilot with insulin treated diabetes who has been granted certification to fly while using insulin."

"After considering all the evidence and clinical experienced outlined above, the expert panel concluded that there are pilots with insulin treated diabetes whose risk of incapacitation in flight is equivalent to, or lower than pilots who do not have insulin treated diabetes."

This.This is what made all the trouble with the FAA worth it. 

I'm not sure how I lost track of these changes, but I'm glad I circled back around to find them. With more Type 1 pilots flying comes more data, and hopefully, continued updates to the FAA's (and other organization's) policies.