Could Occam’s Razor fix FAA AME problem?
Congress, in its infinite wisdom, legislated that the FAA’s Office of Aerospace Medicine (AME) should no longer defer a pilot’s application for a medical. Rather, the Reauthorization Act mandated that when the FAA determines that the file is incomplete, the medical examiner MUST DENY the medical request instead of its past practice of DEFERING it.
EVIDENTLY, THE DEFERRAL TAGS WERE MOUNTING UP AND SHOWING INORDINATE LEVELS OF DELAY.
The image of William of Ockham (also spelled “Occam”) is a reference to a 14th-century English Franciscan friar, scholastic philosopher, apologist and Catholic theologian.
Considered to be one of the most influential philosophers of the Middle Ages. The Occam’s razor is generally credited with being a major decisional item for modern science. The razor is attributed to the efficient reasoning– the principle of parsimony in explanation and theory building.
Applying this rule of reasoning to Section 801 might simply distinguish between delays that are attributable to the applicant’s need to add required information as opposed to a waiting list of pilots that exceed the Doctors’ capacity to process medicals. A SIMPLE DIFFERENTIATION WOULD CLARIFY THE SOURCE OF THE AME WORKLOAD.
Pilots Groups Ask FAA To Reconsider Revised Medical Certification Policy
Unions and pilot associations[1] have written an open letter to the Federal Aviation Administration ( FAA ) to pause the implementation of new medical certificate application rules, warning of potential implications for future pilots.
14 unions and associations, ranging from the Air Line Pilots Association, International ( ALPA ), Allied Pilots Association (APA), the American Airlines pilot union, to the Flight School Association of North America (FSANA) wrote a letter addressed to Susan Northrup, the Federal Air Surgeon of the Office of Aerospace Medicine of the FAA, requesting A STAY IN THE IMPLEMENTATION AND CONSIDERATION OF THE WITHDRAWAL OF THE REGULATOR’S RECENTLY ANNOUNCED CHANGES IN POLICY AFFECTING MEDICAL CERTIFICATE APPLICATIONS.
“As briefed to the industry, beginning January 1, 2025, the FAA is significantly altering the policy for the processing of medical certificates that require additional information for an FAA decision, with the FAA now initially denying rather than requesting additional information following deferral of the application.”
The letter stated that briefings provided to Aviation Medical Examiners (AMEs) and pilot advocacy groups indicated that the change was driven by the regulator’s interpretation of a certain section of the FAA Reauthorization Act 2024, which was signed into law on May 16. Section 801 is related to general aviation (GA) regulations regarding the reexamination of pilots or certificate holders.
“The FAA’s use of denials, in lieu of the currently used deferral, as a routine part of the medical application process will significantly increase unneeded confusion for applicants and introduce unintended consequences for those under initial denial.”
Some stakeholders, including the White House, have expressed disappointment over the FAA Reauthorization Bill of 2024.
Potentially impacting hiring decisions
The 14 unions and associations expressed concern that the denials will be reportable on future medical applications and/or employment applications, which inquire whether a pilot has had a previous medical denial.
“The ramifications of an increase in airmen receiving and reporting medical denials on these applications and the need to educate hiring managers about this change are significant and will take considerable time.”
While the FAA’s Office of Aerospace Medicine has demonstrated its progressive thinking and industry collaboration that has led to significant enhancements, the change was contrary to its goal of progressing toward approving a medical application, the letter added.
“We support your office’s desire to promote the submission of complete information at the time of initial medical application.”
The submission of complete information would reduce the application time and the administrative burden on the FAA’s staff, allowing them to focus on evaluating submitted data instead of looking for gaps in the initial application, the stakeholders noted.
Importance of transparency
System modernization and process improvements to include transparency for the applicant and their AMEs and medical specialists will undoubtedly help the FAA and the pilots, the letter continued.
The associations and unions emphasized that the aviation industry remains committed to working with the regulator on the issue of denying rather than requesting additional information following an initial medical certificate application “in the collaborative environment that you have fostered, and again, we urge the FAA to stay the implementation of this medical certificate policy change.”
[1] AOPA; the Air Line Pilots Association; the Allied Pilots Association; the Coalition of Airline Pilots Associations; the Experimental Aircraft Association; the Flight School Association of North America; the Independent Pilots Association; the International Brotherhood of Teamsters, Airline Division; NATA (formerly the National Air Transportation Association); the National Business Aviation Association; the National Flight Training Alliance; the NetJets Association of Shared Aircraft Pilots; the Southwest Airlines Pilots Association; and Vertical Aviation International.
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