Special Issuance Authorization Letter of Interpretation
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The Federal Aviation
Regulations, Part 67, Subpart E, allows the Federal Air Surgeon latitude to
consider persons with serious medical conditions for a discretionary medical
certificate, or special
issuance authorization. An authorization is required when the applicant for
medical certification is considered unable to meet the medical standards
prescribed in Subparts B, C, and D of Part 67.
A discretionary
issuance carries with it additional requirements for more frequent reevaluation
and testing to determine that the condition for which the authorization is
issued has not progressed to a point that public safety will be endangered
during the time the authorization is in effect. An authorization differs from a
Statement of Demonstrated Ability
(SODA) in that a SODA is issued for a disqualifying condition that is static or
non-progressive, such as a loss of vision in one eye or limb amputation.
Even though an
Authorization may require reexamination every six or twelve months, the date of
renewal of your FAA medical application and physical examination does not
change. It is still required every 6 months for a First-class medical, every
twelve months for Second, and either 24 or 36 months, depending upon your age,
for Third-class (FAR 61.23).
Following is the
text of an FAA Authorization letter with explanation and interpretation of what
the authorization actually is stating.
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Dear Mr. Member: |
PI# 100111 |
I have reviewed the
information submitted by you in support of your request for an airman medical
certificate. The medical evidence reveals a history of myocardial infarction
and coronary artery disease requiring coronary artery bypass surgery. You are
ineligible for third-class medical certification under Section 67.111(a) (1) (3),
67.211(a) (c), and 67.311(a) (c) of the Federal Aviation Regulations (FARs).
The
letter must state the medical history presented to the FAA. Because of the
disqualifying conditions, the medical regulation that makes the condition
disqualifying must also be stated. Section 67.111 details the requirements for
a First class medical, 67.211 for Second class, and 67.313 for Third. The
parenthetical numbers refer to the specific medical condition, in this case,
myocardial infarction and coronary heart disease.
However, based on
the complete review of the available medical evidence, I have determined that
you may be granted authorization for
special issuance of Third-class airman medical certification under Section
67.401 of the FARs.
Your Aviation Medical Examiner is authorized by this letter to issue you
a third-class medical certificate bearing the limitation "NOT VALID FOR
ANY CLASS AFTER NOVEMBER 30, 2001" provided you are found to be otherwise
qualified.
Despite
your disqualifying condition, the Federal Air Surgeon has found that your
current medical condition does not put you at an unacceptable risk that would
endanger public safety during the time the authorization will be in effect
(November 14, 2000 through November 30, 2001). For our purposes, assume this
pilot's last FAA medical examination was more than two years ago, and he will
be reapplying for a new medical with his AME this month. It is usually best to
undergo a current FAA flight physical at the same time you are providing the
FAA with medical records in support of a special issuance request. That way,
the periodic reexamination (usually at yearly intervals) will come in the same
month that your regular FAA medical examination is due according to FAR 61.23.
This Authorization
expires on November 30, 2001.
Only the
authorization expires one year from now. The FAA physical examination done by
your AME is still valid for twenty-four or thirty-six months as specified in
61.23, so you will not need to go back to your AME until November, 2002.
(Assume also that this pilot is over age 40 and requires a new medical
application every 24 months.)
Consideration for a
new Authorization will be contingent upon the following, performed in accordance with the enclosed
specifications:
On or about October 1, 2001:
If there have been
no significant adverse changes in your medical status, you have complied with
all conditions of certification described in your Authorization, and I am
satisfied that the duties permitted by our medical certificate can be performed
without endangering public safety, the Medical Appeals Branch may then grant
you a new Authorization for an additional time. You will still be required to
have your regular third-class physical examination at the frequency prescribed under the provisions of CFR 61.23.
In order to avoid a
lapse in certification, the necessary testing should be completed near the date
noted above and forwarded in one package to the following office.
Aerospace Medical Certification Division
(AAM-300)
FAA Civil Aerospace Medical Institute
6700 South MacArthur Blvd.
Oklahoma City, OK 73169
Phone 800/350-5286, 405/954-4821
The FAA
will allow you to send your renewal information up to 90 days prior to the
expiration date of the authorization. Even though the letter indicates 60 days
is enough lead time, we suggest you take the full 90 days to allow for delays
in getting testing done, receiving final reports from the doctor's office, and
other last minute delays that always seem to pop up. Make copies of everything
for your own files in case something gets lost, which does happen occasionally.
Either address will work, but the best way to send information is by overnight
or express mail to the S. Mac Arthur Blvd. address. Regular first class can go
to the PO Box number.
You must promptly
report any adverse changes in your medical condition to the FAA Medical Appeals
Branch, AAM 320.
Because
your medical is at the discretion of the Federal Air Surgeon, there is an
implied "automatic invalidation" of the authorization if you have an
"adverse" change in your medical condition.
Use of the above
reference number and your full name on any reports or correspondence will aid
us in locating your file and expediting a reply to you.
Sincerely,
Warren S.
Silberman, D.O.
Manager, Aeromedical Certification Division
Civil Aeromedical Institute
Be sure
to use the PI number assigned you at the top of the letter. This is your unique
ID for the FAA to identify you among the one million-plus medical records on
file.
6/02