Donald Singer

Part 1 of 3: The FAA is to be congratulated for addressing this issue in an honest, straightforward way. The goal of this policy, to improve safety by providing a mechanism for pilots with adequately treated depression to fly legally, under appropriate supervision, is laudable. As the FAA has stated, there is a safety concern "… regarding applicants who may be reluctant to disclose [antidepressant treatment] or who may be masking a struggle with depression…" I fully understand, and agree with the need for a cautious, conservative approach to a policy that significantly relaxes previous restrictions, especially in the initial implementation. Other than the two exceptions noted below, I feel that the new policy is reasonable and strikes a fair balance between the needs of the aviator and the public need for safety. As a non-psychiatrist physician, I feel that I am knowledgeable about this issue, although not an expert on it. I am greatly concerned about two requirements for special issuance that I feel err too far on the side of caution and and may even cripple an otherwise excellent policy. These are the requirement for expensive neurocognitive testing of all applicants and the requirement for a one-year period on a stable dose of medication. My understanding is that the testing requirement arises from the FAA's legitimate concern about the possibility of granting a medical certificate to an applicant with a serious, truly disqualifying, co-morbid condition (including bipolar disorder, severe ADHD and others). In my area, I'm told this testing costs $3500 or more. This requirement for costly neuropsychological testing in every case strikes me as overkill. A competent psychiatrist should be able to rule out co-morbid conditions in most cases. Surely, the psychiatric evaluation coupled with an additional review by a specially trained, HIMS certified Aviation Medical Examiner provides an adequate margin of safety regarding co-morbidity.