Donald Singer

Part 2 of 3: Additional testing should be imposed only on a case-by-case basis, when indicated by the patient's history or the psychiatrist's OR HIMS AME's findings. As an aside, I have heard, but have not been able to confirm, that the neurocognitive testing will be required not just for the first special issuance, but at each renewal as well. If true, this would be massive overkill. This is the same test panel ams or is very similar to, that required for a special issuance medical for applicants with a history of substance abuse. Even in that case, the testing is required only once, for the first special issuance! The requirement that the "Airman must be on a stable dosage of medication for a minimum of 12 months prior to certification" seems far too long, and is not practical or realistic. Lack of adequate response and most side effects should be evident in most cases within 10 to 12 weeks. Indeed, in their letter to the Federal Air Surgeon, the AOPA and their consultants recommended "Initial documented stability on medication for 10 weeks with no adverse side effects, including sedation…" (emphasis mine). If necessary, safety could be maintained by allowing the airman to fly subject to more intensive or more frequent monitoring by the evaluating or treating psychiatrist and the HIMS AME during the six to twelve months following the initial 10 or 12 week period of stability. Paradoxically, pilots who have failed to disclose antidepressant treatment and avail themselves of the six month amnesty provision would largely be unaffected by this requirement, since most of them could show a year or more of stability. However, newly diagnosed pilots or those who HAD obeyed the rules and not flown or sought a medical certificate while under treatment would be adversely affected. I don't know how many private pilots would be willing to wait a full year without flying or flying only with an instructor.