Anonymous

Thank you for considering my comments in regard to the issuance of Airman Medical Certificates to applicants being treated with antidepressants. The revision in policy regarding issuance of airman medical certificates for applicants being treated with anti-depressants is certainly a step in the right direction by first and foremost ensuring the safety of passengers and the general public by being open to advancements in modern medicine. While I support most of the consideration criteria for special issuance, I find the required neurocognitive psychological battery of tests to be extreme, expensive, and unnecessary. In my estimation these tests would cost between $3,000-4000 and would take approximately six to eight hours. Additionally, I could not ascertain whether under the new policy these tests would need to be repeated for each renewal and revalidation certification. If so, not only does this place a significant financial burden on an already expensive activity, but I would also question the reliability of any test being repeated this frequently. A potential pilots cognitive ability certainly needs to be assessed before issuing medical clearance to fly, however I would urge the FAA Surgeon to consider an alternative method for determining these abilities in a more cost effective and less time consuming manner. These alternative methods could include personal interviews, educational or employment related recommendation letters detailing the applicant’s ability for complex thought and ability to respond under stress, or even an FAA compiled neurocognitive test. The new test could incorporate components of the currently required battery of tests into a single test that identifies the applicant’s cognitive abilities without adding significant additional financial costs or time burdens toward achieving the ultimate goal…a safe and healthy airman.