Tedd Herman

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 applications 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 the cost of these tests would be between $3000-4000 and take approximately six to eight hours to complete. I could not ascertain whether or not these tests would need to be repeated at each medical renewal and revalidation. If they would need to be repeated, this not only adds a significant cost burden to an already expensive activity, but I also question the accuracy of any test being taken 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 applicants 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 attests the applicants cognitive abilities without adding significant additional financial costs or time burdens toward achieving the ultimate goal…a safe and healthy airman.