Wednesday, December 8, 2010

Petition to eliminate the third class medical

(All opinions expressed below are those of the author, and may not be those of PFC or its members.)

There is an interesting petition ("proposed rule making") being considered by the FAA to eliminate the third class medical for pilots operating aircraft of less than 6,000 lbs max gross weight under Part 91. The proposal seeks to extend the "LSA rule" which requires only a valid drivers license.

This month's Aviation Safety magazine has an editorial on this topic which, among other things, notes that:
  • Over the 6 years in which the LSA rule has been in effect, there have been zero examples of LSA accidents or incidents resulting from a pilot's medical incapacitation.
  • Between 2004 and 2010, there were no incidents where pilot incapacitation was cited as the cause. (Though in 39 incidents, it was considered a possible cause then discarded.)
We've all heard about the King Air that needed to be talked down after the PIC died mid-flight due to a heart attack, so we already knew that the danger of in-flight incapacitation is non-zero. But in the case of the King Air incident, the PIC had a medical which clearly did him or his passengers no good in that particular incident. The same Aviation Safety editorial goes on to note:
  • A 2004 study published by the FAA's Office of Aerospace Medicine cited a separate report concluding that the likelihood of in-flight incapacitation to be 0.074 percent.
So, what might happen if we substituted drivers licenses for a third class medical? The available studies suggest that sudden medical incapacitation accounts for 1-2 per 1,000 (0.1-0.2 percent) of all road accidents. These figures aren't directly comparable. But since the likelihood that a given driver would be involved in an accident is relatively small, the likelihood that any given driver would suffer an on-the-road incapacitation is far smaller than the 0.1-0.2 percent figure. So, substituting the drivers license for the third class medical would most likely have no appreciable impact on safety of the pilot, the passengers or the general public.

While some of the rationales put forward by the original petitioner is certainly debatable, it's probably a move that most of us can get behind. Regardless of where one comes down on the issue, it is certainly something that affects us all. So I encourage all pilots to go and take a look at the original petition at the government regulations site and leave your comments. (If the link doesn't work for some reason, visit www.regulations.gov and enter docket number FAA-2009-0481.) Check the "public submissions" box to see all the comments left on this petition so far.

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