The FAA updated some pilot health limitations just before the new year, but real reforms remain necessary and out of reach.
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I’ll preface this post by stating that I am not a pilot and welcome commentary from experienced pilots like our own, 121Pilot. As an observer of the industry, the adjustments made by the FAA appear more tone-deaf than effective.
FAA Updates Heart Health Requirements Among Others
The FAA updated a number of health requirements for pilots, most importantly affecting airline transport pilots, though it’s not clear to me whether it’s only those holding a commercial pilot certificate or all private pilots (and flight instructors) included as well.
Some of those changes made just before the end of the year (December 28th, 2022) remove cognitive screens unless ordered by an appropriate physician. Additionally, the simplification of vision screenings (except with color detection) that allow for corrective lenses at both intermediary and long distance have been relaxed.
What sent some circles swirling this week were changes dated from October 26th, 2022 but noticed (or raised to public attention now.) Heart arrhythmia tolerances were adjusted from 200 MS to 300 MS based on the information from cardiologists.
“The update is on the FAA’s website, revising its electrocardiogram “normal variants list,” which details electrocardiogram findings that “are not cause for deferment unless the airman is symptomatic or there are other concerns.”
It changed the maximum acceptable PR interval — a heart health metric measured by electrocardiograms — to 300 milliseconds, or 0.3 seconds. A PR interval between 0.12 seconds and 0.2 seconds is considered normal. A PR interval that exceeds 0.2 seconds indicates a first-degree atrioventricular block, which can cause a slower heartbeat or abnormal rhythm.
The Federal Aviation Administration told PolitiFact it raised the cutoff for a first degree ventricular block from 200 milliseconds, or 0.2 seconds, to 300 milliseconds, or 0.3 seconds, because the agency’s cardiology consultants provided information indicating that a PR interval under 0.3 seconds isn’t a risk for subtle or sudden incapacitation.” – Politifact
This adjustment came to light in part because the adjustments on that date also acknowledged an additional accepted COVID vaccine (NOVOVAX) and recent concern regarding potential heart-related issues with some vaccine recipients.
In sum, the FAA stated there is no risk below 300 MS so its prior restriction to 200 MS was unnecessary, and adjusted its requirements in accordance with this information.
Arbitrary Restrictions Remain In Place
These adjustments may be slight in nature but it brings to light the numerous arbitrary restrictions that remain in place despite a pilot shortage and labor constraints. We’ve not been shy, here at Live And Let’s Fly, about the fact that some arbitrary federal regulations keep good pilots away from ever becoming student pilots at all.
Pilot Hours
Following the Colgate 3407 crash in 2009, a move was made to increase the hour requirements for holders of an Air Transport Pilot Certificate (ATP) from 250 hours of flight time to 1,500 before they were eligible to be a pilot-in-command of an aircraft. Those rules were arbitrary in nature because both the first officer and captain had more than 2,000 hours of experience each and would have been able to fly 3407 even if the rule was in place before the accident. It solved nothing.
The very real issue is that flight training is incredibly expensive. Securing just the required minimum of 40 hours for a private license is already a five-figure venture. Adding 1,460 more has led some to remain as certified flight instructors but overall, the expense and limitations has meant fewer pilots flying.
Mandatory Retirement Age
The FAA has a mandatory retirement age of 65. This limitation is irrespective of physical health, ability, or mental acuity. An unhealthy and less experienced 64-year-old is apparently better fit for duty than an athletic, spritely 66-year-old.
There’s no science to the age restriction, no flight time limitation that awards experience nor penalizes burnout. Age might just be a number, but why that number? Why not 70, or 59.5 (like social security)?
Other aspects like a minimum age (17), 20 hours of flight instruction, 10 hours of solo flight, and three hours of cross-country flight experience among others, are based on critical skills analysis and the ability to interact with air traffic control, for example. But keeping good 66-year-old pilots out of the cockpit is just down to a decision made without scientific justification.
Applaud or Demand More?
Are we to applaud these updates? After all, restrictions that are dated or based on bad information are being relaxed and allowing more to fly. Certainly, this would have to be an improvement and even in the slightest possible way, a manner by which we might have more eligible pilots rather than fewer.
For me, however, it just reminds me of how many unfounded rules are in place with a “one size fits all” approach. Some pilots shouldn’t be eligible to fly after 60 based on their own personal situations, but not as a hard and fast rule. Some older pilots should never have been denied the seat at all. Is this a time to challenge the FAA to revisit its generic limitations?
Conclusion
Some FAA changes have revised pilot requirements relaxing some requirements slightly with regard to eyesight and heart arrythmia over the last few months. While I can appreciate that these small changes (though heart arrythmia tolerances were raised 50%) may have simply been a normal course of business for the regulatory body, it reminds me of what’s not being done to solve the pilot shortage and use common sense approaches to ensure healthy pilots are flying regardless of age. While the FAA may not be able to reverse the minimum hours or mandatory retirement age, more could be done in the form of recommendations, formal requests to congress, and active participation to eliminate these foolish barriers to entry.
What do you think? Should the FAA relax other more significant rules around pilot eligibility?
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