Airmen With Special Issuance Medical Certificates Will No Longer Need To Carry Their Letters Of Authorization With Them


In a Direct Final Rule published on March 22, 2012, the FAA disclosed its intent to remove the FAR 67.401(j) requirement that currently requires an airman granted a Special Issuance Medical Certificate to have his or her corresponding letter of Authorization in the airman's physical possession or readily accessible on the aircraft while exercising pilot privileges. (A special issuance is comprised of both a medical certificate and a letter of authorization that specifies any corresponding requirements or limitations associated with the medical certificate).

The FAA originally imposed this requirement in 2008 to respond to a 2007 International Civil Aviation Organization (ICAO) adverse audit finding regarding endorsement of FAA certificates. At that time, the FAA was concerned "that traditional enumeration placed on U.S. medical certificates under the FAA's special-issuance medical certification process might not be detailed enough for affected U.S. pilots during a ramp check in a foreign country, for example." The FAA believed that it was in the airman's best interest to have the letter of Authorization readily available.

However, after imposing the rule, the FAA received many complaints from affected airmen that the full force of the requirement was overly burdensome and invasive. Additionally, during the three years that the rule has been in effect, "[t]he FAA is not aware of any individuals affected by the standard who have had to produce their letter of Authorization for any civil aviation authorities."

As a result, the FAA determined that the regulation was one that could be removed. However, the Final Rule cautions that "[w]hile this action removes the burden for affected individuals to carry their medical letter of Authorization, long-standing requirements under FAA operational standards requiring individuals to carry FAA certificates while exercising pilot privileges remain unchanged." Thus, airmen will still need to carry their airmen and medical certificates with them while exercising their pilot privileges.

The FAA is accepting comments to the Final Rule on or before May 21, 2012. If it receives adverse comments, it will withdraw the Final Rule. Otherwise, the Final Rule will be effective July 20, 2012.

It's nice to see the FAA actually doing something to make things easier for airmen. Although the Final Rule won't affect a wide range of airmen, it certainly represents a move by the FAA in the right direction. And under the circumstances, I wouldn't expect to see any adverse comments to the Final Rule. But I will keep my fingers crossed anyway.