Premium on Safety - Issue 35, 2020 - 4

SPOTLIGHT ON SAFETY

New FAA policy will allow
stable diabetic pilots on
insulin to fly commercially
BY CLAYTON T. COWL, MD, MS

Here is a rundown of what will be
required of insulin-dependent pilots
seeking this medical waiver:
* The applicant must have had no recurrent (two
or more) episodes of hypoglycemia (low blood
sugar reactions) in the past five years and none in
the preceding one year which resulted in loss of
consciousness, seizure, impaired cognitive function or
requiring intervention by another party, or occurring
without warning (hypoglycemia unawareness);

* The applicant will be required to provide copies of
all medical records as well as accident and incident
records pertinent to his or her history of diabetes. The
report must include:
* A complete medical examination, preferably by a physician
who specializes in the treatment of diabetes such as an
endocrinologist who can also document that the pilot knows
how to use a glucometer to measure blood sugar;
* As a minimum, at least two measurements of glycosylated
hemoglobin (total A1 or A1c concentration and the laboratory
reference range) separated by at least 90 days with the most recent
measurement being no more than 90 days old;
* Specific reference to the applicant's insulin dosages and diet;
* Specific reference to the presence or absence of
cerebrovascular, cardiovascular, or peripheral vascular disease
or neuropathy;
* Confirmation by an eye specialist of the absence of a clinically
significant eye disease;
* Verification that the applicant has been educated in diabetes
and its control and understands the actions that should be
taken if complications, especially hypoglycemia, should arise.
* If the applicant is age 40 or older, a report, with ECG tracings,
of a maximal graded exercise stress test.

4

Authorization for insulin-treated diabetes mellitus (ITDM)
pilots to exercise pilot privileges beyond private pilot has been
a topic of much discussion for several years within the aviation
sector. While the FAA has discretion under FAR 67.401 to
consider allowing ITDM special issuance for higher-rated pilots,
it has chosen to proceed cautiously. The American Diabetes
Association and several affected pilots have urged the FAA
to update its special-issuance process for ITDM beyond thirdclass medical certification by developing an ITDM specialissuance protocol to allow the exercise of commercial and
airline transport pilot privileges.
The FAA announced recently that pilots who require injectable
insulin to treat underlying diabetes will now be considered for
aeromedical certification if they have been clinically stable
on their current treatment regimen for a period of six months
or more. Individuals certificated under this policy will be
required to provide medical documentation regarding their
history of treatment, accidents, and current medical status.

Each pilot needs to see their treating
physician and keep track of their
hemoglobin A1c levels once per quarter as
part of the special issuance authorization.
If certificated, they will be required to adhere to monitoring
requirements. There will be no restrictions regarding flight
outside of U.S. airspace for commercial and airline transport
pilots granted special issuance with this condition, and private
pilots who currently require insulin and have been granted
the waiver will now be allowed to fly outside of U.S. borders
as well. Even pilots with insulin pumps are eligible for medical
certification under the new rule.
Once a pilot obtains a special issuance authorization for
the condition, there are additional expectations to ensure
safe operations. This includes carrying a glucometer with
them in the cockpit or on the flight deck, ensuring adequate
supplies to obtain blood samples, and having access to rapidly
absorbable glucose such as juice or other items in the event
of low blood sugar readings during the flight. One-half hour
prior to flying, the pilot must measure his or her blood sugar
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