Obstructive Sleep Apnea and your FAA Medical Certificate. What you need to know.

Every year, millions of Americans are diagnosed with Obstructive Sleep Apnea (OSA). According to some studies, it affects up to 30 percent of males and 15 percent of females in North America [1]. OSA is by far the most commonly diagnosed sleep-related disorder, so if your spouse has been complaining about your snoring and you’ve been waking up feeling unrested in the morning, there is a good chance that OSA could be the culprit. Without delving too far into a detailed medical discussion, OSA is a condition that causes patients to stop breathing during the night because their airways get blocked by some portion of their own tissue. Not surprisingly, people with OSA don’t sleep as well and are more apt to become drowsy during the day. It makes sense that the FAA cares about it.


The good news is that treatment for OSA has improved significantly over the past several years. The bulky and noisy breathing Continuous Positive Airway Pressure (CPAP) devices that once created sleeping disturbances in their own right have become compact, quiet and travel friendly. In addition to the increased levels of alertness and cognitive functions that come with effective treatment, the risk of high blood pressure, coronary artery disease and diabetes - among other conditions - is lower in those who use CPAP to manage their OSA.

Unfortunately for pilots, that’s only half the battle. Once you address the health concerns associated with any conditions, you still have your FAA medical certification to worry about.

OSA happens to be one of the most heavily scrutinized conditions evaluated by the FAA. Once significantly underrecognized, the FAA revised its policy in 2015. Every AME on every aviation exam must assess an airman’s risk for OSA. More details about that process are included below. The important point is this: the approval process for treated or newly diagnosed OSA should be quick. You DO NOT have to wait for the typical special issuance processing times and in many, if not most, cases, your AME can issue your certificate on the day of your exam.

Here are the categories your AME has to choose from along with some commentary about what they mean [2]:

  1. Has OSA diagnosis and is on a Special Issuance. Reports to follow. You’re probably not reading this. You’ve been through the process before and as long as you collected all the information directed in your special issuance, your AME can issue your certificate on the day of your exam.

  2. Has OSA diagnosis and is currently being treated OR has had previous OSA assessment. NOT on Special Issuance. Reports to follow. You already know you have OSA, but this is your first time telling the FAA about it. As long as you’ve been compliant with the treatment your doctor prescribed and you can provide documentation to that effect, your AME can most likely issue you certificate on the same day. Just make sure to provide the appropriate records within 90 days.

  3. Determined to NOT be at risk for OSA at this examination. You’re probably not reading this for a different reason that those mentioned in #1 above. Your AME can issue your certificate and no further action is required on your part.

  4. Discuss OSA risk with airman and provide educational materials. Whether because of your physical exam or some aspect of your medical history, your AME has some concerns about your risk for OSA, but doesn’t think you have the diagnosis. Consider getting evaluated and do everything you can to reduce your risk of developing OSA.

  5. At risk for OSA. AASM sleep apnea assessment required. Reports to follow. Your AME is pretty sure you have OSA, but doesn’t think it poses a significant risk to aviation safety. You have 90 days to get evaluated by a sleep specialist and provide proof to the FAA regarding your OSA

  6. Deferred. Immediate safety risk. AASM sleep apnea assessment required. Reports to follow. You’re bad off. OSA is like just one worry among many medical issues. There is a good chance you actually fell asleep and stopped breathing in front of your AME. You should probably not be driving, much less getting in an airplane.

Don’t get too bogged down in the details here. Most pilots are going to fall into one of the first three categories which have well defined procedures for your AME to follow, don’t require much judgement on their part and all end with you walking out the door with a certificate. If you think you might fall into one of the last three categories, it’s better to get yourself formally evaluated BEFORE you schedule your AME appointment. Technically, your AME can still issue a certificate if you fall into category 4 or 5, but there is no reason to take that chance. Remember what an AME does and put yourself in their position. The line between just being at high risk for OSA (category 4) and posing a significant public safety risk (category 6) can be remarkably difficult to distinguish. Asking your AME to make that determination within 10-20 minutes of meeting you while other patients are waiting in the lobby is unfair to them and many will, justifiably, take the conservative approach by deferring your exam.

There is another reason to get your OSA evaluation before your AME appointment. Unless you fall into category 3 - clearly not at risk - your AME may issue your certificate, but it will come with a big caveat. The “reports to follow” mentioned above include a signed statement by you that you are compliant with whatever treatment your doctor prescribed, a copy of your most recent formal sleep study results and a current status report from your treating physician - not your AME. Those documents will be due to the FAA within 90 days of their request and depending on your schedule, the pandemic de jour and your doctors’ availability, it could take every bit of that 90 days to collect everything you need.

The bottom line is that whether or not they mention it to you specifically, your AME will be thinking about OSA at your next certification appointment. Even if you have OSA, you will likely receive your certificate on the day of your exam. If know you have OSA or think you might be at risk, here are some quick tips to make sure your FAA medical certification does not suffer:

  1. Talk about it with your AME ahead of time. Not all examiners are familiar with the FAA’s OSA protocol and they always have the option of deferring your exam.

  2. Know what information the FAA will require and take it with you to your AME appointment.

  3. Make sure you actually use whatever treatment your doctors prescribe to treat your condition and be prepared to provide documentation to that effect at every FAA medical appointment.

Given its prevalence, clear impact on aviation safety and its association with other serious medical conditions, it is no wonder that OSA is on the FAA’s shortlist conditions to watch. From the pilot perspective it’s best to address it directly. OSA is very treatable and will not keep you out of the cockpit unless you ignore it to the point your AME has no choice.

References:

[1] T. Young, M. Palta, J. Dempsey, P. E. Peppard, F. J. Nieto, and K. M. Hla, “Burden of sleep apnea: rationale, design, and major findings of the Wisconsin Sleep Cohort study,” WMJ Off. Publ. State Med. Soc. Wis., vol. 108, no. 5, pp. 246–249, Aug. 2009.

[2] “Decision Considerations Disease Protocols – Obstructive Sleep Apnea (OSA).” https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/aam/ame/guide/dec_cons/disease_prot/osa/ (accessed Nov. 02, 2021).


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