Reading the Fine Print: FAA Color Vision Standards and how to meet them

“My eyes aren’t good enough to be a pilot.” I’ve heard similar statements from would-be pilots more times than I can count over the past few decades.


Another variation on that theme comes from seasoned aviators who work themselves into fits – read, “spike their blood pressure so high it could actually disqualify them” – when they can’t make out the 20/20 line on an eye chart.


Then there’s color vision.


The reality is that you don’t necessarily have to see like an eagle in order to soar with them. In fact, the FAA doesn’t even set a limit for how bad your vision can be without glasses in order to fly. The common belief that you have to decipher the bottom line of the eye chart in order to become a pilot or maintain your FAA medical certificate is a bit of a misnomer. For commercial pilots or those applying for 1st or 2nd class certificates, your distant vision needs to be good enough to read the 20/20 line at your AME’s office, but you get to wear glasses or contacts in order to meet that standard. For a 3rd class certificate, as long as your lenses correct your vision to 20/40 or better, the FAA is happy to keep you in the air.


What if, despite your robust hairline and youthful exuberance, you’ve started to hold restaurant menus at arm’s length in order to make informed decisions about your meal or just opt to trust the waiter’s recommendation to avoid notice? As people, even pilots, age into their late 30’s and beyond, it’s very common to develop difficulty focusing on objects within a foot or two of the eye. Termed presbyopia in medical-speak, this phenomenon is related to the gradual hardening of the lens that occurs as a normal part of aging. Pride and convenience notwithstanding, a few dollars at your local drug store will solve your problems at your favorite restaurant and at your next FAA medical exam. A pair of reading glasses are perfectly acceptable in either setting and as long as you can read the 20/40 line while wearing them, your medical certificate is safe for whatever class you’ve applied for. Pilots over 50 need to pass an additional intermediate distance vision test, but I’ve yet to see anyone struggle with that.


The rule of thumb for FAA visual acuity standards is similar to one I’ve expressed in other posts: if you think you’re safe to fly, you’re probably right. Just make sure you have a current prescription and remember to bring your glasses with you to your AME appointment.


Color vision standards are a bit more convoluted.


Let’s start with the published standard. 14 CFR Part 67 uses the same phrase to define color vision requirements to obtain any medical certificate. Pilots must have the “ability to perceive those colors necessary for the safe performance of airman duties.” Wouldn’t it be nice if you AME just asked you to make a self-assessment?


Unfortunately, there’s no office-based test that can truly make that determination. As a surrogate measure, the FAA accepts a number of color vision tests that – short of establishing flight safety – at least measure color vision on the not-so-precise normal-not normal scale [1]. As the logic goes, if you can see every color, you’re bound to spot the important ones.


The FAA has approved 16 valid color vision tests and acceptable alternatives. If you pass any one of them at your AME exam, you’re considered to have normal color vision, you get your certificate and fly off into the sunset with full appreciation of the majestic range and subtlety of color it has to offer. If you fail…well…there’s a flow chart [2].


A special note here before I discuss the rest of the process. Not all color vision tests are created equal. Just because you pass or fail one doesn’t mean you will pass or fail all of them. If you happen to fail a test, it pays to shop around for a test you can pass. Two that bear specific mention are the Dvorine 2nd edition 15-plate and the Farnsworth Lantern. The Farnsworth Lantern is perhaps the least restrictive test. It involves discriminating between a series of white, green and red lights of different intensities as opposed to the other tests which identify numbers or symbols against a specially designed background. The Farnsworth test is becoming scarce so it might take some leg work to find an AME who has one, but it may be worth the effort.


If you can’t find a screening test you can pass, there’s still hope. Your AME can still issue a 3rd class certificate with the following limitation: “Not valid for night flying or by color signal controls.” When’s the last time you had to look at the tower for ALDSS lamps signals anyway? For many private pilots, that restriction might not affect you at all. If you want to fly at night or need a 1st or 2nd class certificate, it means a trip to the Flight Standards District Office (FSDO) to set up a specialized test with an Aviation Safety Inspector (ASI) or Aviation Safety Technician (AST).


With a Letter of Authorization (LOA) from the FSDO, you can set up an Operational Color Vision Test (OCVT). The test involves a ground-based evaluation with an ASI or AST that requires the pilot to identify signal light from the tower and read navigational charts in the cockpit. If you pass, you’ll receive a Letter of Evidence (LOE) that effectively removes any color vision related restrictions from your 3rd class certificate [3].


If you fail the daytime OCVT, you can still repeat the test at night to remove the nighttime restriction from a 3rd class certificate, but you’ll be ineligible for a 1st or 2nd class medical certificate.


For those requiring a 1st or 2nd class certificate, there’s one more step. You’ll need to schedule a flight with an ASI and demonstrate that you can effectively read instruments with color markings, correctly interpret approach lights and airport markings and identify terrain features and other hazards[3].


Needless to say, navigating that process can be time consuming and costly. Here are some practical tips if you think you might struggle with color vision testing:


  1. Don’t go to your AME before you know you can pass the test he/she uses for Aviation Medical Exams. Schedule an optometry appointment first to figure out which test(s) you can pass. Then call around until you find an AME and use one of them.

  2. Get a good night’s sleep and show up to your exam hydrated, well nourished, and well rested.

  3. If you fail your color vision test, actually do 1 & 2. Then try again. You only get one chance at the OCVT. You may save yourself a lot of logistical hurdles and a potentially permanent flight restriction with good prep work.

  4. If you have questions, call us. We can walk you through the process and may be able to save you some leg work by recommending an AME with appropriate testing equipment.


Like many medical issues in aviation, color vision isn’t black and white. Don’t let one failed test be the final word on your aviation career.


References:


[1] D. J. Monlux, H. A. Finne, and M. B. Stephens, “Color blindness and military fitness for duty: a new look at old standards.,” Military medicine, vol. 175, no. 2, pp. 84–85, Feb. 2010, doi: 10.7205/milmed-d-09-00171.


[2] “Guide for Aviation Medical Examiners.” https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/aam/ame/guide/app_process/exam_tech/item52/amd/ (accessed Aug. 20, 2021).


[3] “Flight Standards Information System (FSIMS).” https://fsims.faa.gov/PICResults.aspx?mode=EBookContents&restricttocategory=all~menu (accessed Aug. 20, 2021).


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