Comments

As a non-psychiatrist physician, I agree with all but two of the points Mr. Goyer raises. First, the requirement for evaluation by a board certified psychiatrist is not unreasonable, and by itself should not be "an undue burden on pilots trying to do the right thing." Although I agree with Mr. Goyer that the FAA is being overly conservative, I understand and appreciate their need for a cautious, conservative approach to a new policy. A highly respected, HIMS certified AME told me that the FAA's is concerned about the possibility of granting a medical certificate to an applicant with a serious co-morbid condition that would truly be disqualifying, such as bipolar (manic/depressive) disorder or severe ADHD. The anecdotal cases mentioned by joegomes may well be examples of antidepressant-induced mania in bipolar individuals. Although there are exceptions, many primary care physicians may not have the training to detect some of the co-morbid conditions the FAA is concerned about. More importantly, in today's rushed, problem-directed primary care practice, the physician often doesn't have the luxury of spending enough time with the patient to evaluate such possibilities. Granted, some of these problems may become evident over time, probably resulting in a psychiatric referral, but in general, the FAA's requirement for evaluation by a psychiatrist seems reasonable to me. The second issue is that Mr. Goyer describes the special issuance process as "somewhat involved." I'm not sure he understands all the FAA's requirements. In addition to the psychiatric evaluation, according to the AME I consulted, there is an absolute requirement for a battery of at least six neurocognitive psychological tests that in my part of the country will cost $3500 or more. My AME consultant said that the purpose of these tests is also to detect serious co-morbid conditions. But wait. It gets worse. The FAA reportedly wants these tests repeated at every renewal! This is the same test panel that is required for a special issuance medical after recovery from a substance abuse problem. In that case, however, it is required only once, for the first special issuance! This requirement for costly neuropsychological testing in every case strikes me as overkill, and is the real problem with the new policy. A competent psychiatrist should be able to rule out co-morbid conditions in most cases. Additional testing should be imposed only on a case-by-case basis, when indicated by the patient's history or the psychiatrists findings. THIS is where I feel that Mr. Goyer is absolutely correct that the requirements may defeat the stated purpose and goal of the new policy. I fear that many pilots, when they learn the details, may decide to stay "under the radar," and either continue flying with untreated depression or continue not to report antidepressant use to the FAA. In many ways, this policy is a good first step. It would be a shame to see it fail. Maybe we can influence the outcome. The public comment period on this policy (Docket Number FAA-2009-0773) ends May 5, 2010. Comments can be submitted on line at www.regulations.gov or by mail to Docket Operations, M-30; U.S. Department of Transportation, 1200 New Jersey Avenue, SE, Room W12-140, West Building Ground Floor, Washington, DC 20590-0001 I am taking the liberty of cross-posting this on J. Mac McCllelan's blog post on the same subject. Apologies if that is a violation of the rules. (Didn't see anything about it on a quick scan of the Terms of Use.)

Amen, amen & amen. The good secretary had his head firmly up his LaHood on this one.