Pilots who can recite every limitation of their aircraft rarely know their own LDL or hemoglobin A1C, Gulfstream Aerospace flight surgeon Richard Roth told attendees this week at Bombardier Safety Standdown. The session walked through recent FAA certification changes and the reporting errors that can cost aviators their medicals.
Roth, a senior FAA and EASA aviation medical examiner who reviews cases for the NTSB medical appeals branch, said most certification damage is self-inflicted rather than medical, and that a relationship with an AME established before the exam is the best defense. Among the changes catching both airmen and examiners is the computerized color vision test the agency adopted for initial applicants on Jan. 1, 2025.
Pilots who have passed the Ishihara color plates at any point in their careers are exempt from a color vision retest, Roth said. Most of the roughly 2,500 AMEs in the U.S. do not realize that a prior Ishihara pass exempts an airman, and may administer the test anyway, he noted. “Sometimes we can make a problem where there isn’t a problem,” Roth said of the change.
The newer 25-image exam is more difficult to pass than the 38-plate version it replaced. A modest deficiency that would have passed the plates can fail the new exam, and a failure, which links directly to the agency, limits the airman to a third-class medical, day VFR only.
Color vision was one case of Roth’s broader presentation, which encouraged pilots to take more responsibility for their exams. “We put everything into our life for our company, or our aircraft, or our safety, or the people behind us, but we don’t always put everything in our own health,” he explained.
The MedXPress application is a federal legal document, and Roth said the agency is “looking for deceit with motive,” not minor omissions. A dental visit or a sinus infection left off the form is not the exposure; an unreported episode of chest pain, syncope, or unexplained confusion is. Revocation can reduce a logbook to zero flight hours, a penalty he said many pilots fear more than fines.
Of roughly 400,000 applications a year, about 10% require a special issuance reviewed by hand in Oklahoma City, most commonly for cardiac disease, certain cancers, diabetes, and sleep apnea. Outright denial is rare, Roth said, and usually follows a failure to provide requested documentation rather than a medical judgment. A general denial letter carries reconsideration instructions; supplying every listed item, with records less than 90 days old, generally produces an issuance.
He urged pilots to know which conditions an examiner can clear at the time of the exam without deferral—among them hypertension controlled below 155 over 95, pre-diabetes, treated kidney stones, and resected cancers with no ongoing chemotherapy or radiation—and to call an AME before submitting a complicated application rather than after.
On medications, Roth noted that Zyrtec grounds a pilot while Claritin does not, and that prednisone above 20 milligrams equivalent is disqualifying until tapered. “The most common toxicology finding in dead pilots is Benadryl, because it stays in the system so long,” he said.
An airman with a single DUI below 0.15 and no other red flags can usually be issued, with 0.15 and above triggering the HIMS program, but Roth said he requires the arrest record regardless of how a court disposed of the charge. “It’s not just the number; it’s also the narrative,” he said.
Pilots returning from ADHD medication must be off it for 90 days, with pharmacy records and a urine screen. VA disability benefits must be reported: a diagnosis an airman is being paid for is one the agency can find, and failure to disclose it is the violation, not the condition.
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