FAA proposes ending diabetes special issuance requirement

AOPA strongly supports the concept and invites pilots to join the association in submitting comments on the rulemaking proposal by the October 5 deadline.

The FAA estimates significant savings for applicants and the agency­—from $39.7 million in the "low-case" scenario up to $80.19 million over five years—to result from forgoing the special issuance process for pilots with non-insulin-dependent diabetes mellitus (NIDDM).

"Processing all NIDDM cases via the SI process places a burden on applicants and FAA. Reducing time, steps, and number of people required to issue medical certificates in new or recertification cases would provide relief to airmen whose NIDDM is well controlled with approved treatments," the agency wrote in its notice of proposed rulemaking.

Since establishing all diabetes diagnoses as disqualifying in 1959, the agency has taken progressive steps to enable pilot medical certification via special issuance (in 1982), and began granting special issuance medical certificates in the late 1980s to pilots who control diabetes with diet and oral medication. The agency commissioned the American Medical Association to review pilot medical standards and make recommendations. In 1994, while not updating the regulations, the FAA, citing AMA recommendations, made it a formal policy to no longer categorically deny medical certificates on the basis of a diabetes diagnosis. The special issuance process, where medical certificate applications are referred to the FAA for further review, remains in place.

"FAA proposes to no longer classify NIDDM as a specifically disqualifying medical condition under [FAR Part 67]. The proposed amendment would remove the phrase 'or any other hypoglycemic drug' from [Part 67]. If finalized as proposed, this change would allow applicants with NIDDM to be potentially issued first-, second-, and third-class medical certificates by AMEs at the time of the medical examination, as opposed to deferral to FAA for the SI process required under current regulations."

An FAA analysis of fatal accidents involving airman with NIDDM diagnoses between 2008 and 2025 identified 51 cases that met that criteria. In 50 of those, based on the NTSB findings and other information, the FAA determined that pilot incapacitation related to diabetes is "improbable"; one investigation remains open.