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Unmanned Aircraft Pilot

Medical CertificationRequirements

Kevin W. WilliamsCivil Aerospace Medical InstituteFederal Aviation AdministrationOklahoma City, OK 73125

February 2007

Final Report

DOT/FAA/AM-07/3Oce o Aerospace MedicineWashington, DC 20591


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NOTICE

This document is disseminated under the sponsorship

of the U.S. Department of Transportation in the interest

of information exchange. The United States Government

assumes no liability for the contents thereof.

___________

This publication and all Office of Aerospace Medicine

technical reports are available in full-text from the CivilAerospace Medical Institutes publications Web site:

www.faa.gov/library/reports/medical/oamtechreports/index.cfm


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Technical Report Documentation Page

1. Report No. 2. Government Accession No. 3. Recipient's Catalog No.

DOT/FAA/AM-07/3

4. Title and Subtitle 5. Report Date

February 2007Unmanned Aircraft Pilot Medical Certification Requirements6. Performing Organization Code

7. Author(s) 8. Performing Organization Report No.

Williams KW

9. Performing Organization Name and Address 10. Work Unit No. (TRAIS)

FAA Civil Aerospace Medical Institute

P.O. Box 25082 11. Contract or Grant No.

Oklahoma City, OK 73125

12. Sponsoring Agency name and Address 13. Type of Report and Period Covered

Office of Aerospace MedicineFederal Aviation Administration800 Independence Ave., S.W.

Washington, DC 20591 14. Sponsoring Agency Code

15. Supplemental Notes

Work was accomplished under approved task AHRR52116. Abstract

This research study was undertaken to create recommendations for unmanned aircraft pilot medicalcertification requirements. The effort consisted of the convening of a panel of subject matter experts andinteractions with groups engaged in the process of establishing unmanned aircraft pilot guidelines. The resultsof this effort were a recommendation and justification for use of the second-class medical certification.

17. Key Words 18. Distribution Statement

Unmanned Aircraft, UA, UAV, Pilot MedicalCertification

Document is available to the public through theDefense Technical Information Center, Ft. Belvior, VA22060; and the National Technical InformationService, Springfield, VA 22161

19. Security Classif. (of this report) 20. Security Classif. (of this page) 21. No. of Pages 22. Price

Unclassified Unclassified 14Form DOT F 1700.7 (8-72) Reproduction of completed page authorized


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ExECuTIvE Summary

This research addressed the medical requirements necessary or unmanned aircrat (UA) pilots or successul

fight in the National Airspace System (NAS). Given that an existing medical certication was recommended, the

question o which class o certication to propose was based on the perceived level o risk imposed by the potential

incapacitation o the UA pilot. A second-class medical certication was judged to be the most acceptable, consider-

ing that there were several actors that mitigated the risk o pilot incapacitation relative to those o manned aircrat.

First, actors related to changes in air pressure could be ignored, assuming that control stations or non-military

operations would be on the ground. Second, many o the current UA systems have procedures that have been

established or lost data link. Lost data link, where the pilot cannot transmit commands to the aircrat, is unction-

ally equivalent to pilot incapacitation. Third, the level o automation o a system determines the criticality o pilot

incapacitation because some highly automated systems (e.g., Global Hawk) will continue normal fight whether a

pilot is or is not present.


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Unmanned aircraft Pilotmedicalcertification reqUirements

INTrOduCTION

The rapidly expanding commercial Unmanned Aircrat(UA) industry presents a challenge to regulators whosetask it is to ensure the saety o the fying public, as wellas others who might be injured as a result o an aircrataccident. The military has used unmanned aircrat orseveral decades with varying levels o success. Within thelast ew years, commercial UA operations have increaseddramatically. Most o these operations have concentratedon surveillance and advertisement, but several companieshave expressed an interest in using unmanned aircrat ora variety o other commercial endeavors.

Although the term unmanned aircrat suggests theabsence o human interaction, the human operator/pilotis still a critical element in the success o any unmannedaircrat operation. For many UA systems, a contributingactor to a substantial proportion o accidents is humanerror (Williams, 2004). The Federal Aviation Adminis-tration (FAA) needs guidance to assist in deciding whowill pilot UA and the training required. Research may berequired to investigate the eects on pilot perormance odierent types o console display interaces; how UA fightmission proles aect pilot workload, vigilance, atigue,and perormance; and to determine whether prior fight

experience is important in both training and operationo UA. Also, it is important to determine whether newopportunities present themselves in terms o the inclu-sion o handicapped persons previously excluded rompiloting aircrat but not expected to have diculty withpiloting a UA, and to investigate medical and physiologi-cal standards required to operate UA.

To assist in developing guidance, a research eort wasbegun to produce recommendations regarding UA pilotmedical qualications. The approach consisted o threesteps. First, a literature review o existing research on UApilot requirements was conducted. Second, an analysis o

current and potential UA commercial applications andan analysis o current and potential UA airspace usagewas completed. The third step in the process involvedassembling a team o subject matter experts to reviewproposed UA pilot medical and airman certication re-quirements and make recommendations regarding howthose requirements should be changed or expanded. Thispaper is a summary o that eort.

ua PIlOT rEquIrEmENTSlITEraTurE rEvIEw

The rst task was to review the literature related tothe development o UA pilot requirements. Appendix Apresents a bibliography o research related to the develop-ment o UA pilot requirements. The literature ell intoa ew basic categories. Many o the papers were recom-mendations regarding the development o requirements(e.g., DeGarmo, 2004; Dolgin, Kay, Wasel, Langelier,& Homan, 2001; Reising, 2003). The paper by Weeks(2000) listed current crew requirements or several dier-ent military systems. Finally, some o the papers reportedactual empirical research addressing some aspect o pilotrequirements (Barnes & Matz, 1998; Fogel, Gill, Mout,Hulett, & Englund, 1973; Schreiber, Lyon, Martin, &Coner, 2002).

The research by Fogel et al. (1973) was especiallyinteresting because it was one o the earliest attempts toaddress the issue o UA pilot requirements. In the study,three groups o pilots were recruited to fy a simulationo a Strike remotely piloted vehicle. The rst group con-sisted o Navy Attack pilots with extensive combat aircratexperience. The second group consisted o radio-controlaircrat hobbyists. The third was composed o non-pilots

with no radio-control aircrat experience. The resultsshowed that, even though the Navy pilots scored betterthan either o the other two groups, the non-pilot groupsshowed signicant improvement in fight control acrossthe sessions, leading the authors to state, It is hypothesizedthat a broader segment o relatively untrained personnelcould be brought up to the required level o skill withshort time simulation/training provided they meet someminimum selection criteria (Fogel et al., p. 75).

In the study, the control interace consisted o a joystickor controlling the aircrat (but no rudder pedals), withvery little in the way o automation or simpliying the

control task. However, the researchers did compare twotypes o fight control systems, with the joystick eitherdirectly controlling (simulated) aircrat suraces or amore sophisticated control system where the joystickcommanded the aircrat perormance (bank and pitch)directly. The authors concluded that the perormancecontrol joystick was superior or aircrat control, regard-less o the level o pilot experience.


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The research by Schreiber et al. (2002) looked at theimpact o prior fight experience, both Predator andmanned aircrat, on learning to fy the Predator unmannedaircrat system (UAS). Seven groups o participants wereused in the study, ranging rom no fight experience toprior Predator fight experience. Results showed that thegroup with no fying experience perormed signicantly

worse than the other groups, while the group with previousPredator experience perormed signicantly better. Thisnding was expected. However, an unexpected ndingrom the study was that participants with various levelsand types o non-Predator fight experience all perormedat relatively the same level on the Predator system. Theauthors concluded that any type o fight experience withan aircrat with similar handling characteristics to thePredator was benecial or fight training on the Preda-tor system. They pointed out, though, that the studylooked only at stick and rudder skills and not at moregeneral types o fight skills such as communication and

airspace management. In addition, the study did not ad-dress whether other types o training, such as simulatortraining, would also transer to the Predator.

While it might be possible to establish whether acertain type o training or experience is more eectivelytranserred to a particular UA system, such as the Predator,these studies have not answered the question o whethermanned aircrat time is required to be a successul piloto an unmanned aircrat. We know that certain systems,like the U.S. Army Hunter and Shadow systems, aresuccessully fown by pilots with no manned aircratexperience. However, once these systems begin fying in

populated airspace, there is a question o whether a lacko manned aircrat experience within the airspace mightdegrade the eectiveness o the pilot and the saety o thefight. Research is needed to address this issue.

Finally, in regard to pilot medical qualications, theliterature review ailed to nd any research that wasrelevant. While it might be possible to make the argu-ment that studies showing the benet o manned aircratexperience or the piloting o certain systems suggestthat medical qualications should be similar to mannedaircrat qualications, the more reasonable conclusionis that no research is available to guide the decision onmedical qualications.

ua aPPlICaTIONS aNdaIrSPaCE uSagE

Ater completion o the literature review, the secondtask was an assessment o current and near-term UAapplications, along with an assessment o the types oairspace usage that would be required or the applications.

It is o critical importance that we anticipate the types oactivities that will be accomplished using UA. The activi-ties that they will perorm will determine the kinds osystems required, the types o airspace that will be fownthrough, the level o automation that will be used, and thepilot skills and abilities needed to perorm the task. Theairspace requirements will, in turn, determine the expecteddegree o interaction with air trac control and with otheraircrat that will occur during typical fights.

The potential applications to which UA can be em-ployed is expansive. However, they all all into just a ewbasic categories, based on the type o payload that is car-

ried and its unction. The primary purpose or unmannedaircrat stems rom the need to place a payload o sometype in an aircrat. These needs all into the categories o1) Sensor/Surveillance, 2) Payload Delivery, 3) Orbiting,and 4) Transport.

Senso/SveillnceBy ar, the largest category o current applications or

UA, both military and civilian, is Sensor/Surveillance.The placement o a camera or other type o sensor on anaircrat has a great many uses. The types o applicationsvary widely in regard to the type o sensor employed, the

level o detail required, and what is being surveilled.Within the category o sensor/surveillance, we can

distinguish between moving and stationary targets.We can also distinguish between the need or real-timedownload o data or the collection o inormation thatcan be analyzed later.

A ew current sensor/surveillance applications includelogging inspection, pipeline and power line inspection,border patrol, and crop analysis. Potential applicationsinclude those involving law enorcement, agriculture,construction, media, the petroleum industry and public

utilities (James, 1994), as well as data collection or ar-chaeologists, surveyors, and geologists (Aerospace Daily,1994). Other applications include monitoring wildres,foods, and crops (Dino, 2003).


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Pylo deliveyPayload delivery applicationsreer to the use o a UA to

deliver a non-reusable payload. For military UA, this reersto ordnance delivery such as air-to-air or air-to-groundmissiles. Civil applications o payload delivery would becrop dusting or re ghting. Air-to-air reueling is alsoan example o payload delivery. For each o these appli-

cations, the payload is expendable and is not intendedto return with the aircrat. This aspect distinguishes thepayload delivery category rom other categories.

ObitingOrbiting applicationsrequire that the aircrat maintain

position at a particular location or reasons other thansurveillance. At least three applications present themselvesin this category. One is the use o UA at high altitudesto act as communication satellites. Telecommunicationscompanies could use UA to relay signals or mobile phones,or example. Another application is the use o UA or

advertising purposes; banner towing, or example.

TnspotTransport applications reer to the carrying o goods

and/or people rom one location to another. Expressmail delivery to small towns is one potential transportapplication (Aerospace Daily, 1994). For this category,the payload is not expendable and is expected to survivethe fight intact. In addition, the payload is intended tobe moved rom one location to another, as opposed tothose applications where the payload is returned to thepoint o origin.

aispce usgeIt is important that we anticipate how these various

applications will impact the airspace. Table 1 lists vari-ous types o UA applications, organized by the type oairspace that will be utilized. The airspace categories are

listed (rom top to bottom) in terms o the criticality osense-and-avoid technology required to fy in that air-space. The term transition in the table reers to the actthat the aircrat might take o rom a public use airport(Class B, C, or D airspace) and have to transit throughthis airspace beore getting to the location where the ocalactivity will occur.

We have dierentiated between two types o Class Gairspace, depending on whether the area underlying thatairspace is populated or not. Flight in Class G airspacesometimes originates rom a public use airport, depend-ing on the size o the aircrat or its ability to land andtakeo vertically or without a runway. These actors ledto the dierentiation o our separate categories that dealwith Class G airspace. The category called high altitudefight reers to fight above FL430 (43,000 eet abovemean sea level), which is still within Class A airspace butis rarely used by air carriers. Flight within Class E airspace

was considered more critical than fight within Class Aairspace in regard to the sense-and-avoid issue becauseClass A is positively controlled airspace and because eq-uipage requirements or aircrat within Class A are morestringent than equipage requirements or Class E.

rTCa SceniosIn an eort to gauge the types o applications and

systems that are expected, a review was made o 63unmanned aircrat fight scenarios that were developedby members o RTCA Special Committee 203 on Un-manned Aircrat Systems. These scenarios are posted on

their limited-access Web site.The scenarios describe systems that range in weight

rom 200 grams up to 96,000 pounds. Many o thescenarios use existing military systems. Sometimes thesescenarios are military in nature, but more oten thescenarios involve civilian use o a military system. Ater

Table 1. Listing of applications by airspace requirements.

Airspace\Application Surveillance Payload Orbit Transport

Class G only unpopulated RC apps, cropinspection

Transition to Class Gunpopulated

Pipelineinspection

Crop dusting

Class G only populated Building fireinspection

Transition to Class Gpopulated

Powerlineinspection

Advertisement

Transition to high altitudeflight

Environmentalimaging

Pseudo satellite

Transition to Class A Crop surveys Air refuel Cargo/people

Transition to Class E Law enforcement Banner towing Cargo


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reviewing each o the scenarios, the ollowing gureswere constructed to categorize the types o applicationsproposed and the types o airspace that will be used.Figure 1 shows how the scenarios all into the our basic

types o applications described above.As can be seen rom Figure 1, most scenarios, 49

(78%), ell into the Sensor/Surveillance category. TheOrbiting category was a distant second, although itshould be pointed out that test fights were placed intothis category. The Transport applications included thedelivery o mail and the transportation o donor organs.Finally, the Payload applications included two in-fightreueling scenarios and a military strike mission.

Figure 2 shows the breakdown o scenarios accord-ing to how they would use the airspace. Airspace usagecategories are those reerenced earlier. It should be notedthat the numbers in Figures 1 and 2 add to greater thanthe number o scenarios because some o the suggestedscenarios included more than one application and morethan one type o airspace being used.

Figure 2 does not show two o the airspace usagecategories because there were no scenarios associatedwith those categories. Those categories were transition tonon-populated Class Gairspace and transition to populatedClass Gairspace. That these categories were not included

in the scenarios suggests that the types osystems expected to fy in Class G airspacewould be able to take o and land withoutthe need or a runway. All o the scenariosoccurring within Class G airspace as-sumed that the aircrat would be launchedand recovered within Class G airspace.

Scenarios occurring within a militaryoperational area (MOA) were classiedas Class G airspace over a non-populatedarea. Scenarios occurring within Class Gairspace over a populated area (G-pop inthe gure) involved monitoring automo-bile trac, transporting donor organs tohospitals, and police surveillance. It isinteresting to note that the majority oscenarios used airspace in a manner thatminimized the need or sense-and-avoidtechnologies. One conclusion that was

evident rom reviewing the RTCA sce-narios is that a distinction can be madebetween systems that remain within theline-o-sight o the pilot and those that donot. This distinction could prove useulwhen it comes to speciying airworthinessand pilot classications.

Summary Of a mEETINg ON uaPIlOT mEdICal rEquIrEmENTS

On July 26, 2005, a meeting was held at the FAA

Civil Aerospace Medical Institute (CAMI) in OklahomaCity, OK, o a diverse group o subject matter expertsrom industry, academia, the FAA, and the military todiscuss UA pilot medical requirements. Table 2 lists theattendees and contact inormation.

Attendees included representatives o several groupscurrently working on the development o standards andguidelines or UA. There were representatives rom theNational Aeronautics and Space Administration (NASA)Access 5, the FAA, ASTM F38, RTCA SC-203, and SAE-G10 at the meeting. In addition, Dr. Warren Silbermanrepresented the FAA Aerospace Medical CerticationDivision in regard to the medical certication require-ments.

Given that the meeting encompassed only a single day,an attempt was made to ocus the discussion as much aspossible by providing to the group a drat standard thatwas developed by the FAA Flight Standards Division(AFS-400). In particular, one paragraph rom the dratUA standard (shown below) was reviewed and discussedextensively during the meeting.

0

10

20

30

40

50

Number of

Scenarios

Surv/Sens Payload Orbiting Transport

Application Categories

Figure 1. Breakdown of RTCA scenarios by application category

0

510

15

20

25

30

Number of

Scenarios

G-non pop G-pop High Class A Class E

Airspace Usage Categories

Figure 2. Breakdown of RTCA scenarios by airspace usage category.


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6.14 Pilot/Observer Medical Standards. Pilots andobservers must have in their possession a current third class

(or higher) airman medical certifcate that has been issuedunder 14CFR67. The provisions o 14CFR91.17 on alco-hol and drugs apply to both UA pilots and observers.

Current pilot medical requirements are separatedinto three classes. Table 3 lists the requirements or eachclass.

The rst topic discussed was whether the agency shouldcreate a new medical certication category or UA pilotsor use an existing certication. The rapid consensus bythe group was that the creation o a new certicationwould be prohibitive or a number o reasons related tothe diculty, expense, and time o initiating any new

rulemaking activity.The next topic addressed which existing medical

certication(s) to use. Several suggestions were gener-ated by the group, including the use o the Air TracController (ATC) medical certication and the use o anautomobile drivers license. Regarding the ATC medicalcertication, the argument presented was that the activ-ity o a UA pilot was, in some ways, closer to that o anair trac controller. However, it was pointed out thatthere was very little dierence between the ATC medicalrequirements and the second-class medical certicationrequirements. The real question, then, could be reduced

to whether or not a second-class medical was required.The discussion regarding the use o an automobile

drivers license, as is done in Australia and in the UnitedStates or the Sport Pilot Certicate, centered on theidea o accountability and proessionalism. Some o thegroup maintained that there was a need to instill at leasta minimal level o accountability and proessionalismupon UA pilots, and that the use o a drivers licensewould not accomplish this goal. Others, however, sug-gested that the pilot certication process could be used

to instill proessionalism and accountability and thata stronger rationale, using medical reasons, should be

established beore discarding the use o a drivers licenseor medical requirements.As a ollow-up to the meeting, Anthony Tvaryanas

provided a useul summarization regarding the establish-ment o occupational medical standards. Basically, thereare two separate reasons to establish medical standards oroccupations. The rst is predicated on the need withinindividual organizations to establish medical standardsthat comply with the Americans with Disabilities Act.The procedure includes an analysis o the job require-ments (knowledge, skills, and abilities) or a particularposition. Because the analysis is or each individual job,

there is no generalizable medical standard. Ater the jobrequirements are established, the medical examiner, asdescribed by Tvaryanas, typically receives a list o thejob essential tasks (stand or 2 hrs, lit 25 lbs, etc.). Theexaminer determines and reports whether the individualcan or cannot perorm the essential tasks outlined by theemployer. I they cannot, the organization has a duty toattempt to accommodate the individual (redesign the job),unless it poses an undue burden on the organization, orthe individual poses an undue hazard to the saety o selor others. This approach is raught with the potential orlitigation (Tvaryanas, personal communication).

The second reason or establishing medical standards isto protect the public rom occupations where public saetyis potentially at risk, such as transportation (including airtransport) and the nuclear industry. Medical standardsor these occupations are not based on an analysis othe specic tasks but, instead, are ocused on the risk oimpairment or incapacitation due to the pathology oany preexisting medical conditions. These standards alsousually stipulate provisions or drug and alcohol testing.The establishment o medical standards or unmanned

Table 2. Attendee listing.

Name Organization E-mail Phone

Adams, Rich FAA AFS-430 [email protected] 202-385-4612

Beringer, Dennis FAA/CAMI AAM-510 [email protected] 405-954-6828

Berson, Barry Lockheed Martin/Access 5 [email protected] 661-572-7326

Eischens, Woody MTSI/Access 5 [email protected] 703-212-8870

x133

Goldfinger, Jeff Brandes Associates/ASTMF38 [email protected] 775-232-1276

Johnson, Marca Access 5 [email protected] 410-961-3149

McCarley, Jason U of Illinois Institute ofAviation

[email protected] 217-244-8854

Silberman, Warren FAA/CAMI AAM-300 [email protected] 405-954-7653

Swartz, Steve FAA AFS-430 [email protected] 202-385-4574

Tvaryanas, Anthony USAF (311 HSW/PE) [email protected] 210-536-4446

Williams, Kevin FAA/CAMI AAM-510 [email protected] 405-954-6843


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Table 3. Pilot medical certification standards.

Certificate Class PilotType

First-Class AirlineTransport

Second-Class Commercial

Third-Class - Private

Distant Vision 20/20 or better in each eye separately, with orwithout correction.

20/40 or better in eacheye separately, with orwithout correction.

Near Vision 20/40 or better in each eye separately (Snellen equivalent), with or without

correction, as measured at 16 in.

Intermediate Vision 20/40 or better in each eye separately (Snellenequivalent), with or without correction at age 50 andover, as measured at 32 in.

No requirement.

Color Vision Ability to perceive those colors necessary for safe performance of pilot duties.

Hearing Demonstrate hearing of an average conversational voice in a quiet room, usingboth ears at 6 feet, with the back turned to the examiner or pass one of theaudiometric tests.

Audiology Audiometric speech discrimination test (Score at least 70% discrimination inone ear):

500Hz 1,000Hz 2,000Hz 3,000Hz

Better Ear 35Db 30Db 30Db 40Db

Worse Ear 35Db 50Db 50Db 60Db

Ear, Nose & Throat No ear disease or condition manifested by, or that may reasonably be expectedto be manifested by, vertigo or a disturbance of speech or equilibrium.

Blood Pressure No specified values stated in the standards. 155/95 Maximum allowed.

Electrocardiogram At age 35 & annuallyafter age 40.

Not routinely required.

Mental No diagnosis of psychosis or bipolar disorder or severe personality disorders.

Substance Dependence& Substance Abuse

A diagnosis or medical history of substance dependence is disqualifyingunless there is established clinical evidence, satisfactory to the Federal AirSurgeon, of recovery, including sustained total abstinence from thesubstance(s) for not less than the preceding 2 yrs. A history of substance abuse

within the preceding 2 yrs is disqualifying. Substance includes alcohol andother drugs (i.e., PCP, sedatives and hypnotics, anxiolytics, marijuana,cocaine, opiods, amphetamines, hallucinogens, and other psychoactive drugsor chemicals.)

DisqualifyingConditions

Note: Pilots with theseconditions may still beeligible for SpecialIssuance of a medicalcertificate.

Examiner must disqualify if the applicant has a history of: (1) diabetesmellitus requiring hypoglycemic medications; (2) angina pectoris; (3)coronary heart disease that has been treated or, if untreated, that has beensymptomatic of clinically significant; (4) myocardial infarction; (5) cardiacvalve replacement; (6) permanent cardiac pacemaker; (7) heart replacement;(8) psychosis; (9) bipolar disease; (10) personality disorder that is severeenough to have repeatedly manifested itself by overt acts; (11) substancedependence; (12) substance abuse; (13) epilepsy; (14) disturbance ofconsciousness without satisfactory explanation of cause; and (15) transientloss of control of nervous system function(s) without satisfactory explanation

of cause.


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aircrat pilots clearly alls under the second reason. Thus,the suggestion by Tvaryanas and others in the group(e.g., Eischens) was that it is important to identiy theactors associated with the risk o pilot incapacitation orunmanned aircrat in deciding on the appropriate level omedical certication. In addition, it is important that weunderstand these actors as they relate to manned aircrat

to obtain an objective assessment.Ultimately, the primary driver o the decision o whichcertication level to use was the current perception orisk or these aircrat. One member o the group oeredthe ollowing comment in regard to the denition oacceptable risk:

I think the core issue is dening acceptable publicrisk rom UA operations and applications. This hashistorically driven (at least in part) the evolution o thecurrent stratied pilot and medical certication systemsor manned aviation. This cut-point (acceptable versusunacceptable risk) is not dened by the medical, scientic,

or engineering communities, but rather by the policycommunity (e.g., our political/regulatory institutions).For example, the current 1% rule (derived rom Euro-pean civil aviation standards) or risk o incapacitation incommercial aviation is a policy threshold. It could justhave easily been a 2% rule or a 5% rule. The point isthat it is a completely arbitrary boundary. The unctiono the medical/scientic community is to then quantiyan individuals risk to determine whether they may exceedthis arbitrary threshold. This is accomplished in part bysetting certication standards. It is inherently utile or themedical and scientic communities to try to set standards

without the policy community rst dening acceptablerisk. I would urge the FAA to consider this core issueearly, and then return to a discussion o standards setting.Once acceptable public risk is dened, setting medicalstandards becomes more an academic exercise rather thana policy debate (A. Tvaryanas).

Regarding the risk o pilot incapacitation, at least a ewactors distinguish this risk rom manned aircrat. First,actors related to changes in air pressure can be ignored,assuming that control stations or non-military operationswill always be on the ground. Second, it was pointed outby one participant that many o the current UA systemshave procedures established or lost data link. Lost datalink, where the pilot cannot transmit commands to theaircrat, is unctionally equivalent to pilot incapacitation(Goldnger, personal communication). For those systemswith an adequate procedure or handling a lost data link,pilot incapacitation does not compromise saety to thesame extent as it would in a manned aircrat. Third, thelevel o automation o a system determines the critical-ity o pilot incapacitation, since some highly automated

systems (e.g., Global Hawk) will continue normal fightwhether a pilot is present or not (Tvaryanas, personalcommunication).

In the end, it was decided that not enough was knownabout these aircrat to make an accurate assessment o allo the risks involved. Because o this, the decision wasreached by the group that the original suggestion o a

third-class medical certication was adequate, with useo the existing medical waiver process (also called Au-thorization o Special Issuance) or handling exceptions(e.g., paraplegics). This decision was also supported by theactors identied above that mitigate the severity o pilotincapacitation. However, there was additional discussionthat some applications might require a second- or rst-class medical certication because o the increased risksinvolved. Imposing dierent certication requirements,though, would require a clearer specication o pilot cer-tication levels and UA classes. The third-class medicalcertication statement was believed to apply to many, i

not all, existing commercial and public UA endeavors (e.g.,border patrol applications). The question then arose asto what types o pilot certication would require strictermedical certication. Because the document was viewedas sucient or present needs, no wording changes weresuggested or paragraph 6.14.

Since the meeting, the FAA Oce o Aerospace Medi-cine has suggested that a second-class medical certicationmight be more appropriate or UA pilots. The main rea-sons or this recommendation are that some UA pilots arerequired to maintain visual contact with the aircrat and athird-class medical certication requires only 20/40 vision,

with or without correction. On the other hand, second-class medical certication requires 20/20 vision, with orwithout correction. A second reason or a second-classmedical is that there are currently no commercial pilotsthat have less than a second-class medical. A replacementparagraph has been drated that will change the medicalcertication requirement to second-class. The paragraphis as ollows:

Pilot/Observer Medical Standards. Pilots and observersengaging in fight operations or compensation or hire whowill, in the course o their duties, perorm visual collisionavoidance duties IAW1 paragraph 6.20 o this policy, must

have in their possession a current Second-Class airmanmedical certicate that has been issued under 14 CFR 67,Medical Standards And Certication. Pilots and observersengaged in fight operations o other than a commercialnature will possess a current Class Three medical certica-tion. The provisions o 14 CFR 91.17, Alcohol or Drugs,applies to both UA pilots and observers. The Department oDeense will establish guidelines or medical tness that, inthe judgment o the services, provides a similar standard.

1 In accordance with (IAW)


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Summary aNd CONCluSIONS

The goal o the research was a recommendation o themedical requirements or UA pilots. The recommendationor the level o medical class or UA pilots was based onan analysis o the method or establishing the medicalrequirements o other occupations, including manned-

aircrat pilots. Rather than suggesting the creation o anew medical class or UA pilots, the group decided torecommend an existing pilot medical certication. Therewere several reasons supporting this decision, includingthe diculty o establishing a new certication level andthe problems associated with training medical examinersthat would be asked to assess whether UA pilots success-ully met the new requirements.

Given that an existing medical certication was recom-mended, the question o which class o certication topropose was based on the perceived level o risk imposedby the potential incapacitation o the UA pilot. The origi-

nal recommendation o a third-class medical certicationwas replaced with the implementation o a second-classmedical in the standards. The decision was based on theidea that there were several actors that mitigated the risko pilot incapacitation relative to those o manned aircrat.First, actors related to changes in air pressure could beignored, assuming that control stations or non-militaryoperations would always be on the ground. Second, manyo the current UA systems have procedures that havebeen established or lost data link. Lost data link, wherethe pilot cannot transmit commands to the aircrat, isunctionally equivalent to pilot incapacitation. Third, the

level o automation o a system determines the criticalityo pilot incapacitation because some highly automatedsystems (e.g., Global Hawk) will continue normal fightwhether a pilot is or is not present.

Against these mitigating actors was the act that mostUA operations were anticipated to be public use, such asborder patrol fights or commercial activities. Manned-aircrat pilots in these instances are required to have asecond-class medical certication. In addition, there isvery little dierence between a second- and third-classmedical certication. The major dierences are the visionrequirements (20/20 vs. 20/40 correctable) and how otenthey must be renewed.

Finally, the waiver process available to pilots providesthat handicapped persons can still receive a medicalcertication. All that is required is a demonstration otheir ability to pilot the aircrat eectively. This processgives individuals who might not be able to fy mannedaircrat an opportunity to receive medical certicationor fying an unmanned aircrat. However, issues withpilot airman certication must still be resolved beorethis can occur.

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