ALPA Files for Exemption from SIC First Class Medical Requirement

ALPA, joined by Airlines for America (A4A), petitioned the FAA today to permit pilots flying as Second In Command (SIC) to continue to operate aircraft in part 121 operations with a Second Class medical certificate After August 1, 2013, instead of a First Class Medical certificate. This exemption was filed in response to the FAA’s April 10, 2013, Information for Operators (InFO) bulletin 13004, which states, in part:

In accordance with the Airline Safety and Federal Aviation Administration (FAA) Extension Act of 2010, Public Law (P.L.) 111-216, section 216, pilot flightcrew members who are authorized to operate in part 121 operations must have obtained an ATP certificate, issued under part 61 by August 2, 2013, regardless of the FAA’s progress in related rulemaking. As a result of that requirement, all pilot flightcrew members will be exercising the privileges of an ATP certificate and, therefore, will be required to hold a first class medical certificate per § 61.23.

The FAA emphasizes that P.L. 111-216 does not include any grandfathering provisions for current pilot flightcrew members who hold commercial pilot certificates. In addition, the regulations currently do not allow a pilot exercising the privileges of an ATP certificate to hold any medical certificate other than a first class medical certificate.

ALPA has previously recommended to its membership that pilots not holding a First Class medical should endeavor to obtain it before August 2, 2013. Today’s petition for exemption from this rule is intended to protect all pilots flying as SICs in part 121 operations on the basis of the following: P.L. 111-216, which focuses on pilot training and other related qualifications, does not direct FAA to amend the medical qualifications for these pilots; SICs have operated with Second Class medical certificates for decades with no demonstrable safety impact; and, the livelihoods of a significant number of pilots, now and in the future, could be impacted by this ruling.

As has been previously announced, unless the FAA modifies the regulations regarding the requirements for all pilots to hold an ATP contained P.L. 111-216, pilots not holding an ATP by that deadline may not be permitted to be used by a carrier in Part 121 operations.

ALPA continues to do all that it can to ensure that the employment status of current airline pilots is not altered by the 2010 law, but it is incumbent upon affected pilots to be fully aware of what may transpire on August 2, 2013 and prepare accordingly. ALPA will pass along additional information on this important subject as it becomes available.

For questions or concerns about this matter, please contact the Engineering & Air Safety department (800-424-2470).