Unmanned Aircraft Pilot 

Medical Certification 

Requirements

Kevin W. Williams

Civil Aerospace Medical Institute

Federal Aviation Administration

Oklahoma City, OK 73125

February 2007

Final Report

DOT/FAA/AM-07/3

Office of Aerospace Medicine

Washington, DC 20591
NOTICE

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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 Civil 

Aerospace Medical Institute’s publications Web site: 

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i

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 

Unmanned Aircraft Pilot Medical Certification Requirements February 2007 

6. 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 Medicine 

Federal Aviation Administration 

800 Independence Ave., S.W. 

Washington, DC 20591 14. Sponsoring Agency Code 

15. Supplemental Notes 

Work was accomplished under approved task AHRR521 

16. Abstract 

This research study was undertaken to create recommendations for unmanned aircraft pilot medical 

certification requirements. The effort consisted of the convening of a panel of subject matter experts and 

interactions with groups engaged in the process of establishing unmanned aircraft pilot guidelines. The results 

of 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 Medical 

Certification

Document is available to the public through the 

Defense Technical Information Center, Ft. Belvior, VA 

22060; and the National Technical Information 

Service, Springfield, VA 22161 

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

Unclassified Unclassified 14 

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

iii

Executive Summary

This research addressed the medical requirements necessary for unmanned aircraft (UA) pilots for successful 

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

question of which class of certification to propose was based on the perceived level of risk imposed by the potential 

incapacitation of the UA pilot. A second-class medical certification was judged to be the most acceptable, considering that there were several factors that mitigated the risk of pilot incapacitation relative to those of manned aircraft. 

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

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

established for lost data link. Lost data link, where the pilot cannot transmit commands to the aircraft, is functionally equivalent to pilot incapacitation. Third, the level of automation of a system determines the criticality of pilot 

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

pilot is or is not present.

1

Unmanned Aircraft Pilot Medical Certification Requirements

Introduction

The rapidly expanding commercial Unmanned Aircraft 

(UA) industry presents a challenge to regulators whose 

task it is to ensure the safety of the flying public, as well 

as others who might be injured as a result of an aircraft 

accident. The military has used unmanned aircraft for 

several decades with varying levels of success. Within the 

last few years, commercial UA operations have increased 

dramatically. Most of these operations have concentrated 

on surveillance and advertisement, but several companies 

have expressed an interest in using unmanned aircraft for 

a variety of other commercial endeavors.

Although the term “unmanned aircraft” suggests the 

absence of human interaction, the human operator/pilot 

is still a critical element in the success of any unmanned 

aircraft operation. For many UA systems, a contributing 

factor to a substantial proportion of accidents is human 

error (Williams, 2004). The Federal Aviation Administration (FAA) needs guidance to assist in deciding who 

will pilot UA and the training required. Research may be 

required to investigate the effects on pilot performance of 

different types of console display interfaces; how UA flight 

mission profiles affect pilot workload, vigilance, fatigue, 

and performance; and to determine whether prior flight 

experience is important in both training and operation 

of UA. Also, it is important to determine whether new 

opportunities present themselves in terms of the inclusion of handicapped persons previously excluded from 

piloting aircraft but not expected to have difficulty with 

piloting a UA, and to investigate medical and physiological standards required to operate UA.

To assist in developing guidance, a research effort was 

begun to produce recommendations regarding UA pilot 

medical qualifications. The approach consisted of three 

steps. First, a literature review of existing research on UA 

pilot requirements was conducted. Second, an analysis of 

current and potential UA commercial applications and 

an analysis of current and potential UA airspace usage 

was completed. The third step in the process involved 

assembling a team of subject matter experts to review 

proposed UA pilot medical and airman certification requirements and make recommendations regarding how 

those requirements should be changed or expanded. This 

paper is a summary of that effort.

UA Pilot Requirements

Literature Review

The first task was to review the literature related to 

the development of UA pilot requirements. Appendix A 

presents a bibliography of research related to the development of UA pilot requirements. The literature fell into 

a few basic categories. Many of the papers were recommendations regarding the development of requirements 

(e.g., DeGarmo, 2004; Dolgin, Kay, Wasel, Langelier, 

& Hoffman, 2001; Reising, 2003). The paper by Weeks 

(2000) listed current crew requirements for several different military systems. Finally, some of the papers reported 

actual empirical research addressing some aspect of pilot 

requirements (Barnes & Matz, 1998; Fogel, Gill, Mout, 

Hulett, & Englund, 1973; Schreiber, Lyon, Martin, & 

Confer, 2002).

The research by Fogel et al. (1973) was especially 

interesting because it was one of the earliest attempts to 

address the issue of UA pilot requirements. In the study, 

three groups of pilots were recruited to fly a simulation 

of a Strike remotely piloted vehicle. The first group consisted of Navy Attack pilots with extensive combat aircraft 

experience. The second group consisted of radio-control 

aircraft hobbyists. The third was composed of non-pilots 

with no radio-control aircraft experience. The results 

showed that, even though the Navy pilots scored better 

than either of the other two groups, the non-pilot groups 

showed significant improvement in flight control across 

the sessions, leading the authors to state, “It is hypothesized 

that a broader segment of relatively untrained personnel 

could be brought up to the required level of skill with 

short time simulation/training provided they meet some 

minimum selection criteria” (Fogel et al., p. 75).

In the study, the control interface consisted of a joystick 

for controlling the aircraft (but no rudder pedals), with 

very little in the way of automation for simplifying the 

control task. However, the researchers did compare two 

types of flight control systems, with the joystick either 

directly controlling (simulated) aircraft surfaces or a 

more sophisticated control system where the joystick 

commanded the aircraft performance (bank and pitch) 

directly. The authors concluded that the performance 

control joystick was superior for aircraft control, regardless of the level of pilot experience.
2

The research by Schreiber et al. (2002) looked at the 

impact of prior flight experience, both Predator and 

manned aircraft, on learning to fly the Predator unmanned 

aircraft system (UAS). Seven groups of participants were 

used in the study, ranging from no flight experience to 

prior Predator flight experience. Results showed that the 

group with no flying experience performed significantly 

worse than the other groups, while the group with previous 

Predator experience performed significantly better. This 

finding was expected. However, an unexpected finding 

from the study was that participants with various levels 

and types of non-Predator flight experience all performed 

at relatively the same level on the Predator system. The 

authors concluded that any type of flight experience with 

an aircraft with similar handling characteristics to the 

Predator was beneficial for flight training on the Predator system. They pointed out, though, that the study 

looked only at stick and rudder skills and not at more 

general types of flight skills such as communication and 

airspace management. In addition, the study did not address whether other types of training, such as simulator 

training, would also transfer to the Predator.

While it might be possible to establish whether a 

certain type of training or experience is more effectively 

transferred to a particular UA system, such as the Predator, 

these studies have not answered the question of whether 

manned aircraft time is required to be a successful pilot 

of an unmanned aircraft. We know that certain systems, 

like the U.S. Army Hunter and Shadow systems, are 

successfully flown by pilots with no manned aircraft 

experience. However, once these systems begin flying in 

populated airspace, there is a question of whether a lack 

of manned aircraft experience within the airspace might 

degrade the effectiveness of the pilot and the safety of the 

flight. Research is needed to address this issue.

Finally, in regard to pilot medical qualifications, the 

literature review failed to find any research that was 

relevant. While it might be possible to make the argument that studies showing the benefit of manned aircraft 

experience for the piloting of certain systems suggest 

that medical qualifications should be similar to manned 

aircraft qualifications, the more reasonable conclusion 

is that no research is available to guide the decision on 

medical qualifications.

UA Applications and 

Airspace Usage

After completion of the literature review, the second 

task was an assessment of current and near-term UA 

applications, along with an assessment of the types of 

airspace usage that would be required for the applications. 

It is of critical importance that we anticipate the types of 

activities that will be accomplished using UA. The activities that they will perform will determine the kinds of 

systems required, the types of airspace that will be flown 

through, the level of automation that will be used, and the 

pilot skills and abilities needed to perform the task. The 

airspace requirements will, in turn, determine the expected 

degree of interaction with air traffic control and with other 

aircraft that will occur during typical flights.

The potential applications to which UA can be employed is expansive. However, they all fall into just a few 

basic categories, based on the type of payload that is carried and its function. The primary purpose for unmanned 

aircraft stems from the need to place a payload of some 

type in an aircraft. These needs fall into the categories of 

1) Sensor/Surveillance, 2) Payload Delivery, 3) Orbiting, 

and 4) Transport.

Sensor/Surveillance

By far, the largest category of current applications for 

UA, both military and civilian, is Sensor/Surveillance. 

The placement of a camera or other type of sensor on an 

aircraft has a great many uses. The types of applications 

vary widely in regard to the type of sensor employed, the 

level of detail required, and what is being surveilled.

Within the category of sensor/surveillance, we can 

distinguish between moving and stationary targets. 

We can also distinguish between the need for real-time 

download of data or the collection of information that 

can be analyzed later.

A few current sensor/surveillance applications include 

logging inspection, pipeline and power line inspection, 

border patrol, and crop analysis. Potential applications 

include those involving law enforcement, agriculture, 

construction, media, the petroleum industry and public 

utilities (James, 1994), as well as data collection for archaeologists, surveyors, and geologists (Aerospace Daily, 

1994). Other applications include monitoring wildfires, 

floods, and crops (Dino, 2003).
3

Payload Delivery

Payload delivery applications refer to the use of a UA to 

deliver a non-reusable payload. For military UA, this refers 

to ordnance delivery such as air-to-air or air-to-ground 

missiles. Civil applications of payload delivery would be 

crop dusting or fire fighting. Air-to-air refueling is also 

an example of payload delivery. For each of these applications, the payload is expendable and is not intended 

to return with the aircraft. This aspect distinguishes the 

payload delivery category from other categories.

Orbiting

Orbiting applications require that the aircraft maintain 

position at a particular location for reasons other than 

surveillance. At least three applications present themselves 

in this category. One is the use of UA at high altitudes 

to act as communication satellites. Telecommunications 

companies could use UA to relay signals for mobile phones, 

for example. Another application is the use of UA for 

advertising purposes; banner towing, for example. 

Transport

Transport applications refer to the carrying of goods 

and/or people from one location to another. Express 

mail delivery to small towns is one potential transport 

application (Aerospace Daily, 1994). For this category, 

the payload is not expendable and is expected to survive 

the flight intact. In addition, the payload is intended to 

be moved from one location to another, as opposed to 

those applications where the payload is returned to the 

point of origin.

Airspace Usage

It is important that we anticipate how these various 

applications will impact the airspace. Table 1 lists various types of UA applications, organized by the type of 

airspace that will be utilized. The airspace categories are 

listed (from top to bottom) in terms of the criticality of 

sense-and-avoid technology required to fly in that airspace. The term “transition” in the table refers to the fact 

that the aircraft might take off from a public use airport 

(Class B, C, or D airspace) and have to transit through 

this airspace before getting to the location where the focal 

activity will occur.

We have differentiated between two types of Class G 

airspace, depending on whether the area underlying that 

airspace is populated or not. Flight in Class G airspace 

sometimes originates from a public use airport, depending on the size of the aircraft or its ability to land and 

takeoff vertically or without a runway. These factors led 

to the differentiation of four separate categories that deal 

with Class G airspace. The category called “high altitude 

flight” refers to flight above FL430 (43,000 feet above 

mean sea level), which is still within Class A airspace but 

is rarely used by air carriers. Flight within Class E airspace 

was considered more critical than flight within Class A 

airspace in regard to the sense-and-avoid issue because 

Class A is positively controlled airspace and because equipage requirements for aircraft within Class A are more 

stringent than equipage requirements for Class E.

RTCA Scenarios

In an effort to gauge the types of applications and 

systems that are expected, a review was made of 63 

unmanned aircraft flight scenarios that were developed 

by members of RTCA Special Committee 203 on Unmanned Aircraft Systems. These scenarios are posted on 

their limited-access Web site.

The scenarios describe systems that range in weight 

from 200 grams up to 96,000 pounds. Many of the 

scenarios use existing military systems. Sometimes these 

scenarios are military in nature, but more often the 

scenarios involve civilian use of a military system. After 

Table 1. Listing of applications by airspace requirements. 

Airspace\Application Surveillance Payload Orbit Transport 

Class G only unpopulated RC apps, crop 

inspection 

Transition to Class G 

unpopulated 

Pipeline 

inspection 

Crop dusting 

Class G only populated Building fire 

inspection 

Transition to Class G 

populated 

Powerline 

inspection 

Advertisement 

Transition to high altitude 

flight 

Environmental 

imaging 

Pseudo satellite 

Transition to Class A Crop surveys Air refuel Cargo/people 

Transition to Class E Law enforcement Banner towing Cargo 
4

reviewing each of the scenarios, the following figures 

were constructed to categorize the types of applications 

proposed and the types of airspace that will be used. 

Figure 1 shows how the scenarios fall into the four basic 

types of applications described above.

As can be seen from Figure 1, most scenarios, 49 

(78%), fell into the Sensor/Surveillance category. The 

Orbiting category was a distant second, although it 

should be pointed out that test flights were placed into 

this category. The Transport applications included the 

delivery of mail and the transportation of donor organs. 

Finally, the Payload applications included two in-flight 

refueling scenarios and a military strike mission.

Figure 2 shows the breakdown of scenarios according to how they would use the airspace. Airspace usage 

categories are those referenced earlier. It should be noted 

that the numbers in Figures 1 and 2 add to greater than 

the number of scenarios because some of the suggested 

scenarios included more than one application and more 

than one type of airspace being used.

Figure 2 does not show two of the airspace usage 

categories because there were no scenarios associated 

with those categories. Those categories were transition to 

non-populated Class G airspace and transition to populated 

Class G airspace. That these categories were not included 

in the scenarios suggests that the types of 

systems expected to fly in Class G airspace 

would be able to take off and land without 

the need for a runway. All of the scenarios 

occurring within Class G airspace assumed that the aircraft would be launched 

and recovered within Class G airspace. 

Scenarios occurring within a military 

operational area (MOA) were classified 

as Class G airspace over a non-populated 

area. Scenarios occurring within Class G 

airspace over a populated area (G-pop in 

the figure) involved monitoring automobile traffic, transporting donor organs to 

hospitals, and police surveillance. It is 

interesting to note that the majority of 

scenarios used airspace in a manner that 

minimized the need for sense-and-avoid 

technologies. One conclusion that was 

evident from reviewing the RTCA scenarios is that a distinction can be made 

between systems that remain within the 

line-of-sight of the pilot and those that do 

not. This distinction could prove useful 

when it comes to specifying airworthiness 

and pilot classifications.

Summary of a Meeting on UA

Pilot Medical Requirements

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

Civil Aerospace Medical Institute (CAMI) in Oklahoma 

City, OK, of a diverse group of subject matter experts 

from industry, academia, the FAA, and the military to 

discuss UA pilot medical requirements. Table 2 lists the 

attendees and contact information.

Attendees included representatives of several groups 

currently working on the development of standards and 

guidelines for UA. There were representatives from the 

National Aeronautics and Space Administration (NASA) 

Access 5, the FAA, ASTM F38, RTCA SC-203, and SAEG10 at the meeting. In addition, Dr. Warren Silberman 

represented the FAA Aerospace Medical Certification 

Division in regard to the medical certification requirements.

Given that the meeting encompassed only a single day, 

an attempt was made to focus the discussion as much as 

possible by providing to the group a draft standard that 

was developed by the FAA Flight Standards Division 

(AFS-400). In particular, one paragraph from the draft 

UA standard (shown below) was reviewed and discussed 

extensively 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

5

10

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. 
5

6.14 Pilot/Observer Medical Standards. Pilots and 

observers must have in their possession a current third class 

(or higher) airman medical certificate that has been issued 

under 14CFR67. The provisions of 14CFR91.17 on alcohol and drugs apply to both UA pilots and observers.

Current pilot medical requirements are separated 

into three classes. Table 3 lists the requirements for each 

class.

The first topic discussed was whether the agency should 

create a new medical certification category for UA pilots 

or use an existing certification. The rapid consensus by 

the group was that the creation of a new certification 

would be prohibitive for a number of reasons related to 

the difficulty, expense, and time of initiating any new 

rulemaking activity.

The next topic addressed which existing medical 

certification(s) to use. Several suggestions were generated by the group, including the use of the Air Traffic 

Controller (ATC) medical certification and the use of an 

automobile driver’s license. Regarding the ATC medical 

certification, the argument presented was that the activity of a UA pilot was, in some ways, closer to that of an 

air traffic controller. However, it was pointed out that 

there was very little difference between the ATC medical 

requirements and the second-class medical certification 

requirements. The real question, then, could be reduced 

to whether or not a second-class medical was required.

The discussion regarding the use of an automobile 

driver’s license, as is done in Australia and in the United 

States for the Sport Pilot Certificate, centered on the 

idea of accountability and professionalism. Some of the 

group maintained that there was a need to instill at least 

a minimal level of accountability and professionalism 

upon UA pilots, and that the use of a driver’s license 

would not accomplish this goal. Others, however, suggested that the pilot certification process could be used 

to instill professionalism and accountability and that 

a stronger rationale, using medical reasons, should be 

established before discarding the use of a driver’s license 

for medical requirements.

As a follow-up to the meeting, Anthony Tvaryanas 

provided a useful summarization regarding the establishment of occupational medical standards. Basically, there 

are two separate reasons to establish medical standards for 

occupations. The first is predicated on the need within 

individual organizations to establish medical standards 

that comply with the Americans with Disabilities Act. 

The procedure includes an analysis of the job requirements (knowledge, skills, and abilities) for a particular 

position. Because the analysis is for each individual job, 

there is no generalizable medical standard. After the job 

requirements are established, the medical examiner, as 

described by Tvaryanas, “typically receives a list of the 

job essential tasks (stand for 2 hrs, lift 25 lbs, etc.). The 

examiner determines and reports whether the individual 

can or cannot perform the essential tasks outlined by the 

employer. If they cannot, the organization has a duty to 

attempt to accommodate the individual (redesign the job), 

unless it poses an undue burden on the organization, or 

the individual poses an undue hazard to the safety of self 

or others. This approach is fraught with the potential for 

litigation” (Tvaryanas, personal communication).

The second reason for establishing medical standards is 

to protect the public from occupations where public safety 

is potentially at risk, such as transportation (including air 

transport) and the nuclear industry. Medical standards 

for these occupations are not based on an analysis of 

the specific tasks but, instead, are focused on the risk of 

impairment or incapacitation due to the pathology of 

any preexisting medical conditions. These standards also 

usually stipulate provisions for drug and alcohol testing. 

The establishment of medical standards for unmanned 

Table 2. Attendee listing. 

Name Organization E-mail Phone 

Adams, Rich FAA AFS-430 rich.adams@faa.gov 202-385-4612 

Beringer, Dennis FAA/CAMI AAM-510 dennis.beringer@faa.gov 405-954-6828 

Berson, Barry Lockheed Martin/Access 5 barry.berson@lmco.com 661-572-7326 

Eischens, Woody MTSI/Access 5 weischens@mtsi-va.com 703-212-8870 

x133 

Goldfinger, Jeff Brandes Associates/ASTM 

F38

jgoldfinger@brandes-assoc.com 775-232-1276 

Johnson, Marca Access 5 marca@direcway.com 410-961-3149 

McCarley, Jason U of Illinois Institute of 

Aviation 

mccarley@uiuc.edu 217-244-8854 

Silberman, Warren FAA/CAMI AAM-300 warren.silberman@faa.gov 405-954-7653 

Swartz, Steve FAA AFS-430 steven.swartz@faa.gov 202-385-4574 

Tvaryanas, Anthony USAF (311 HSW/PE) anthony.tvaryanas@brooks.af.mil 210-536-4446 

Williams, Kevin FAA/CAMI AAM-510 kevin.williams@faa.gov 405-954-6843 
6

Table 3. Pilot medical certification standards. 

Certificate Class Pilot 

Type 

First-Class – Airline 

Transport 

Second-Class – 

Commercial 

Third-Class - Private 

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

without correction. 

20/40 or better in each 

eye separately, with or 

without 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 (Snellen 

equivalent), with or without correction at age 50 and 

over, 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, using 

both ears at 6 feet, with the back turned to the examiner or pass one of the 

audiometric tests. 

Audiology Audiometric speech discrimination test (Score at least 70% discrimination in 

one 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 expected 

to 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 & annually 

after 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 disqualifying 

unless there is established clinical evidence, satisfactory to the Federal Air 

Surgeon, of recovery, including sustained total abstinence from the 

substance(s) for not less than the preceding 2 yrs. A history of substance abuse 

within the preceding 2 yrs is disqualifying. Substance includes alcohol and 

other drugs (i.e., PCP, sedatives and hypnotics, anxiolytics, marijuana, 

cocaine, opiods, amphetamines, hallucinogens, and other psychoactive drugs 

or chemicals.) 

Disqualifying 

Conditions 

Note: Pilots with these 

conditions may still be 

eligible for “Special 

Issuance” of a medical 

certificate.

Examiner must disqualify if the applicant has a history of: (1) diabetes 

mellitus requiring hypoglycemic medications; (2) angina pectoris; (3) 

coronary heart disease that has been treated or, if untreated, that has been 

symptomatic of clinically significant; (4) myocardial infarction; (5) cardiac 

valve replacement; (6) permanent cardiac pacemaker; (7) heart replacement; 

(8) psychosis; (9) bipolar disease; (10) personality disorder that is severe 

enough to have repeatedly manifested itself by overt acts; (11) substance 

dependence; (12) substance abuse; (13) epilepsy; (14) disturbance of 

consciousness without satisfactory explanation of cause; and (15) transient 

loss of control of nervous system function(s) without satisfactory explanation 

of cause. 
7

aircraft pilots clearly falls under the second reason. Thus, 

the suggestion by Tvaryanas and others in the group 

(e.g., Eischens) was that it is important to identify the 

factors associated with the risk of pilot incapacitation for 

unmanned aircraft in deciding on the appropriate level of 

medical certification. In addition, it is important that we 

understand these factors as they relate to manned aircraft 

to obtain an objective assessment.

Ultimately, the primary driver of the decision of which 

certification level to use was the current perception of 

risk for these aircraft. One member of the group offered 

the following comment in regard to the definition of 

acceptable risk:

I think the core issue is defining acceptable public 

risk from UA operations and applications. This has 

historically driven (at least in part) the evolution of the 

current stratified pilot and medical certification systems 

for manned aviation. This cut-point (acceptable versus 

unacceptable risk) is not defined by the medical, scientific, 

or engineering communities, but rather by the policy 

community (e.g., our political/regulatory institutions). 

For example, the current ‘1% rule’ (derived from European civil aviation standards) for risk of incapacitation in 

commercial aviation is a policy threshold. It could just 

have easily been a ‘2% rule’ or a ‘5% rule.’ The point is 

that it is a completely arbitrary boundary. The function 

of the medical/scientific community is to then quantify 

an individual’s risk to determine whether they may exceed 

this arbitrary threshold. This is accomplished in part by 

setting certification standards. It is inherently futile for the 

medical and scientific communities to try to set standards 

without the policy community first defining ‘acceptable 

risk.’ I would urge the FAA to consider this core issue 

early, and then return to a discussion of standards setting. 

Once ‘acceptable public risk’ is defined, setting medical 

standards becomes more an academic exercise rather than 

a policy debate (A. Tvaryanas).

Regarding the risk of pilot incapacitation, at least a few 

factors distinguish this risk from manned aircraft. First, 

factors related to changes in air pressure can be ignored, 

assuming that control stations for non-military operations 

will always be on the ground. Second, it was pointed out 

by one participant that many of the current UA systems 

have procedures established for lost data link. Lost data 

link, where the pilot cannot transmit commands to the 

aircraft, is functionally equivalent to pilot incapacitation 

(Goldfinger, personal communication). For those systems 

with an adequate procedure for handling a lost data link, 

pilot incapacitation does not compromise safety to the 

same extent as it would in a manned aircraft. Third, the 

level of automation of a system determines the criticality of pilot incapacitation, since some highly automated 

systems (e.g., Global Hawk) will continue normal flight 

whether a pilot is present or not (Tvaryanas, personal 

communication).

In the end, it was decided that not enough was known 

about these aircraft to make an accurate assessment of all 

of the risks involved. Because of this, the decision was 

reached by the group that the original suggestion of a 

third-class medical certification was adequate, with use 

of the existing medical waiver process (also called “Authorization of Special Issuance”) for handling exceptions 

(e.g., paraplegics). This decision was also supported by the 

factors identified above that mitigate the severity of pilot 

incapacitation. However, there was additional discussion 

that some applications might require a second- or firstclass medical certification because of the increased risks 

involved. Imposing different certification requirements, 

though, would require a clearer specification of pilot certification levels and UA classes. The third-class medical 

certification statement was believed to apply to many, if 

not all, existing commercial and public UA endeavors (e.g., 

border patrol applications). The question then arose as 

to what types of pilot certification would require stricter 

medical certification. Because the document was viewed 

as sufficient for present needs, no wording changes were 

suggested for paragraph 6.14.

Since the meeting, the FAA Office of Aerospace Medicine has suggested that a second-class medical certification 

might be more appropriate for UA pilots. The main reasons for this recommendation are that some UA pilots are 

required to maintain visual contact with the aircraft and a 

third-class medical certification requires only 20/40 vision, 

with or without correction. On the other hand, secondclass medical certification requires 20/20 vision, with or 

without correction. A second reason for a second-class 

medical is that there are currently no commercial pilots 

that have less than a second-class medical. A replacement 

paragraph has been drafted that will change the medical 

certification requirement to second-class. The paragraph 

is as follows:

Pilot/Observer Medical Standards. Pilots and observers 

engaging in flight operations for compensation or hire who 

will, in the course of their duties, perform visual collision 

avoidance duties IAW1 paragraph 6.20 of this policy, must 

have in their possession a current Second-Class airman 

medical certificate that has been issued under 14 CFR 67, 

Medical Standards And Certification. Pilots and observers 

engaged in flight operations of other than a commercial 

nature will possess a current Class Three medical certification. The provisions of 14 CFR 91.17, Alcohol or Drugs, 

applies to both UA pilots and observers. The Department of 

Defense will establish guidelines for medical fitness that, in 

the judgment of the services, provides a similar standard.

1

 In accordance with (IAW)
8

Summary and Conclusions

The goal of the research was a recommendation of the 

medical requirements for UA pilots. The recommendation 

for the level of medical class for UA pilots was based on 

an analysis of the method for establishing the medical 

requirements of other occupations, including mannedaircraft pilots. Rather than suggesting the creation of a 

new medical class for UA pilots, the group decided to 

recommend an existing pilot medical certification. There 

were several reasons supporting this decision, including 

the difficulty of establishing a new certification level and 

the problems associated with training medical examiners 

that would be asked to assess whether UA pilots successfully met the new requirements.

Given that an existing medical certification was recommended, the question of which class of certification to 

propose was based on the perceived level of risk imposed 

by the potential incapacitation of the UA pilot. The original recommendation of a third-class medical certification 

was replaced with the implementation of a second-class 

medical in the standards. The decision was based on the 

idea that there were several factors that mitigated the risk 

of pilot incapacitation relative to those of manned aircraft. 

First, factors related to changes in air pressure could be 

ignored, assuming that control stations for non-military 

operations would always be on the ground. Second, many 

of the current UA systems have procedures that have 

been established for lost data link. Lost data link, where 

the pilot cannot transmit commands to the aircraft, is 

functionally equivalent to pilot incapacitation. Third, the 

level of automation of a system determines the criticality 

of pilot incapacitation because some highly automated 

systems (e.g., Global Hawk) will continue normal flight 

whether a pilot is or is not present.

Against these mitigating factors was the fact that most 

UA operations were anticipated to be public use, such as 

border patrol flights or commercial activities. Mannedaircraft pilots in these instances are required to have a 

second-class medical certification. In addition, there is 

very little difference between a second- and third-class 

medical certification. The major differences are the vision 

requirements (20/20 vs. 20/40 correctable) and how often 

they must be renewed.

Finally, the waiver process available to pilots provides 

that handicapped persons can still receive a medical 

certification. All that is required is a demonstration of 

their ability to pilot the aircraft effectively. This process 

gives individuals who might not be able to fly manned 

aircraft an opportunity to receive medical certification 

for flying an unmanned aircraft. However, issues with 

pilot airman certification must still be resolved before 

this can occur.

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A-1

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C. (2001). Identification of the cognitive, psychomotor, 

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navy.mil/articles/safeucav/.

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Englund, C.E. (1973). Principles of display and 

control design for remotely piloted vehicles. Decision 

Science, Inc. second semi-annual technical report 

on Contract #N00014-72-C-0196, Project # NR 

196-119/11-29-71 455.