So? When the FAA proposed ADS-B in this NPRM, the FAA had no obligation to educate the public about electronics and radio communication standards either, but they were obligated to publish the relevant technical standards so those members of the public who were trained in the appropriate fields could provide feedback. The ADS-B NPRM referenced a highly technical document over 1000 pages that any idiot could have tried reading and commenting on during the comment period. Sure, you could look it over and say "Dammit Jim, I'm a doctor, not a radio communications engineer!" but the NPRM process would have allowed you to seek help from an expert who wasn't on the payroll of the FAA so you could understand it and then comment on it intelligently!
Also, with ADS-B the FAA was required to issue an Initial Regulatory Flexibility Analysis (guide here) like this revised one for ADS-B that attempts to quantify the affect any proposed rule change has on the economics of small entities.
There may be an informal feedback mechanism to aeromedical, but is there any formal mechanism equivalent to the NPRM process? My complaint is that there doesn't appear to be one, but changes to medical standards sure by god do impact the common airman since they have all the force of regulations.
(The MMPI test and its variants is rather famous, or infamous, even to people like me who otherwise had no interest in such things.)
As to the two spec sheets - neither one contains any quantified (or other) justification for the risk assessment claim made at the very top of each:
- "Mental disorders, as well as the medications used for treatment, may produce symptoms or behavior that would make an airman unsafe to perform pilot duties."
- "Attention-Deficit/Hyperactivity Disorder (ADHD), formerly Attention Deficit Disorder (ADD), and medications used for treatment may produce cognitive deficits that would make an airman unsafe to perform pilot duties."
For example - based on what you haven't said, it seems there is currently no legal mechanism stopping aeromedical from suddenly and unilaterally making the ingestion of any amount of Ibuprofen cause for grounding unless one gets a SI - and their spec sheet and justification could be as simple as this:
- "Taking Ibuprofen may produce an increase risk of heart attack that would make an airman unsafe to perform pilot duties."
Without public disclosure of how they quantified that risk and what level of risk they were using as a threshold for enactment of that regulation-by-medical-proxy, they could (and probably have) created lame-brain special issuance criteria.
Your attacks on our lack of medical expertise is absolutely irrelevant - all I want is for aeromedical to publish its justifications and determination criteria for public critique. (For example, the main reference in those two specs is a book that wont be published for another 3 months!) Pilots like me don't need medical expertise so long as we know where we can borrow or hire it (so we can respond and hopefully change the what aeromedical decides.) There are doctors who are also pilots who have the needed expertise that affected pilots could hire as experts, who then could intelligently contest aeromedical's decisions during the justification and spec writing phase if only aeromedical could be made to follow modern regulatory practice. All the evidence shown so far indicates they operate carte blanche.
