We are often asked how pilots can get a FAA medical with multiple CPAP machines. In order to obtain a special issuance authorization and FAA medical certification with a history of obstructive sleep apnea treated with CPAP, the FAA requires that pilots meet certain therapy goals. Specifically, in order to achieve and maintain certification, the FAA will expect a pilot to demonstrate an average CPAP usage on at least 75% sleep nights and an average of at least 6 hours of use per night. This data must come directly from a CPAP machine that records usage. What happens when you aren’t averaging those numbers on a single CPAP machine? Will the FAA say that you are not in compliance with their usage requirements?
Many pilots have more than one CPAP machine – one for home and one for travel. For example a pilot may have one machine at their home and another at a vacation property. The FAA requires all of your data, in its totality, in order to determine if you are meeting therapy goals. In other words, you need to account for 100% of your sleep nights, even if it is split across multiple machines. The FAA will consider the data in aggregate in order to determine whether your CPAP is effectively mitigating risk to aviation safety.
When using more than one CPAP device, consider the following:
- You should always report a history of obstructive sleep apnea and use of a CPAP or therapy on your application for airman medical certification. If you use multiple CPAP machines to treat your OSA, the FAA requests that you provide a note on your MedXPress (FAA Form 8500-8, application for airman medical certification) that you notate the number of machines used.
- You must generate compliance reports from each device you’ve used during the reporting period. Consider identifying for the FAA in a cover letter that you use two CPAP devices so that they understand why there are multiple compliance reports.
- If one of your CPAP machines does not track usage, it is important to produce evidence for the FAA which reassures the agency that you are otherwise hitting the required therapy goals. You should also have documentation from your treating physician which is supportive of your appropriate usage of the non-recording machine. You should generate a statement for the FAA estimating what you believe your usage to be on the non-recording device and when you used that device. Most importantly, you should consider investing in a secondary device which records usage. Using cloud-connected devices (like ResMed AirSense or DreamStation) that can sync to a central app or platform have proven to be helpful for pilots.
If you are having trouble deciphering how to satisfy the compliance protocols of your FAA medical with multiple CPAP machines, please contact The Ison Law Firm Aviation Lawyers to consult.
Contact the Aviation Lawyers from The Ison Law Firm Aviation Lawyers for Help Today
You need both a pilot and a lawyer on your side for your aviation law needs. Don’t hesitate to contact our team from The Ison Law Firm Aviation Lawyers to schedule a confidential consultation with an experienced aviation lawyer today.
We’re pilots representing pilots. The Ison Law Firm Aviation Lawyers offers FAA enforcement defense and medical certification representation worldwide.
Contact the Aviation Lawyers from The Ison Law Firm Aviation Lawyers for Help Today
You need both a pilot and a lawyer on your side for your aviation law needs. Don’t hesitate to contact our team from The Ison Law Firm Aviation Lawyers to schedule a confidential consultation with an experienced aviation lawyer today.
We’re pilots representing pilots. The Ison Law Firm Aviation Lawyers offers FAA enforcement defense and medical certification representation worldwide!
The Ison Law Firm Aviation Lawyers
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