The current standards for FAA medical certification and testosterone replacement therapy (“TRT”) have allowed for many airmen to continue flying while undergoing treatment for low testosterone. TRT is commonly utilized for the treatment of hypogonadism. Fortunately, hypogonadism is not a specifically disqualifying condition for FAA medical certification under the Federal Aviation Regulations. Instead, hypogonadism is a “catch-all” condition considered under 14 C.F.R.§§ 67.113(b), 67.213(b), and 67.313(b), wherein the applicant must establish that there is no history of any organic, functional, or structural disease, defect, or limitation that would make them unable to safely exercise the privileges of their respective airman certificate. When it comes to hypogonadism, the FAA looks at the risk to aviation safety caused by any associated fatigue, sleep disturbances, anxiety, depression, and more.
Most testosterone replacement therapy is not disqualifying for FAA medical certification. However, applicants for FAA medical certification need to be careful as not all forms of testosterone are approved for issuance of a medical certificate. The same regulation relevant to hypogonadism, 14 C.F.R.§§ 67.113(c), 67.213(c), and 67.313(c), identifies that an applicant should have no medication or other treatment that the Federal Air Surgeon, based on the case history and appropriate, qualified medical judgment relating to the medication or other treatment involved, finds would make them unable to safely exercise the privileges of their respective airman certificate. As a result, if you are using a form of TRT which the Federal Air Surgeon finds aeromedically unacceptable, the FAA could deny your application for medical certification based purely on the type of TRT you are using. Some of the medications commonly approved by the FAA for TRT on a case-by-case basis included Anastrozole and Clomiphene. Some medications not currently approved by the FAA for testosterone deficiency include, but are not limited to Enclomiphene, Nandrolone, and biocompound testosterone pellets. Whether your medication is approved or not, the FAA and your Aviation Medical Examiner will still wish to assess whether your medication is causing any aeromedically significant side effects.
If you are applying for FAA medical certification while on testosterone replacement therapy, consider the following items first:
- You will need to report the underlying medical conditions on your application for FAA medical certificate. Furthermore, you need to report your TRT at question 17a., relative to your current use of medications.
- Prior to submitting an application for FAA medical certification through your Aviation Medical Examiner, it would be prudent to obtain a record from your treating physician identifying the status of your underlying condition, as well as the effectiveness of your TRT. Furthermore, your treating physician should identify whether you are experiencing any side effects from your TRT.
- You should confirm that the TRT you utilize to treat low testosterone is approved for FAA medical certification purposes.
- The FAA will require that you report any changes in side effects or symptoms your Aviation Medical Examiner.
Why involve a FAA attorney with your FAA medical certificate and testosterone replacement therapy? As you can tell from the above regulation, the medical certification process is more so a legal process than a medical process. Ensuring that your doctor is developing the proper documentation regarding your TRT, as needed, can be a difficult task. To that end, everything that is submitted to the FAA (i.e. records, statements, evaluations, etc.) goes into your airman medical file. This file is what the FAA then utilizes to evaluate whether you are eligible to hold a medical certificate, despite your TRT. If you are later denied and wish to appeal that denial, your airman medical file becomes “Exhibit A” before the NTSB or upon reconsideration by the Federal Air Surgeon. So, a FAA attorney can evaluate your records, prepare a plan for best presentation of your case to the AME or FAA, and best argue your medical eligibility to the Federal Air Surgeon, with an eye for potential, future appeal. Furthermore, if your medical documentation is as strong as possible upon initial submission, in doing so, hopefully, you will avoid unnecessary delay. Also, if you have failed to report your TRT on your FAA medical application, a FAA medical attorney can give you counsel on how to rectify your omission.
If you are concerned about your FAA medical and TRT, call the FAA attorneys at The Ison Law Firm. We are happy to evaluate your case and discuss with you a plan for presenting your case to your AME or the FAA. Aviation law is all we do. Nothing else.
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