FAA color vision standards can be quite confusing for airmen trying to get an airman medical certificate. If an airman does not meet the FAA color vision standards, the airman’s medical certificate may not be valid for night flying or operation by color signal control. Having an airman medical certificate restricted to not being valid for night flying or operation by color signal control can impede your ambition to operate as a commercial pilot or may significantly limit the operational freedom of your flying for recreational purposes. Knowing how to navigate the FAA’s maze of color vision standards is critical to avoiding unnecessary restrictions on your FAA medical certificate.
Preparation for avoiding, if possible, a color vision restriction on your FAA medical certificate starts well before your exam with an AME. Specifically, if you find yourself at an exam with an AME and are unaware of the nuance regarding the FAA color vision standards, it may be too late to avoid limitations on your flying abilities.
When you apply for a first-, second-, or third-class medical certificate, your AME is required to examine your color vision. Upon examination by your AME, he or she is required to administer one of a series of color vision instruments. There are certain tests that are unacceptable to the FAA for color vision testing, which include the OPTEC 5000 Vision Tester (color vision portion), “Farnsworth Lantern Flashlight,” “yarn tests,” and AME-administered aviation Signal Light Gun test. If you fail the test that is administered by your AME, you can request to take an alternative test, so long as it is a test which is approved by the FAA. If you have failed all of the tests administered by the AME and have run out of options for testing, your AME will issue you a medical certificate, if you are otherwise qualified, with a limitation stating: “not valid for night flying or by color vision signal control.”
What can you do if you fail the color vision tests in your AME’s office? If you do not meet the FAA color vision standards in your AME’s office, your next step may be to attempt the Operational Color Vision Test (“OCVT”). If you successfully complete the OCVT, the FAA will issue to you a Letter of Evidence, which, in turn will remove the color vision limitation on your airman medical certificate. The specifications of the OCVT vary based upon the class medical certificate which you apply. The nuances based on class certificate are as follows:
OCVT for Third-Class Medical Certificate:
If you are attempting to take the OCVT for a third-class medical certificate, testing will be administered at your local Flight Standards District Office (“FSDO”). You can expect the testing to include:
- Signal Light Test (during the day). In this test, an airman is required to identify aviation red, green, and white via light gun signal, at a specified distance, within a timely manner. Note that if you fail this portion of the OCVT, you will be allowed to retest at night. If you pass the test at night, your medical certificate will require a restriction which reads: “not valid for flight during daylight hours by color signal.”
- Aeronautical Chart Reading. In this test, an airman is required to read and correctly evaluate an aeronautical chart within a timely manner. This test should be approached with caution as the chart being used by the FSDO will include various colors of conventional markings and terrain, typefaces, and font size. It has also been the experience of our firm that the quality of the chart being used varies from FSDO to FSDO.
OCVT for First- and Second-Class Medical Certificates:
If you are attempting to take the OCVT for a first- or second-class medical certificate, you will be expected to complete the same testing required for a third-class medical certificate. In addition to this testing, you will be required to undergo a Medical Flight Test at a Flight Standards District Office (“FSDO”). You can expect a Medical Flight Test to include in-flight testing with evaluation of the following:
- Ability to read and correctly interpret instruments and displays in a timely manner;
- Ability to recognize terrain and obstructions in a timely manner; and,
- Ability to visually identify the location, color, and significance of aeronautical lights (including other aircraft, runway lights, etc.) in a timely manner.
The good news? If you pass the OCVT, you will be granted a Letter of Evidence for third-class privileges only. If you pass the OCVT and medical flight test, you will be issued a Letter of Evidence for all classes of FAA medical certification.
The bad news? You can only take the OCVT once (one time during the day and if you fail, one time at night). If you fail the OCVT during the day, you will not be permitted to upgrade to a first- or second-class medical Letter of Eligibility. If you fail the Medical Flight Test, you will not be permitted to upgrade to a first- or second-class medical Letter of Eligibility. You have one chance to be successful with these tests.
As noted above, it is prudent to consider your color vision well in advance of your visit to the AME. You do not want to be put in the position of finding out you are color vision deficient while you are sitting in your AME’s office. As such, keep the following in mind when it comes to FAA color vision standards (not legal advice, as every case is different):
- Establish a general understanding of your color vision status before you see an AME. If you know or have reason to know you may be color vision deficient, be prepared for your visit with an AME.
- Investigate which AME you plan to visit. You need to know which color vision instrument your AME administers in his or her office. If you know that your color vision may be stronger with one instrument over the other, make sure your AME administers that test.
- Take every opportunity to repeat the color vision instruments offered by your AME, if you fail the first time.
- Be considerate when selecting the FSDO where you perform your OCVT and/or Medical Flight Test. If your FSDO has a reputation for deficient procedures in administering the OCVT and/or Medical Flight Test, consider going to a different FSDO.
- When preparing for the OCVT, find an old sectional chart and have a friend quiz you on your performance before going to the FSDO.
- Practice, practice, and practice some more, with your Certified Flight Instructor or other licensed pilot before completing a Medical Flight Test. There is no reason to show up for your Medical Flight Test with no knowledge of how you will perform in-flight.
- Pay careful attention to any discrepancies with how either an OCVT or Medical Flight Test is administered by the FSDO. If the FSDO does not administer your OCVT or Medical Flight Test within appropriate, published procedures, you may be able to request that the Office of Aerospace Medicine authorize retesting of either the OCVT or Medical Flight Test (despite the one time per test rule).
For more information on this topic, check out our episode of The Pilot Lawyer Podcast regarding FAA color vision standards.
Preparation of your application for airman medical certification by an aviation law firm, such as The Ison Law Firm, can help prevent the dreaded limitations which come along with color vision issues. If you know or have reason to know of a potential color deficiency, there is reason to strategize on the best path forward for ensuring that you can effectively and legitimately avoid the need for a night flying or color signal restriction. In the alternative, if you already have such a restriction, consultation with a FAA medical defense attorney can determine if you have a path toward having the restriction removed.
If you are concerned about obtaining your FAA medical certificate free of limitation due to the FAA color vision standards, 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.