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Why did the FAA issue a new sleep apnea policy?

On March 2, the FAA published its latest guidelines on obstructive sleep apnea (OSA). I wanted to provide some additional background on the new policy to help pilots understand why the new guidelines were issued. 

Several years ago, the National Transportation Safety Board issued a safety finding on flight crew fatigue following investigations of several aircraft accidents. Although the focus was primarily on making changes to rules for crew rest, sleep apnea was rolled into the fatigue discussion. I was aware of one of the accidents involving a helicopter. The pilot, the only occupant on board, had sleep apnea and the crash occurred on a VFR day. The NTSB physician noticed that the pilot’s sleep physician had misinterpreted the results of the Maintenance of Wakefulness Test that the FAA was using at that time as a requirement to support special issuance recertification. As part of the safety finding, the FAA several years ago began including training lectures on sleep apnea at all AME recertification seminars. The Aerospace Medical Certification Division also tightened up their special issuance requirements for someone with sleep apnea.   

The literature says that 2 to 4 percent of the population has sleep apnea. People who have this condition will complain of daytime sleepiness, loud snoring, and can have witnessed breathing interruptions or awakening secondary to gasping or choking. People who are obese, have an upper jaw that is receded (called retrognathia), and high blood pressure have an increased incidence of sleep apnea. People with the following conditions have been noted to have an increased incidence of sleep apnea. 

  1. Obesity with BMI (body mass index) >35
  2. Congestive heart failure
  3. Atrial fibrillation
  4. Poorly controlled high blood pressure
  5. Type II diabetes mellitus
  6. Nocturnal irregular heart rhythms
  7. Stroke
  8. Pulmonary high blood pressure
  9. High-risk type driving
  10. Preoperative for bariatric surgery

If a physician suspects a patient may have sleep apnea, the usual procedure is to order a polysomnogram or sleep study.  This is a monitored test performed in a sleep laboratory. If the technician feels the study will be positive, they will place a mask on the patient’s face that delivers air in a positive pressure fashion to determine at what level of pressure will open the airway enough to reduce the likelihood of obstruction. There are several different ways the air can be delivered, but the most common is called continuous positive airway pressure (CPAP). Some patients are intolerant of the mask, so there are many differing types of masks that can be custom fitted for the most comfort. The newer CPAP devices are portable and today have a smart card that monitors the usage days and length of time the machine is in use. The data can be downloaded and presented in hard copy report form to demonstrate utilization and compliance. The FAA prefers to see that an airman is using CPAP 75 percent of the nights and an average of six hours each night.  

For more information on the new guidelines, please see the FAA's guidance chart.

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