Substance Use History & FAA Certification

The FAA medical standards in 14 CFR 67.107, 67.207, and 67.307 (first, second, and third class) use their own definitions of substance dependence and substance abuse. These are not the same as a clinical (DSM) diagnosis. Substance dependence means you are dependent on a substance (alcohol, sedatives, anxiolytics, opioids, stimulants, hallucinogens, cannabis, inhalants, or other psychoactive drugs, but not tobacco or caffeine), shown by any one of four signs: increased tolerance, withdrawal symptoms, impaired control of use, or continued use despite harm to your health or your social, personal, or work life. Dependence is disqualifying unless the Federal Air Surgeon is satisfied that you have recovered, including sustained total abstinence for at least the preceding 2 years. Substance abuse within the preceding 2 years is also disqualifying. It covers any of three situations: using a substance where it was physically hazardous (such as driving) on more than one occasion; a verified positive drug test, an alcohol test of 0.04 or higher, or a refusal to test under a U.S. Department of Transportation (DOT) program; or misuse that the Federal Air Surgeon finds makes you unsafe to fly. If you don't meet these standards, you can ask the FAA for a Special Issuance under 14 CFR 67.401.

You must report every drug or alcohol event on each FAA Form 8500-8 (MedXPress), no matter how long ago it happened. That includes arrests, convictions, and administrative actions, such as an education program in place of a conviction or a DUI arrest reduced to reckless driving. Once the FAA has reviewed an event, you keep answering "yes" on every later application, but you can write "PREVIOUSLY REPORTED, NO CHANGE" if nothing new has happened. Reporting to the FAA medical side is separate from a legal duty under 14 CFR 61.15(e). Within 60 days of any alcohol- or drug-related motor vehicle action (a conviction, or a license suspension, revocation, cancellation, or denial), you must send a written report to the FAA Security and Investigations Division (AXE-700), P.O. Box 25810, Oklahoma City, OK 73125-0810. Telling your AME or listing it on MedXPress does not count as that report. If you don't report, that alone can lead to denial, suspension, or revocation of your certificates. A second motor vehicle action within 3 years of a previous one is also grounds for denial, suspension, or revocation.

For a DUI/DWI or other alcohol event, your AME follows the FAA's disposition table. If you had a single event 5 or more years ago with a blood alcohol content (BAC) below 0.15 and the AME finds no sign of a substance problem, the AME may issue your certificate and send your personal statement to the FAA. If the single event was less than 5 years ago, your BAC was 0.15 or higher, or the BAC is unknown or you refused testing, the AME completes an Alcohol Event Status Report and sends it to the FAA. The AME must defer if any item on that report raises a concern, or if the records aren't available. Two or more alcohol events in your lifetime, or any history of dependence, means the AME must defer and the FAA decides. Any drug use (illicit or prescription misuse, including marijuana even where state law allows it) that the FAA has not already cleared is also deferred for FAA review. The FAA may then ask for a substance abuse evaluation. Its letter tells you which type of evaluator you need, which can range from a substance abuse professional up to a HIMS psychiatrist.

If you need monitoring, you work with a HIMS-trained AME: an AME with extra FAA training in evaluating substance-related conditions. HIMS AMEs monitor airline pilots and pilots who fly for non-HIMS carriers or for fun. The initial package includes a face-to-face HIMS AME evaluation, your treatment records, a psychiatrist evaluation, and a separate neuropsychological evaluation with CogScreen-AE by a neuropsychologist on the FAA's list. First- and second-class commercial pilots need a HIMS-trained psychiatrist in most cases; most others need a board-certified psychiatrist. After a Special Issuance, you follow the HIMS Step Down Plan. It has four phases: Initial (year 1, beginning with your Special Issuance), Early (years 2–4), Advanced (years 5–7), and Maintenance (year 8 and beyond). Monitoring starts with random testing of at least 14 screens in 12 months (or Soberlink) and decreases as you progress. The FAA requires permanent abstinence from mind- and mood-altering substances for your entire flying career. If you relapse, do not fly (14 CFR 61.53); your Time-in-Phase resets to the date of any new Special Issuance.