P4HR Files Sweeping Petition for Rulemaking to Reform FAA Aeromedical Certification
Coalition asks FAA to replace opaque, indefinite, and discretionary aeromedical practices with transparent, evidence-based, time-limited, and reviewable federal standards.
Pilots for HIMS Reform, Inc. has formally filed a Petition for Rulemaking with the Federal Aviation Administration under 14 C.F.R. Part 11, asking the agency to undertake a comprehensive modernization of the rules governing HIMS monitoring, Special Issuance medical certification, substance-related and mental-health determinations, testing, independent review, and the pathway to unrestricted medical certification.
This is not another request for a meeting.
It is not a position paper.
And it is not simply a criticism of the existing HIMS system.
P4HR has now placed before the FAA a detailed regulatory proposal asking the agency to establish enforceable standards governing an aeromedical system that can profoundly affect a pilot's career, livelihood, medical privacy, professional reputation, and ability to return to unrestricted flight.
The Petition asks the FAA to replace a system too often dependent upon guidance, authorization letters, informal practices, individual discretion, closed professional networks, and requirements that can change during a pilot's participation with a regulatory structure based upon published standards, current individualized evidence, meaningful due process, independent clinical judgment, defined timelines, and an actual endpoint.
From Advocacy to Formal Rulemaking
For years, pilots navigating HIMS and the FAA medical-certification system have confronted a fundamental problem: many of the requirements capable of determining whether they fly, remain monitored, undergo additional testing, obtain another psychiatric or neuropsychological evaluation, advance through monitoring, or ever return to unrestricted certification do not appear in the Code of Federal Regulations.
P4HR believes that must change.
On August 19, P4HR formally invoked the federal rulemaking petition process and asked the FAA to put these protections where they belong: in enforceable rules.
The Petition proposes extensive regulatory language rather than merely asking the FAA to “study” the problem.
Among other reforms, P4HR asks the FAA to establish:
- An objective and enforceable pathway to fully unrestricted medical certification.
- Defined monitoring periods, presumptive completion points, mandatory step-down criteria, and protections against indefinite monitoring.
- A modern clinical framework separating a historical diagnosis from present aeromedical risk.
- Modernization of the FAA's substance-related diagnostic framework so regulatory terminology and certification decisions reflect contemporary clinical standards.
- Written reasons and current individualized evidence before monitoring can be extended, intensified, restarted, or moved backward.
- Meaningful independent medical review of disputed FAA decisions.
- Protections for pilots seeking second opinions or disagreeing in good faith with an FAA or evaluator conclusion.
- An end to compelled acceptance of disputed diagnoses, labels, identities, or program narratives as a condition of progression.
- Open, competency-based AME participation rather than an exclusive HIMS-AME gatekeeping structure.
- Equal access for airline pilots, general-aviation pilots, independent pilots, and others without employer or union sponsorship.
- Equivalent protections for other covered aviation professionals, including air traffic controllers where FAA medical-qualification systems operate under separate authority.
- Standardized professional education and public access to the materials clinicians need to understand FAA requirements.
- Strong privacy, record-access, conflict-of-interest, decisional-record, and anti-retaliation protections.
- Enforceable FAA decision deadlines and consequences for administrative delay.
- Public reporting sufficient to determine whether the reformed system is actually working.
But the Petition goes considerably further.
Drug and Alcohol Testing Must Meet Defensible Standards
P4HR is asking the FAA to reform one of the most consequential components of aeromedical monitoring: testing.
Where certification-related drug testing can result in grounding, increased monitoring, backward movement, denial, or another significant aeromedical consequence, the Petition calls for safeguards meeting or exceeding the relevant integrity protections reflected in Department of Transportation testing standards.
The proposal addresses collection integrity, chain of custody, laboratory methodology, confirmation, medical review where appropriate, records access, challenge procedures, reporting, and confidentiality.
It also addresses specialized non-DOT biomarkers—including EtG/EtS and PEth—and asks the FAA to disclose the scientific purpose, detection window, applicable threshold, known limitations, confirmation procedures, quality requirements, and permissible decisional use of such testing.
The Petition also proposes an important structural firewall for random testing.
Random testing would remain mandatory where properly required. But the entity generating the random selections should be genuinely independent from the people diagnosing, treating, monitoring, employing, representing, or adjudicating the individual.
Under P4HR's proposal, the participant would select an independent qualified testing administrator at the beginning of monitoring. That administrator—not the AME, treating clinician, employer, union, treatment program, or FAA decision-maker—would generate auditable random selections.
Results would be provided simultaneously to the participant and designated monitoring AME, with FAA transmission governed by the written monitoring plan and applicable law.
The purpose is not to weaken testing.
It is to make testing more credible, more defensible, and truly random.
The FAA Should Not Make Clinical Policy Behind Closed Doors
The Petition also addresses a concern increasingly raised by medical professionals themselves.
P4HR recently received a statement from a psychiatrist supportive of reform who described frustration with what the clinician viewed as clinical requirements being announced intermittently without meaningful public input and based upon the views of a very small internal FAA staff without adequate outside peer review.
The psychiatrist also expressed concern about the size of the FAA's psychiatric staff relative to what is presumably a substantial mental-health and substance-related aeromedical workload.
P4HR has deliberately not presented an unverified numerical estimate of FAA psychiatric staffing as fact.
But the larger issue does not depend upon any particular headcount.
What evidence is being used?
Who independently reviews it?
How large and appropriately specialized is the professional staff responsible for it?
What happens when qualified outside specialists disagree?
And how does a requirement become effectively mandatory?
Those are legitimate questions for a federal medical-certification system.
The Petition therefore asks for something far more durable than an argument over staffing numbers.
P4HR proposes that significant new or materially revised clinical requirements undergo independent, specialty-appropriate peer review by professionals who did not formulate the requirement.
The FAA would identify the evidence supporting the requirement.
Generally applicable substantive clinical standards would be published with meaningful opportunity for public input when practicable.
Material clinical requirements would carry version control, effective dates, supporting rationale, and an identifiable issuing authority.
And the FAA would publish de-identified information concerning its aeromedical clinical workforce and capacity, including relevant professional disciplines, staffing, vacancies, aggregate caseload measures, reliance upon contractors or outside consultants, and the peer-review mechanisms supporting significant clinical policy.
There would remain an exception for a genuine and immediate safety need.
But emergency authority should not become permanent policy by default.
No More Policy by Seminar
One of the Petition's most important transparency principles is also one of its simplest:
The same applies to a conference presentation, webinar, training deck, checklist, closed stakeholder meeting, or other informal communication.
P4HR's proposed framework requires substantive certification, testing, diagnosis, monitoring, evaluator, progression, and completion requirements to be traceable to statute, regulation, or publicly accessible guidance with an identifiable version and effective date.
Pilots should not have to attend the right conference, employ the right physician, belong to the right organization, or know the right person to discover the rules governing their medical certificates.
Neither should their doctors.
Medical Professionals Need Access to the Rules, Too
Reform cannot succeed if only the FAA and a small group of insiders understand the system.
P4HR therefore proposes recurring standardized education and openly available materials for AMEs, psychiatrists, psychologists, neuropsychologists, addiction specialists, treating physicians, FAA personnel, and other professionals whose opinions the agency requires or materially relies upon.
That education should include modern diagnostic standards, remission and recovery science, present-risk assessment, testing limitations, professional independence, procedural rights, conflicts of interest, and the critical distinction between making a diagnosis and determining present aeromedical risk.
Core curricula, templates, report standards, decision aids, evidence summaries, qualification requirements, and updates should be publicly available.
Medical professionals should not have to enter a closed network to understand what the federal government expects of them.
And qualified professionals should not fear exclusion merely because they disagree in good faith with the FAA.
A Diagnosis Cannot Become a Life Sentence
At the heart of the Petition is a fundamental distinction.
A historical medical diagnosis and a present aviation-safety risk are not necessarily the same thing.
P4HR is asking the FAA to recognize that distinction expressly.
A past diagnosis, prior treatment, previous Special Issuance, former HIMS participation, or generalized recurrence statistic should not, standing alone, establish that a pilot remains a present material aeromedical risk indefinitely.
The Petition instead calls for current, individualized evidence.
And once a pilot has satisfied published completion or advancement criteria, the burden should change.
P4HR proposes that continuing, restarting, or intensifying extraordinary conditions after successful completion require a written FAA determination supported by clear and convincing current individualized medical evidence.
Monitoring Cannot Be Indefinite
The Petition proposes defined monitoring limits, advancement criteria, credit for successfully completed monitoring, and protections against arbitrary resets.
Administrative delay should not restart the clock.
Changing AMEs should not restart the clock.
Changing employers or unions should not restart the clock.
Changing an authorization letter or program name should not restart the clock.
And the government should not be able to move the finish line simply because internal policy changed while an individual was already complying with an approved plan.
Where a new standard is more favorable, participants should receive its benefit.
Where it is more burdensome, applying it midstream should require a current individualized safety justification.
General Aviation Cannot Be an Afterthought
P4HR is a coalition representing people across aviation—not merely pilots fortunate enough to have access to a major-airline HIMS structure.
The Petition expressly addresses self-sponsored access.
A general-aviation pilot, independent pilot, small-operator pilot, unemployed pilot, furloughed pilot, or other covered individual should not receive a fundamentally different pathway simply because there is no airline or labor organization standing behind them.
A federal medical-certification system must ultimately be accessible on equal terms to the people the federal government regulates.
Reforming HIMS Does Not Mean Abandoning Safety
P4HR rejects the false choice between reform and aviation safety.
The coalition is not asking the FAA to stop identifying genuine medical risks.
It is not asking the agency to eliminate appropriate treatment.
It is not asking that pilots with current disqualifying conditions simply be returned to flight.
And it is not asking that legitimate monitoring or testing disappear.
P4HR is asking for something considerably more defensible:
A system possessing those characteristics should be safer—not less safe—because aviation professionals would have greater reason to seek help early, cooperate with a system they trust, and believe that entering treatment does not necessarily mean surrendering control of their careers indefinitely.
Congress and the FAA Have Different Jobs
The Part 11 Petition is deliberately coordinated with P4HR's broader legislative proposal, the Pilots for HIMS Reform Act of 2026.
The two initiatives are complementary.
The Petition asks the FAA to use the regulatory authority it already possesses to reform medical certification.
The proposed legislation addresses matters requiring or benefiting from congressional action—including broader independent oversight, statutory rights, institutional safeguards, enforcement mechanisms, and protections that cannot simply be created through FAA rulemaking.
P4HR does not believe reform should wait for one branch of government while another already possesses authority to act.
We are pursuing both.
The Petition Is Now Before the FAA
On August 19, 2026, the Petition was formally transmitted through Regulations.gov for FAA review under the Part 11 rulemaking process.
This filing marks a significant transition in P4HR's work.
We have met.
We have written.
We have requested dialogue.
We have documented experiences.
We have examined the governing rules.
We have listened to pilots and aviation professionals.
We have listened to clinicians.
And now we have proposed the rules we believe should replace the system we have been challenging.
The FAA does not have to agree with every word of our proposal.
But the issues are now squarely presented.
The questions are now being placed into the formal federal rulemaking process.
And the proposed solutions are no longer abstract.
Read the Petition and the P4HR Act
P4HR is publishing both documents so pilots, clinicians, policymakers, aviation organizations, and the public can review the complete reform framework for themselves.
FAA Part 11 Petition for Rulemaking
P4HR's formal regulatory petition submitted to the Federal Aviation Administration on August 19, 2026.
Pilots for HIMS Reform Act of 2026
P4HR's complementary legislative framework for reforms requiring or benefiting from congressional action.
Public-copy note: The version of the Petition published by P4HR may redact personal residential contact information. The substantive regulatory filing is otherwise reproduced for public review.
Read It. Challenge It. Participate.
We encourage pilots, air traffic controllers, AMEs, psychiatrists, psychologists, neuropsychologists, addiction specialists, physicians, treatment professionals, unions, operators, aviation organizations, policymakers, researchers, and other stakeholders to read the Petition and the proposed P4HR Act.
Critique them.
Discuss them.
Tell us where you agree.
Tell us where you disagree.
And, most importantly, participate when opportunities for formal public input arise.
This should not be a conversation conducted behind closed doors.
That is one of the reasons we filed the Petition in the first place.
Pilots for HIMS Reform, Inc.
Advocating for transparent, evidence-based, fair, and accountable aeromedical certification.