Shared Responsibility in the HIMS Program
The FAA, ALPA, and HIMS AMEs operate together in a system that harms pilots. This matrix shows how they jointly contribute to the abuse.
| Entity | Role in HIMS | Potential Liability | Legal/Policy Concern |
|---|---|---|---|
| FAA | Creates and enforces HIMS policy; issues Special Issuances and SIs | Overreach / denial of due process Delegation of authority without oversight Compelled religious elements |
Administrative law Constitutional law |
| ALPA | FAA-funded to manage HIMS ops; trains AMEs and company reps; oversees pilots | Conflict of interest (union vs. enforcer) Discriminatory gatekeeping Suppression of dissent |
Labor law Civil rights |
| HIMS AMEs | Evaluate pilots and report to FAA; often chosen by airlines or ALPA | Biased reporting Coercive testing protocols Arbitrary medical judgments |
Medical ethics Professional liability |
These actors function in a closed system where transparency is minimal and pilot rights are often disregarded. This is not a neutral oversight program—it's institutionalized harm.