NBAA Supports New Rule Providing Relief from Medical Certificate Requirements for Check Pilots, Flight Instructors

July 1, 2024

Part 135 operators may soon find obtaining check pilot and flight instructor services easier, thanks to a final rule recently published by the FAA.

The final rule, Removal of Check Pilot Medical Certificate Requirement, removes inconsistencies in qualification requirements for check pilots so they may continue to perform functions in aircraft without a medical certificate unless they are serving as required flightcrew members. The rule similarly removes the medical certificate requirement for flight instructors in Part 135 commuter and on-demand operations who perform their functions in aircraft and are not serving as required flightcrew members.

The rule goes into effect July 18.

“This final rule will be well-received by the industry after years of challenges related to availability of check pilots,” said Melanie Hight Viau, charter captain and Part 135 training instructor at OpenAir.

Viau also explained that by revising these medical certificate requirements, pilots who have years of experience flying, but who are unable to maintain a medical certificate, can continue to add value for Part 135 operators while not serving as a required crewmember.

“This grants a little bit of relief for operators who want to continue involving experienced pilots who still want to participate in the industry,” said Viau. “There’s a lot to be said for sharing that valuable experience.”

Previously, requirements for flight instructors and check pilots in Parts 121 and 135 were unclear, stating these pilots must hold a third-class medical certificate when not serving as a required flightcrew member; elsewhere, however, regulations stated no medical certificate is required unless the flight instructor or check pilot is serving as a required flightcrew member.

Also, Part 135 check pilots conducting checks in an aircraft were held to different medical certification standards than Part 121 check pilots and flight instructors and Part 135 flight instructors.

This new rule clarifies flight instructors and check pilots must hold an appropriate medical certificate only when serving as required flightcrew members in an aircraft.