As of 2011 according to the American Diabetes Association, approximately 25.8 million in U.S. have diabetes mellitus (8.3% of the adult population). The incidence is increasing rapidly. Not only is diabetes a costly condition estimated at $245 billion per year, but it is a leading risk factor in many other diseases that adversely affect pilot’s career such as heart disease, stroke, vision, kidney disease, claudication, impotence and neurologic disease. Fortunately, the condition is treatable, and in most cases, pilots may be granted authorization for all classes of airman and ATCS medical certification.
Diabetes Mellitus- A Mixed Disease
Diabetes is not a single disease, but a mix of causes that have a common end result of blood glucose (sugar) levels elevated above normal. Two broad types of diabetes exist, Type I and Type II. Two other types of diabetes include Gestational (pregnancy-related) diabetes and diabetes due to other diseases and conditions.
Diabetes mellitus that is prone to causing comas due to severely elevated blood glucose, and which requires insulin for control, is termed Type I diabetes mellitus or immune-mediated diabetes . Formerly known as insulin requiring diabetes, it is the most life threatening form of the disease and may be diagnosed at any age. The body’s ability to produce its own insulin from the pancreas is destroyed in this condition. To survive, Type I diabetics require one or more shots of insulin daily.
Type II diabetes mellitus is much less prone to comatose states and frequently can be controlled without the use of insulin. It was previously known as non-insulin dependent diabetes mellitus (even though insulin was sometimes used for enhanced control). Oral medication (pills) and lifestyle changes in diet and exercise are usually adequate to control Type II diabetes .
Both types of diabetes mellitus are serious conditions that require careful monitoring and treatment to slow or prevent the numerous complications of each. The FAA treats the two types of diabetes mellitus quite differently because of the relative differences in range of blood sugars and possible effect on alertness and consciousness.
Blood sugar is maintained as relatively constant levels in a fine balance by diet input, the body’s production of insulin, its resistance to insulin and stores of carbohydrates. The normal peaks and valleys of blood sugar are dampened by the blunting effect of insulin and the enhancing effect of adrenal hormones.
With diabetes, there is an absence of the blunting effect and blood sugars may rise unchecked. In response to rising blood sugar through the dietary absorption of all foods, but sugars or carbohydrates (CHOs) in particular, the pancreas releases insulin to move CHO from the blood into the liver. In the liver, the simple CHOs are stored in a more complex form caused glycogen.
If the blood sugar drops due to missing meals or from extra consumption of sugar due to exercise, the adrenal glands above the kidneys release chemicals which trigger the release of glycogen from the liver and its conversion to glucose. This is a safety valve to prevent blood sugar from dropping too low. Low blood sugar results in impaired concentration, unconsciousness or even death. An individual feels this dropping blood glucose as anxiety, tremors, hunger, thirst, and confusion.
Certain medications, beta-blockers, may mask these symptoms of hypoglycemia and place an individual at risk for undetected hypoglycemia. The concurrent use of these medications with diabetes mellitus should be done with caution and though now acceptable, adverse reaction may adversely affects FAA certification decisions in diabetics.
Type I diabetes mellitus results from an absolute deficiency of insulin production from the pancreas. Type II diabetes mellitus may be from a relative deficiency in insulin production, the body’s resistance to insulin or increased production of glycogen from the liver and its conversion to glucose. Type II diabetes mellitus is more prone to occur in overweight individuals.
Symptoms of Diabetes
Many people with diabetes do not know they have the condition. Diabetes may be discovered on a routine FAA medical examination when the urine is tested for sugar. Often, a routine blood test during a periodic health exam finds elevated levels of glucose (sugar) in the blood. Symptoms may vary widely. People may notice increased thirst, frequent urination, unexplained weight loss, fatigue or infections. Rarely, diabetes first shows itself as unconsciousness or coma. This indicates very serious disease.
Diseases of the Small Vessels
Diabetes affects the body by damaging blood vessels, in particular very small blood vessels. The result is progressive and accelerated narrowing of the vessels and impairing the function of organs. The kidneys may gradually fail and manifest the failure by high blood pressure, and the leaking of glucose and protein in the urine (checked for in all FAA medical exams).
The nervous system initially manifests the damage as a loss of feeling, including temperature, touch and vibration, in the feet and hands. The circulation in the extremities is also impaired and an individual may note coolness of the feet, pale color or non-healing ulcers. Men, especially smokers, may note impotence with impaired circulation and nerve function in the penis. Diabetes is the leading cause of blindness in the U.S., which is caused by leaking of blood from the retina in the eye.
Diseases of the Larger Vessels
Diabetics have accelerated development of diseases of the larger vessels, which can cause sudden death. Coronary heart disease is the cause of death in over 50% of Type II diabetics versus approximately 30% in non-diabetics. Strokes are 2-4 times more likely, as is heart disease, in diabetics as the non-diabetic population. Peripheral vascular disease, which causes leg cramping with exercise contributes to non-healing ulcers of the feet and may even result in amputation, is four times more likely in diabetics.
Control of blood sugar levels may substantially reduce both the small and large vessel complications of diabetes. FAA medical certification of diabetic pilots is more likely if control of diabetes mellitus is achieved before the development of any of these complications.
High Risk Groups for Diabetes Mellitus
The cause of Type I diabetes mellitus is unknown. There may be ethnic and genetic risk factors. Infectious causes have also been postulated, but not proven. Type I diabetes mellitus may declare itself at any age, often in dramatic fashion with mental confusion or coma. Type II diabetes mellitus usually presents in adulthood and often goes undetected until discovered during a routine physical examination or laboratory testing for other reasons (such as FAA periodic exams). Several non-white ethnic groups are at increased risk over whites.
Characteristics associated with Type II diabetes mellitus include obesity, increasing age, physical inactivity and women with previous diabetes in pregnancy. Smokers with diabetes have a tremendous increase in the risk of diabetic complications.
Diagnostic Criteria for Diabetes Mellitus
The American Diabetic Association and medical authorities revised the standards for diabetes mellitus and a “borderline” condition known as Impaired Glucose Tolerance (IGT). Three values are generally measured in diabetics.
The fasting blood sugar is a value determined after not eating or drinking anything but water for approximately 8-12 hours prior to testing. A normal value is less that 100 mg/dL. People with IGT have values ranging from 100 mg/dL to 125 mg/dL, while individuals with fasting glucose values 126 mg/dL or greater confirmed with a second separate sample meet the criteria for diabetes mellitus.
The 2-hour glucose is measured 2 hours after drinking a glucose solution given as part of a glucose tolerance test. This test is not usually required to make the diagnosis of diabetes. A “casual” or “random” blood glucose is measured without a pre-test fast. Values over 200 mg% meet a criterion for diabetes mellitus. Blood sugar levels between 140-200 mg% represent IGT, while normal individuals will have levels below 140 mg%.
IGT, also known as Impaired Fasting Glucose (IFG) and “pre-diabetes”, is a condition that is a risk factor for later development of diabetes. People with fasting levels ranging from 100 to 125 mg/dL have pre-diabetes.
A third value commonly measured is the glycosylated hemoglobin or hemoglobin A1C. This test is not a direct increase of blood sugar but gives a picture of the general range of glucose over the previous 3-4 months. A normal individual will have less than 7% of their hemoglobin with glucose molecules attached. Diabetics tend to have 7% or more of their hemoglobin with glucose molecules attached though the FAA uses any Hgb A1C of 6.5% or greater as a definition of Diabetes. Hgb A1C values vary significantly from laboratory to laboratory. Changes in Hgb A1C occur slowly over weeks to months and are only useful in trend analysis of diabetes management. The diagnosis of diabetes is not made by Hgb A1C levels, but elevated levels are suggestive of the diagnosis. Newer tests, such as serum frucosamine, may be more useful as a short term glucose trend analysis and a management tool.
Treatment of Diabetes
The control of blood sugar and management of diabetes is accomplished through several strategies, often used in combination. One strategy is using diet and exercise to control weight and glucose levels in Type II diabetics. Additional control is achieved through several types of medication to lower blood sugar. Type I diabetics and those Type II diabetics unable to maintain adequate control with the above strategies require the use of insulin. Insulin is given daily or more frequently by injection, as no oral form is available.
Weight Control- Diet and Exercise
Over three quarters of Type II diabetics are overweight. By restricting dietary caloric intake, many people with IGT or Type II diabetes mellitus may obtain adequate control of their weight and blood sugar. Weight loss may dramatically increase life expectancy in diabetics and increase the effectiveness of oral medication, if required. For an individual to reap the benefits of weight loss, the loss must be sustained. The American Diabetes Association has listed the food values of many types of food servings. Calories and nutrient value are listed on all manufactured food labels, frequently with ADA ratings for ease in calculation of dietary plans. A nutritionist is particularly useful in educating newly diagnosed diabetics with menu planning for weight reduction. Frequently, the ADA cookbook is used for a wide variety of recipes.
An exercise program is a valuable compliment to dietary planning for weight reduction and blood sugar control. Exercise is potentially effective in lowering blood glucose for up to half a day. The benefits of aerobic exercise may yield improvements in coronary heart disease and peripheral vascular disease. Because of the increased risk of heart disease, a diabetic should consult with their personal physician before initiating a program. Diet and exercise must be balanced, as each effects glucose levels, particularly for those on medications.
In 2023 the FAA issued new guidelines to also allow use of certain diabetes medications as part of a CACI – Weight Management Program. As of Sep 2023 the AME was authorized to clear single medication use of either metformin, liraglutide, or semaglutide after a 2- week successful ground trial. An over the counter weight loss aid, Orlistat, is allowed after a 48 hour ground trial. Please consult with an AMAS physician regarding specific details of the program as it currently stands.
Oral Medications for Diabetics- Pills
Type II diabetics who cannot achieve or sustain adequate blood sugar control with diet and exercise will usually benefit from oral medication. If blood sugar levels are not severely elevated, many physicians will recommend a several month trial of diet and exercise before starting medication. There are several types of oral medication are currently available. Several types are waiverable by the FAA after proper evaluation. Refer to our medication database for more information about specifically allowed medications and combinations as there are frequent updates.
Sulfonylurea medications were the first category of oral diabetic agents. They work by increasing the release of insulin from the pancreas and making more available to lower blood sugar. This category is more effective in recently diagnosed, older and obese individuals. They are effective in approximately 85% of people, but some individuals lose their responsiveness. The major side effect is excessive lowering of the blood sugar, hypoglycemia. This is aeromedically significant and pilots are required to show stability without hypoglycemia before obtaining medical authorization. Some commonly used sulfonylureas include glypizide (Glucotrol), chlorpropramide (Diabenase), glyburide (Glynase, Micronase, DiaBeta) and glimepiride (Amaryl). These medications are no longer restricted with Beta Blockers. Refer to our medication database for more information about specifically allowed medications and combinations.
Metformin (Glucophage) was approved for use by the FDA in December 1994. Its primary advantage is that it does not increase the risk of hypoglycemia as sulfonylureas. Although equally effective in lowering blood sugar, it works by a different mechanism. Insulin levels are not affected, but the liver’s release of glucose into the blood is inhibited. Metformin may also have a favorable effect on cholesterol and triglycerides. It is usually well tolerated after some initial diarrhea and abdominal gas, but must be used with caution in those few individuals with medical conditions affecting the acid-base balance in the blood or heavy alcohol consumers. Metformin can be taken once or twice daily.
As of 9 Apr 2013, the FAA released a new policy to allow AMEs to certify airmen with “prediabetes” if treated only with metformin. There are unique requirements and this policy is in flux. Currently, there is a 14 day observation period required for the medication for adequate ground testing, and the hemoglobin a1c% (or HbA1c) must be below 6.5% to be eligible. In Sep 2023 the FAA further extended use of Metformin under it’s CACI program for Weight Management and Polycystic Ovary Syndrome as well. We recommend you discuss this situation with an AMAS physician. Refer to our medication database for more information about specifically allowed medications and combinations.
Acarbose – Precose
Acarbose (Precose) lowers peak levels of blood sugar by delaying the intestine’s conversion of complex sugars into simple ones which enter the blood stream. After a meal, rather than a quick rise in blood sugar and then an insulin response (inadequate in diabetics), those taking acarbose will have a more gradual rise in blood sugar. This is analogous to a leaned out engine with a lower fuel consumption rate, though the aircraft (body) has the same fuel (food) load. It may not lower HbA1c as much as sulfonylureas and metformin, but may be used individually or in combination with each. The major side effects are diarrhea, intestinal gas and abdominal pain. It must be taken before each meal to be effective. Refer to our medication database for more information about specifically allowed medications and combinations.
Repaglinide – Prandin
Prandin is in another class of medications called meglitinides that lower blood sugar by stimulating release of insulin from the pancreas. This medication may be used in combination with Glucophage. It’s use is approved by the FAA and can be waived after proper reporting. Refer to our medication database for more information about specifically allowed medications and combinations.
Rosiglitazone – Avandia
Unlike other medications that increase insulin production or decrease glucose release from the liver, Avandia increases cells’ sensitivity to insulin. The FAA has authorized Avandia for Special Issuance medical certification. Refer to our medication database for more information about specifically allowed medications and combinations.
Pioglitazone – Actos
Like Avandia, Actos is waiverable for pilots who use this medication. Refer to our medication database for more information about specifically allowed medications and combinations.
Januvia (sitagliptin), was approved by the FAA in the Fall of 2007. This may be used as monotherapy or in combination with metformin or a thiazolidinedione (e.g. Actos and Avandia). When used as monotherapy, the FAA still requires an observation period. Refer to our medication database for more information about specifically allowed medications and combinations.
Onglyza (saxagliptin) and Victoza (liraglutide) are allowed by the FAA with waiver. As of 2014, the FAA is modifying its policies regarding waiting times after adding these medications. We recommend that you discuss current policy with an AMAS physician. Refer to our medication database for more information about specifically allowed medications and combinations.
GLP-1 Agonists – Victoza (liraglutide) & Wegovy/Ozempic (semaglutide)
Victoza (liraglutide) and Wegovy/Ozempic (semaglutide) are allowed by the FAA with waiver. As of 2014, the FAA is modifying its policies regarding waiting times after adding these medications. As of Sep 2023 these medications were also allowed under the FAA CACI – Weight Management Program as long as the a1c% has never been 6.5% or higher. We recommend that you discuss current policy with an AMAS physician. Refer to our medication database for more information about specifically allowed medications and combinations.
The FAA approves the use of Byetta (exenatide) and an extended release form, Bydureon, for all classes of airmen certification. In addition to the basic non-insulin dependent protocol outlined in this article, Byetta requires an observation to ensure no adverse effects prior to submission for a Special Issuance. Please contact an AMAS physician to see how this applies to your specific circumstance. Refer to our medication database for more information about specifically allowed medications and combinations.
Sodium-glucose contransporter-2 (SGLT2) inhibitors – Medications in this class represent the newest class of oral drugs for fighting elevated blood sugar. Commonly prescribed examples are Invokana (canagliflozin), Farxiga (dapagliflozin), Jardiance (empagliflozin), and Steglatro (ertugliflozin). The FAA has concerned for this medication class because of concerns for possible sudden loss of consciousness. Additionally the FDA issued a warning in May of 2015 because of a potential for too much acid in the blood or ketoacidosis. This class of medication was eventually approved for use with Special Issuance or Special Consideration in early 2021 after an observation period.
Insulin injections and recently inhaled insulin are used to treat Type I diabetics who have an absolute insulin deficiency, as well as approximately 1/3 of Type II diabetics with severe (>350 mg%) elevations of blood sugar. Insulin was initially made from beef or pork sources, but now is available as genetically engineered human form. Insulin is categorized by how long it takes to act and its duration of action. Insulin lispro (Humalog) is approved as a very fast acting form, allowing individuals to take insulin immediately prior to meals rather than 30-60 minutes prior. The main advantage of insulin is its tremendous ability to rapidly lower blood sugar. This is also one of its major disadvantages, as hypoglycemia and coma is possible if taken in inappropriately high doses, meals are skipped or physical activity is more than anticipated. Of course, the inconvenience of refrigeration, injections, needle disposal and careful glucose monitoring, all necessary, must be considered. For diabetics not controlled by other means, insulin may significantly prolong and improve their quality of life. Insulin waivers previously were limited to 3rd class only, but as of 7 Nov 2019 the FAA also included new protocols for insulin treated diabetes with continuous glucose monitors for all classes. The prior restriction to flying in the domestic US with insulin was also removed. These protocols are very complicated, and we recommend you consult with an AMAS physician if this applies. ATCS can get a waiver with insulin, but have restrictions such as not being able to control alone.
Diabetics need to be very familiar with how to handle diabetic emergencies primarily, hypoglycemia or low blood sugar, hyperglycemia or high blood sugar and insulin shock or coma due to ketoacidosis.
Many of the restrictions and requirements imposed by the FAA on insulin requiring pilots with Special Issuance Authorizations are designed to decrease the possibility of a diabetic emergency in flight. As noted below, the FAA will grant Special issuance medical certificates to pilots who have met very stringent criteria.
Monitoring Diabetes Control
Individuals with diabetes should measure their blood sugar regularly. Some require monitoring several times a day, while others may monitor it less frequently. Generally, people using insulin require more frequent monitoring of blood glucose to determine insulin dosages and the need for snacks. Those on oral medications or controlled with diet and exercise may be able to monitor their blood sugar less frequently. Monitoring generally requires a device to obtain a small amount of blood to put on a chemical treated strip of paper/plastic. This strip is inserted in a machine which will give a reading of the blood sugar. A log of these readings should be maintained for adjustments in the treatment of diabetes. 1st & 2nd class airmen require continuous glucose monitoring.
Pilots with Diabetes Special Issuance Medical Certificates
Pilots with diabetes controlled with diet and exercise alone are eligible for medical certification without requiring a Special Issuance Authorization. They must demonstrate adequate control of their diabetes and the absence of any complications. Regular reports from their treating physicians are required with each FAA medical application. The AME may issue a certificate if the pilot is otherwise qualified.
As noted previously, the FAA also allows use of metformin, liraglutide, or semaglutide for weight loss and for pre-diabetes with HbA1c less than 6.5% to be cleared by the AME without need for Special Issuance.
Special Issuance Authorizations with Oral Medications
For oral medications, the medical evaluation required includes a physician evaluation and physical examination. There should be no evidence of eye damage, nerve damage or significant skin ulcers due to diabetes. A physical examination will detect these conditions. Diabetic complications to the kidneys can be excluded by a urinalysis looking for protein and sugar. Neither should be present. Stress testing is not required for oral medications unless clinically indicated. This protocol is available to all airmen and controllers.
If blood pressure is controlled with medication, no medication that would block the body’s natural symptoms of hypoglycemia or low blood sugar may be used. The FAA no longer excludes using beta blockers in diabetic pilots with hypertension, but caution is advised.
Finally, the pilot/controller must demonstrate control of the blood sugar and have no history of hypoglycemia on FDA approved medications. Control is demonstrated by monthly Hemoglobin A1C values within 1-2 % of the laboratory’s highest normal values. Recently, representatives from the FAA Aeromedical Certification Division stated that A1C values less than 9% could be favorably considered.
The results of these tests must be reviewed by the FAA before a Special Issuance Authorization is granted.
Special Issuance Authorizations with Insulin and Continuous Glucose Monitoring (CGM)
As of 7 Nov 2019, diabetic pilots whose blood sugars are well controlled with insulin and continuous glucose monitoring may be granted a Special Issuance Authorization (SIA) for all classes after they demonstrate control and the absence of related diabetic complications. For insulin, these airmen will require continuous glucose monitoring and complicated protocols (please discuss with an AMAS physician). This is the only insulin protocol available for first and second class certification.
Special Issuance Authorizations for 3rd Class Airman Treated With Insulin without CGM
The FAA will certify 3rd class diabetic pilots who must use insulin for control of their condition without CGM. In Nov 2019 the restriction for flying only in the domestic US was removed. For 1st and 2nd class airmen the FAA requires CGM as noted above. Note that controller standards are equally complicated and require monitoring by management and restrictions to not control alone. For third class, stress testing is typically required every five years. Note that pilots are encouraged to apply for their medical certificate prior to beginning or resuming any flight training. The process may take several months.
The 3rd class pre-flight and in-flight monitoring requirements for diabetic pilots using insulin are rather complex and cumbersome. As stated above, they are designed to minimize the possibility of a diabetic emergency occurring in flight. These requirements are for in-flight only and do not reflect appropriate management on the ground. To lower the risk of insulin shock in flight, the required blood sugar values are somewhat higher in flight than those desired for optimum control when the pilot is on the ground.
Third class pilots are required to have a glucose monitor that they can use in flight and the appropriate supplies (not expired) to check their blood sugar at several phases of flight. They must also have several 10 gram (1/3 oz.) snacks of readily absorbable glucose available for the planned duration of the flight.
Preflight testing for 3rd class requires documentation of blood sugar levels between 100-300 mg% within 30 minutes of takeoff. If greater than 300 mg%, the pilot may not fly the flight. If less than 100 mg%, the pilot must eat a snack and confirm the level is above 100 mg% before flying.
For third class, in-flight testing is more cumbersome, particularly for the task saturated pilot. The overriding concern is the safe conduct of flight. A pilot should delay any required blood sugar testing in critical phases of flight with increased operational demands. Instead, the pilot should eat or drink a 10 gram snack and measure the glucose one hour later. If still unable to measure glucose at one hour later, the pilot should take a 20 gram snack and land at the nearest suitable airport.
The schedule for 3rd class in-flight testing includes hourly checks of blood sugar (ouch!) and one check within 30 minutes of landing. If the blood sugar is below 100 mg%, the pilot should take a 20 gram snack. No snack is required if the blood sugar is between 100-300 mg%. The pilot should land at the nearest suitable airport if the blood sugar is above 300 mg% and not take off until the level can be maintained between 100-300 mg%. This is quite a bit of testing and presumably will require some practice. Conducting this testing at night may be particularly difficult. The well controlled and highly motivated pilot will be able to overcome these obstacles and maintain a Special Issuance medical certificate.
For more information on certification of insulin requiring diabetic pilots refer to FAA.gov.
FAA Reporting Requirements
This is a very broad overview of a complex subject with many nuances. Often clinical narratives from specialists may not necessarily address all of the aeromedical issues involved. Incomplete information can result in significant delays in the certification process.
For a more specific personal explanation to your questions or those concerning aeromedical certification, contact AMAS for a private consultation. For help in reporting treatment for and obtaining clearance from the FAA to fly with these conditions, refer to the AMAS Confidential Questionnaire. If you are an AMAS Corporate Member, these services are FREE to you.