Comment from Quinton Weiskittel

Quinton WeiskittelSupportIndividual

Summary: Quinton Weiskittel, an insulin-dependent diabetic pilot, supports Eric Friedman's petition for an exemption from specific FAA medical certification regulations. He argues that the current discretionary process is inefficient and outdated, and that a formal exemption would provide regulatory certainty, improve safety by reducing administrative burdens, and reflect modern medical advancements in diabetes management.

I strongly support Eric Friedman’s Petition for Exemption from 14 CFR sections 67.113(a), 67.213(a), and 67.313(a), along with related relief from the discretionary issuance process under sections 67.115, 67.215, 67.315, and 67.401. As an insulin-dependent diabetic pilot myself, I have personally experienced the burdens, uncertainties, and inefficiencies of the current system. Formalizing and stabilizing the process through a grant of exemption is not only in the public interest but essential for aviation safety, regulatory fairness, and government efficiency. The FAA’s longstanding blanket prohibition on insulin use for medical certification no longer reflects medical reality or safety data. Since 1996, the FAA has issued thousands of medical certificates (including first- and second-class) to insulin-treated pilots via discretionary processes. The safety record has been outstanding: no reported incapacitation events among these pilots, often matching or exceeding that of non-diabetic pilots. Advances in diabetes management—continuous glucose monitors (CGMs), modern insulins, and better education—have transformed the condition. International regulators in Canada, the UK, and elsewhere have safely certified insulin-treated pilots for years, including operations in U.S. airspace. The U.S. FAA’s own actions since 2020 confirm that individualized assessment works. Maintaining an obsolete regulatory ban while relying on an informal, shifting “special issuance” process creates unnecessary barriers without enhancing safety. Eric Friedman’s petition accurately describes the problems I and other pilots face: • Unpredictable and shifting standards in the Guide for Aviation Medical Examiners (GAME), with no public notice-and-comment. • Medically unnecessary or duplicative testing (e.g., extra ophthalmologist reports or lab panels not required of other pilots). • Extra-regulatory “drop-dead” date limitations on certificates that conflict with standard validity periods under 14 CFR § 61.23. • Lack of transparency and consistency, leading to different treatment for similarly situated applicants and prolonged administrative delays. These issues increase costs, distract pilots from safety-critical duties, and strain FAA resources. As a pilot who must renew certifications semi-annually, the uncertainty undermines the stability pilots need to focus on professional responsibilities. A formal exemption with clear, stable terms would eliminate this “administrative limbo” while preserving (and likely improving) safety through standardized, evidence-based criteria. Granting this exemption would: 1. Enhance safety by reducing distractions from opaque bureaucracy, allowing pilots to prioritize training, rest, and flight duties. Eric Friedman’s professional background as a former FAA aviation safety inspector lends strong credibility to this point. 2. Promote regulatory certainty and fairness, aligning with the Pilot’s Bill of Rights and Administrative Procedure Act principles. 3. Improve efficiency for the FAA by streamlining processing, reducing internal confusion, and enabling AMEs to handle more cases under clear guidelines. 4. Benefit the traveling public by keeping qualified, experienced pilots (many with extensive training and hours) in the cockpit without artificial barriers. 5. Provide transparency through a published exemption, allowing consistent application to other pilots and reducing arbitrary disparities. This petition does not seek new privileges—only to formalize what the FAA is already doing successfully. It replaces an unstable, extra-regulatory workaround with a reliable framework. As someone managing insulin-dependent diabetes while pursuing and maintaining pilot qualifications, I echo Eric Friedman’s call for modernization. I have advocated directly to experts like Dr. Steve Edelman for support on this issue, emphasizing the need for updated FAA processes that reflect current medical capabilities. Pilots with well-controlled diabetes pose no greater risk than others when properly monitored. The data and real-world experience support this. I urge the FAA to grant the exemption expeditiously, evaluate it on the merits (rather than dismissing via the discretionary process), and consider broader rulemaking to update Part 67 permanently. This change would affirm the FAA’s commitment to evidence-based regulation and inclusivity without compromising the highest safety standards. Thank you for considering this comment. I am available for any questions and strongly encourage approval of Docket FAA-2024-2648. Sincerely, Quinton Weiskittel

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