Alcohol, The Pilot, and The FAA

There is some evidence that a moderate intake of alcohol offers some health benefits, although it is also a well-established fact that too much of a good thing, or a good thing at a bad time can be quite dangerous. Alcohol is a major factor in motor vehicle deaths, and still is a significant causative factor in aviation deaths.

There are two FAR’s that are important to know when it comes to drinking and flying. Most pilots are aware of the “8 hour” rule, that is, 8 hours from bottle to throttle, although many airlines have a more stringent 12 hour time limit. Most pilots do not know of the 0.04% FAR, which prohibits flying an aircraft with a blood alcohol concentration (BAC) of 0.04% or higher.

Let’s talk a bit about the physiology of alcohol metabolism, in order to understand these 2 different FAR’s, and what they mean to the pilot. The first one is quite clear. The FAA prohibits the ingestion of any alcohol within 8 hours of flying as a pilot crew member, be it general or commercial aviation. For most of us who are not heavy and regular drinkers, if we follow the 8 hours rule, we would assume that we should not generally be busting the 0.04% rule. However, because our bodies eliminate alcohol at a constant rate, it is quite possible to ingest enough alcohol, follow the 8 hour rule, and still be over the 0.04% limit. In comparison, most states set this limit for driving under the influence (DUI) at a higher level, generally about 0.08%.

The BAC at any given time depends mostly on the size (and to a lesser degree the sex)of the person, the amount ingested, and the amount of time passed since ingestion. It has nothing to do with the alcohol experience of the person, although habituation certainly leads to tolerance, meaning that higher BAC’s can be tolerated by the individual.

Pure alcohol is metabolized at a rate of about 0.015 mg% per hour. The concentration of a unit of ingested alcohol in a person depends on the size of that person, but the hourly rate of elimination is the same, regardless of size of the individual. Since a standard serving of any alcoholic beverage contains roughly the same amount of alcohol, the following formula can be used to approximate the BAC at any given time:

(Body weight per drink x number of drinks) – (elimination rate x number of hours since last drink)

To make this calculation, the following table shows the figures for the first variable (Body weight per drink) in the formula, for 3 different sizes of individuals:

0.04% per drink @110# 0.03% per drink @155# 0.02% per drink @200#

To illustrate how this is calculated, let’s take the middle person who weighs 155 pounds. A standard alcoholic beverage would result in a BAC immediately after consumption of 0.03%. If that person drank 6 drinks rather quickly, 8 hours later his BAC could be estimated by plugging in the numbers and doing the arithmetic like this:

(0.03 x 6) – (0.015 x 8) = 0.06%

Note that this exceeds the 0.04% rule!

From this discussion, it is easy to figure out that one could still be legally intoxicated even while complying with the 8 hour rule. Furthermore, there are important issues pertaining to alcohol abuse and alcoholism as it relates not only to flying, but to one’s general health.

While many of us have had occasion to overindulge and suffered the unpleasant, but rather short term consequences of that behavior, that is quite different from what is considered alcoholism. There are a variety of definitions of this disease, but in general they all contain these 2 important elements: that the need to drink becomes harmful to one’s relationships, and it adversely affects one’s activities of daily living, such as job performance. This frequently comes to light with behavior such as family quarrels, loss of reliability at work, and an accumulation of DUI’s. Since so much of one’s time and emotional energy is spent on working toward getting that next drink, the alcoholic’s judgment is impaired even when sober. Additionally, chronic alcoholism injures not only liver and heart tissue, but adversely affects the brain, and can therefore cause permanent cognitive impairment even long after sobriety is obtained.

Since it is not common for an alcoholic pilot to self report their problem to society, the FAA has 2 further regulations that are intended to identify pilots with potential alcohol problems. One requires that a pilot who is found guilty of a DUI report this to the FAA Civil Aviation Security within 60 days of this action. The other one is a mandatory report of DUI on their next Airman Medical Examination. It should be noted that when you sign this document, not only are you certifying your truthfulness but you are also authorizing the FAA to compare your statements with the National Driver Registry for verification. It should be emphasized here that the FAA does not consider a person to be an alcohol abuser with one DUI. However, the FAA can automatically revoke, suspend, or deny a medical certificate if there have been two or more DUI’s within a three year period. It should be obvious that it is by far more important to honestly document even one DUI action as hiding it would only increase the suspicion of alcohol abuse. Furthermore, any falsification of information on the FAA Form 8500 (the Airman Medical Examination form)can subject an individual to criminal penalties of a fine up to $250,000 or imprisonment for not more than five years, or both.

In the General Aviation world, the FAA will consider granting a Class III or even a Class II Medical Certificate to a pilot who has successfully undergone alcohol treatment. This usually requires some sort of recognized treatment center, either inpatient or outpatient, depending on the circumstances, and strong evidence of sobriety for a period of 2 years. This can include documentation of attendance of AA meetings, letters from employers or other reputable individuals who know the pilot well, or at best a letter from the treating counselor indicating successful treatment. The FAA takes a more difficult stance with individuals who relapse.

For professional Class I pilots, there is a special program developed several years ago called HIMS, which stands for Human Intervention and Motivation Study. This is an extraordinary program that brings together the FAA, ALPA (Airline Pilots Association) and the management sector of the airline industry. It sets the rules for bringing back successfully treated alcoholic pilots to the cockpit, and requires strict adherence to a sobriety program. In general, the pilot must undergo a 4week inpatient treatment program, and prove sobriety through a rigorous process that includes regular AA meetings, involvement with a peer group, regularly scheduled meetings with their medical sponsor (usually their AME)as well as a representative from their airline, and regular urine tests. They can be returned to the cockpit as soon as 3 months if it is felt that they are successful, but must remain in the program for monitoring for a minimum of 3 years. These programs have been shown to be highly successful, as these pilots are usually highly motivated to keep their jobs.