FAR 67.103 (c)

[Captain_Bob]

(c) Ability to perceive those colors necessary for the safe
performance of airman duties. -

How much wiggle room is there in that statement from your (an AME's) perspective?

I have a buddy who was trying to get his medical and he has a blue/green deficiency... but he can easily differentiate between Green/Red/White. The problem is, he can't pass the Ishihara Color Plates test which seems to be the most common form of color blindness test out there. But he can pass several of the other "authorized" tests... but lot's of them aren't even offered anymore.

So he calls up one AME in particular and the AME says... "Those tests are ridiculous... The Federal Aviation Regulation 61.103 (c) states you only need to perceive the colors necessary for the safe performance of airman duties."

So basically, my buddy goes... he is shown the Ishihara Color Plates as part of the exam but he is not asked to decipher them... instead... the Doc asks him to turn around and look across the room to 3 colored sheets (Red, Green, White) of paper labled "1, 2, 3" posted on the wall and asks him to tell him what color sheet 1 is... what color sheet 2 is... etc.

The Doc says that is how he interprets 67.103(C).

The Guide for Aviation Medical Examiners states that "Examiner's shall have adequate facilities for performing the required examinations and posess or agree to posess the following equipment prior to conducting any FAA examinations."

It obviously goes on to list the different "authorized" color blindness test plates and equipment. But it doesn't specifically state that the specific equipment must be "used"... just be "posessed".

The AME Guide also states that AME's have the delegated authority to: "Issue or deny airmen medical certificates to applicants or holders of such certificates based upon whether or not they meet the applicable medical standards. The medical standards are found in... Part 67." Which brings us full circle back to the 67.103 (c)... where it doesn't say you have to look at color plates... just perceive the colors necessary for the safe performance of airman duties.

Well, it makes sense... but do you guys really have that sort of "interpretational latitude"?

I'm just certain that if I told my AME to just show me three different colored pieces of paper for the color vision screen that he would laugh at me...

What's your take Doc?

Thanks,

Bob

[My Flight Surgeon]

Short answer is NO! We must use one of the authorized tests. If you ask the FAA, that is what they will say. There is a "colored yarn test" for color vision that uses pieces of colored yarn (this is similar to what the AME is doing) and it is specifically disallowed.

The options are a Farnsworth light test (I have one of these in my office for just such a situation) or if the color test can't be passed, get a SODA by applying for the light test - that solves the problem for all time.

The AME in the senario you present is misinterpreting the regs. Also, when we issue a medical certificate, the FAA has 60 days to reverse our decision. As AME's we agree to follow the FAA's interpretation of the regs and not to interpret them the way we think they should be.