by Dr. Susan Northrup, FAA Federal Air Surgeon
On January 1, the FAA changed color vision testing for pilot medical certificates.
This primarily impacts first-time applicants for an FAA medical certificate. If you already have a medical certificate, the change doesn’t affect you. However, you might be wondering, "Why the change?"
Why the Change?
Having adequate color vision — the “ability to perceive those colors necessary for the safe performance of airman duties” — in pilots was assumed by the developers of traditional aviation sectionals and charts, airport signage, and lighting. Color vision has been evaluated by both the FAA and military branches with various tests including the Ishihara plates and Falant Lantern. It was recognized, though, that some individuals passed the test despite a significant color vision deficiency (CVD) due to either limitations of the test or memorization of the plate order.
Over the past few decades, aviation has become an increasingly color-rich environment with multi-function displays and tablets. The FAA recognizes that adequate color vision is much more essential in aviation. The military, in fact, noted that both aircrew and flight test engineers who held waivers for CVD sometimes struggled with accurately interpreting the more modern color-rich displays.
The 2002 FedEx Incident
The limitations of current testing were highlighted on July 26, 2002, when a FedEx aircraft struck trees on short final to the runway at Tallahassee Regional Airport (TLH), landed short, and was destroyed. Fortunately, there was no loss of life, although the crew was seriously injured. During the investigation, the NTSB determined that the known color deficiency of the first officer, the pilot flying, was a factor in the mishap. Notably, this individual had received a “waiver” for his CVD from both the military and the FAA. The NTSB then made several recommendations to the FAA.
Subsequently, our staff at CAMI, the Civil Aerospace Medical Institute, began an extensive review of available testing for color deficiency. It quickly became clear that the current tests had inherent limitations including color fading of the plates with time, lighting issues, and the ability of individuals to memorize the order of the plates if not shuffled. Also, none of the tests in routine use evaluated blue-yellow deficiency, which had become increasingly important in aviation.
The staff at CAMI then undertook testing of both color-normal and color-deficient individuals to determine thresholds for operationally acceptable (not necessarily normal) color vision. Following this, we began an in-depth discussion of the path forward with our ophthalmologist consultants and military counterparts.
How the New Testing Works?
A change to computer-based testing was necessary and three such tests are now authorized. Any is acceptable and the applicant has the option of taking a test more than once (since they are randomized) or a different test if one is failed. More information can be found at bit.ly/ColorVisionFAQs (PDF).
So, whom does this impact? We determined that those who already had an FAA medical can retain their current privileges. In other words, if someone has a CVD, but has been given a letter of evidence (LOE) or a statement of demonstrated ability (SODA), we will continue to recognize these. Note that these generally were issued following an operational color vision test (OCVT). However, these are time-consuming and expensive for both the pilot and the FAA. One of the goals for the change to computer-based tests is to minimize the need for an OCVT in the future.
First-time applicants for an FAA medical certificate after Jan. 1, 2025, will receive a computer-based test. With certain exceptions, this is a “one and done” test for them and is not required for those who have a medical issued on or prior to Dec. 31, 2024.
Exceptions to the Rule
The first exception is if you are diagnosed with a medical condition or take a medication that can impair color vision, a computer-based test will be required as part of your evaluation. This is true regardless of when you first had an FAA medical issued. The other exception is for those issued a medical prior to Jan. 1, 2025, but who request removal of a current limitation for color vision or an upgraded medical (e.g., from a Class III to a Class I or II).
We recognize that this is a significant policy change and will monitor it closely to minimize the impact on pilots while ensuring safety of flight.
About Dr. Susan Northrup
Dr. Susan Northrup received a bachelor’s degree in chemistry, a medical degree from The Ohio State University, and a master’s degree in public health from the University of Texas. She is double board-certified by the American Board of Preventive Medicine in Aerospace Medicine and Occupational Medicine. She is a retired U.S. Air Force colonel and a former regional medical director for Delta Air Lines. She is also an active private pilot and aircraft owner.
