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Old 08-02-2018, 06:49 PM
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Question Deferred 3rd Class for OSA and SNRI

I applied for a 3rd class medical certificate for the first time in May 2018. I had the exam on May 18 and was deferred because of my obstructive sleep apnea diagnosis and my use of Venlafaxine, which is an SNRI, an antidepressant. The AME told me to get a letter from both my psychiatrist and the physician who oversees my CPAP use stating that I am "medically fit to fly." I requested as much from both. In meeting with my psychiatrist I decided to discontinue Venlafaxine because I assumed it would be easier to obtain certification in the future off of Venlafaxine. The documents were sent to the FAA on June 11. The FAA says they received my application on July 2. I took my last dose of Venlafaxine on July 4. I call the FAA once a week for an update and they haven't taken any action. My questions are: Have I sent the proper documentation to the FAA? What will the FAA say? What will be different when I apply in the future without a reported medication? Will I need recommendation from my psychiatrist? Thanks.
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Old 08-02-2018, 07:11 PM
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In a case like yours, you really to speak with a doctor familiar with your medical profile AND with FAA procedure. These cases take time to resolve (I had a pilot wait six months on initial return to flight status after involved heart surgery) and you need pros to make it happen. Just an observation from reading threads, coming off an anti-depressant requires three months before the FAA will consider it.

AOPA has a good medical and legal services that would be a good start.

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Old 08-03-2018, 08:24 AM
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As a general rule you delay things if you make changes. Although Venlafaxine is on the list of SSRIs that they will generally waive if there are no other problems, by simply stopping taking it you have now changed the goalposts. Instead of having to show that you HAVE BEEN doing well enough on the medication that it is not a problem you must now demonstrate that you WILL BE ABLE to do well enough OFF the medication for it not to be a problem.

Since the FAA bases their assessment on a reasonable period of observation, by changing the conditions of the situation you have lost the ability to be judged on your historical record and must now twiddle your thumbs waiting out an observation period.
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Old 08-03-2018, 10:02 AM
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To be clear, I reported taking Venlafaxine to the FAA. Then I stopped taking it because it was not on the approved SSRI list. I did not report this change to the FAA. As far as they know I'm still taking it. Will a granted medical be valid under these conditions?
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Old 08-03-2018, 04:32 PM
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Originally Posted by chrisitizer View Post
To be clear, I reported taking Venlafaxine to the FAA. Then I stopped taking it because it was not on the approved SSRI list. I did not report this change to the FAA. As far as they know I'm still taking it. Will a granted medical be valid under these conditions?

Either way you are sort of temporarily screwed:

If they did approve you (and it is within their authority to add additional SSRIs to the original four) then you have changed the conditions that were (or at least would be) specified in your SODA and it would no longer be valid.

If they didn't approve you, they would STILL want to establish a history of how you did off medication before they approve you.

You would have done better to call them up and discuss the options with them before doing things without telling them. You have a regional flight surgeon at your FSDO and - despite sometimes keeping you on hold listening to elevator music while they talk to some other guy wanting a SODA - the OKC guys are scarcely unapproachable either.

Realistically, for a flying class 3, they tend to be pretty liberal. Knowing that your OSA isn't going to cause you to fall asleep on a long boring cross country and that you are stable either off meds or on any of the approved meds will probably be adequate, but you and your treating physician need to choose a treatment plan AND STICK WITH IT to establish the presence or absence of that stability.

They can't give you an answer other than "no" if you keep changing the question before the efficacy of treatment can be assessed and if you keep changing the treatment without telling them it becomes easier for them to give you a permanent "no" rather than putting their professional reputations at risk by telling ou "yes."

These guys aren't ogres. They ultimately approve, either right out of the box, or by SODA, about 99.95% of applicants, but if you are going to keep changing what's going on without telling them,you have a high risk of winding up in that 0.05%.
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