No Rules. No Standards. No Oversight:
What the FAA Admitted About the Airline HIMS Program
Date: June 2025
In a 2021 internal memo obtained by Pilots for HIMS Reform, Federal Air Surgeon Dr. Susan Northrup issued several stunning admissions regarding the FAA’s oversight—or lack thereof—of airline-administered HIMS programs.
🚨 FAA Quote from the Memo
“There is no FAA Order, Regulation or Standard applicable to the airline HIMS program.”
— Dr. Susan Northrup, Federal Air Surgeon
Key FAA Admissions
- “The FAA does not establish or promulgate regulatory requirements for airline HIMS programs.”
- “Since AAM has not established regulatory requirements for an airline HIMS program, there is no FAA Order, Regulation or Standard applicable to the airline HIMS program.”
- “The FAA has no authority to require compliance by the airline.”
P4HR Analysis
These statements validate what many pilots have long reported: there are no enforceable rules governing how airlines administer HIMS. Yet the FAA allows these internal programs to heavily influence pilot medical certification—with no clear protections, no independent review, and no due process.
When the FAA admits it has “no authority” over these programs but still acts on employer reports to restrict or revoke medicals, it confirms the central problem: pilots are punished under a system that doesn’t exist in law or regulation.
Why This Matters
This memo confirms the central failure of the current FAA HIMS structure: pilots are held to standards that don’t formally exist. While airlines can discipline employees however they wish, the FAA’s medical office uses employer reports from these unregulated programs to deny, delay, or revoke medical certificates.
Without any FAA rules governing how airline HIMS programs are run, pilots have no right to challenge their fairness, no standard review process, and no pathway for appeal if targeted unfairly. This is not just unjust—it’s unconstitutional.
Furthermore, the FAA's own admission that it lacks authority over airline HIMS programs raises a serious legal question: If a pilot’s livelihood is destroyed based on an employer-driven process with no federal oversight, could that airline now bear legal liability for mismanagement, retaliation, or emotional harm?
P4HR Is Fighting for Change
The Pilots for HIMS Reform Act of 2025 would close these gaps by requiring FAA oversight, enforcing consistent national standards, and protecting pilots’ rights to due process. Read the full bill here.