P4HR Supplements FAA Rulemaking Petition With Expanded Medical and Scientific Advisory Resources
Pilots for HIMS Reform has submitted supplemental information in FAA Docket No. FAA-2026-10399 to notify the agency that P4HR has expanded the medical and scientific expertise available to support review of its pending Part 11 petition for rulemaking.
What P4HR filed
The supplemental submission was filed in the same federal docket as P4HR’s existing Petition for Rulemaking, FAA-2026-10399. Rather than proposing new regulatory language, the filing updates the administrative record with information about P4HR’s expanded medical and scientific advisory resources.
The submission also offers to facilitate appropriate responses from Advisory Board members, provide supporting scientific or professional literature, and participate in technical discussion if the FAA concludes that additional information would assist its review.
That approach is consistent with the FAA’s Part 11 framework. The FAA’s own guidance for petitions for rulemaking states that petitioners should provide supporting information and arguments, including relevant technical and scientific data, and notes that the agency may request additional information or data while considering a petition. FAA petition-for-rulemaking guidance →
Expanded aviation medical expertise
The update follows the recent addition of two aviation medical professionals to P4HR’s Advisory Board:
Dr. Andrea Nelsen
An aviation psychiatrist whose participation adds psychiatric and aeromedical perspective to P4HR’s work, including questions involving mental-health assessment, treatment, standards of care, recovery, and medical certification.
Read Dr. Nelsen’s announcement →Dr. Chuck Denison
An aviation and forensic neuropsychologist and pilot whose work includes FAA medical-certification evaluations, neuropsychological assessment, human factors, and aviation-related professional consultation.
Read Dr. Denison’s announcement →These additions broaden the range of professional perspectives available to P4HR as the petition moves through the FAA’s review process. They also give the organization additional capacity to respond when a regulatory question depends on medical evidence, clinical practice, psychological or neuropsychological assessment, or human-factors analysis.
An important distinction
P4HR’s supplemental submission intentionally makes clear that service on the Advisory Board should not be interpreted as an individual endorsement by either professional of every provision or specific regulatory proposal contained in the petition unless that individual has expressly said so.
The purpose of the update is narrower and more practical: to ensure that the FAA knows qualified clinical perspectives are available to inform P4HR’s work and to help address medical or scientific questions that may arise during review.
P4HR now has additional aviation psychiatry, neuropsychology, and human-factors expertise available to support substantive technical engagement. If the FAA needs further clinical information, scientific literature, or clarification relevant to the petition, P4HR is prepared to help provide it.
Why add this to the docket?
A federal rulemaking petition is evaluated on its substance, not simply on the number of organizations or individuals supporting it. For that reason, P4HR believes it is useful for the official record to reflect the medical and scientific resources now available to the organization.
The original petition raises questions that intersect with aviation safety, medical certification, psychiatric and substance-related evaluation, monitoring, Special Issuance processes, recovery standards, due process, and pathways to unrestricted medical certification. Some of those issues necessarily require medical and scientific analysis in addition to regulatory and operational analysis.
The supplemental filing gives the FAA a straightforward point of contact if reviewing officials determine that additional expertise would be useful.
What happens next
The underlying Petition for Rulemaking remains before the FAA. The supplemental submission does not replace or restart that petition; it adds information to the existing docket.
P4HR will continue to respond to requests for information and will supplement the record when there is new information that is materially relevant to the agency’s review.
Source note: FAA, “Petition for Exemption or Rulemaking,” 14 C.F.R. Part 11 guidance; P4HR Supplemental Submission Regarding Medical and Scientific Advisory Resources, Docket No. FAA-2026-10399 (Oct. 2, 2026).
Pilots for HIMS Reform is an independent advocacy organization and is not affiliated with the Federal Aviation Administration or the official HIMS Program.