Statement of Demonstrated Ability (SODA) : What to Expect at the Flight Physical

Item 23: FAA Policies on the Airman Medical Exam

Apr 2014

Abbreviated Briefing:
  • A Statement of Demonstrated Ability (SODA) is a type of FAA Waiver for static conditions that are not expected to worsen
  • Airman who seek SODAs will likely require additional medical documentation and may have to prove his/her practical ability during a Medical Flight Test


Guidance is compiled and interpreted by professional pilots and physicians at from the 2014 AME Guide pages 22-45, FAA and FDA web data ( &, instructions specified in the Aeronautical Information Manual, Federal Air Surgeon Bulletins from 1999-2015, and 14 CFR Part 61 and Part 67 (the FARs).


23. Statement of Demonstrated Ability (SODA)

(Statement of Demonstrated Ability)

  ▢ Yes

  ▢ No

Defect Noted:

Instructions for the AME

The AME will ask the applicant if a Statement of Demonstrated Ability (SODA) has ever been issued. If the answer is "yes," the AME will ask you to show you the document. Then they'll check the appropriate block and record the nature and degree of the defect.

SODA's are valid for an indefinite period or until an adverse change occurs that results in a level of defect worse than that stated on the face of the document.

The FAA issues SODA's for certain static defects, but not for disqualifying condition or conditions that may be progressive. The extent of the functional loss that has been cleared by the FAA is stated on the face of the SODA. If the Examiner finds the condition has become worse, a medical certificate should not be issued even if the applicant is otherwise qualified. The Examiner should also defer issuance if it is unclear whether the applicant's present status represents an adverse change.

The AME must take special care not to issue a medical certificate of a higher class than that specified on the face of the SODA even if the applicant appears to be otherwise medically qualified. The AME may note in Item 60: AME Comments on History and Findings the applicant's desire for a higher class.

Statement of Demonstrated Ability (SODA)

At the discretion of the Federal Air Surgeon, a Statement of Demonstrated Ability (SODA) may be granted, instead of an Authorization, to a person whose disqualifying condition is static or non-progressive and who has been found capable of performing airman duties without endangering public safety. A SODA does not expire and authorizes a designated Examiner to issue a medical certificate of a specified class if the Examiner finds that the condition described on the SODA has not adversely changed.

In granting a SODA , the Federal Air Surgeon may consider the person's operational experience and any medical facts that may affect the ability of the person to perform airman duties including:

  • The combined effect on the person of failure to meet more than one requirement of part 67; and
  • The prognosis derived from professional consideration of all available information regarding the person.

In granting a SODA under the special issuance section of part 67 (14 CFR 67.401), the Federal Air Surgeon specifies the class of medical certificate authorized to be issued and may do any of the following:

  • State on the SODA , and on any medical certificate based upon it, any operational limitation needed for safety; or
  • Condition the continued effect of a SODA, and any second- or third-class medical certificate based upon it, on compliance with a statement of functional limitations issued to the person in coordination with the Director of Flight Standards or the Director's designee
  • In determining whether a SODA should be granted to an applicant for a third-class medical certificate, the Federal Air Surgeon considers the freedom of an airman, exercising the privileges of a private pilot certificate, to accept reasonable risks to his or her person and property that are not acceptable in the exercise of commercial or airline transport pilot privileges, and, at the same time, considers the need to protect the safety of persons and property in other aircraft and on the ground

A SODA granted to a person who does not meet the applicable standards of part 67 may be withdrawn, at the discretion of the Federal Air Surgeon, at any time if:

  • There is adverse change in the holder's medical condition;
  • The holder fails to comply with a statement of functional limitations or operational limitations issued under the special issuance section of part 67 (14 CFR § 67.401);
  • Public safety would be endangered by the holder's exercise of airman privileges;
  • The holder fails to provide medical information reasonably needed by the Federal Air Surgeon for certification under the special issuance section of part 67 (14 CFR § 67.401)
  • The holder makes or causes to be made a statement or entry that is the basis for withdrawal of a SODA under the falsification section of part 67 (14 CFR § 67.403); or
  • A person who has been granted a SODA under the special issuance section of part 67 (14 CFR 67.401), based on a special medical flight or practical test need not take the test again during later medical examinations unless the Federal Air Surgeon determines or has reason to believe that the physical deficiency has or may have degraded to a degree to require another special medical flight test or practical test

The authority of the Federal Air Surgeon under the special issuance section of part 67 (14 CFR § 67.401) is also exercised by the Manager, AMCD, and each Regional Flight Surgeon.

If a SODA is withdrawn at any time, the following procedures apply:

  • The holder of the SODA will be served a letter of withdrawal stating the reason for the action;
  • By not later than 60 days after the service of the letter of withdrawal, the holder of the SODA may request, in writing, that the Federal Air Surgeon provide for review of the decision to withdraw. The request for review may be accompanied by supporting medical evidence;
  • Within 60 days of receipt of a request for review, a written final decision either affirming or reversing the decision to withdraw will be issued; and
  • A medical certificate rendered invalid pursuant to a withdrawal, in accordance with the special issuance section of part 67 (14 CFR § 67.401 (a)) shall be surrendered to the Administrator upon request

This page discussed the Statement of Demonstrated Ability (SODA) section of the Fight Physical Examination required of pilots.

Reminder: use to familiarize yourself with aviation medical regulations and guidelines, but always discuss your specific situation with one or more AMEs before dedicating resources toward expensive clinical workups. Find an AME now