Originally published in Wings Magazine Winter 2025-2026 edition https://issuu.com/annexbusinessmedia/docs/wg_-_winter_2025_2026
Although not entirely new, Transport Canada (TC) has recently increased its focus on the signs and risks of sleep apnea. Pilots in higher-risk categories, such as those with a higher BMI, larger neck circumference, or signs of daytime fatigue, are now more consistently flagged during their aviation medical renewal.
In many cases, these pilots still receive their medical certificate, but it’s now conditional on completing a sleep study and submitting the results before the next renewal. For some, it may feel like another hoop to jump through, but this aligns with what ICAO and the FAA have been practicing for years.
A Quiet Risk
Fatigue has long been one of aviation’s biggest hazards. The nature of the job, with long duty hours, jet lag, and sometimes stressful and exhausting flying conditions, already poses fatigue risks to flight crews. If a pilot also suffers from an untreated sleep disorder, these risks are compounded.
Obstructive Sleep Apnea (OSA) occurs when the airway repeatedly collapses during sleep, disrupting breathing and depriving the brain of oxygen. This leads to poor-quality sleep, slow reaction times, and decreased cognitive performance.
Untreated sleep apnea can cause a variety of health problems and can even be fatal. That’s why ICAO and the FAA have long encouraged regulators to identify and address the condition among flight crews before it becomes a safety threat. Sleep apnea increases the risk of cardiovascular issues such as high blood pressure, heart attack, stroke, and heart failure due to repeated drops in blood oxygen levels. Other risks include daytime fatigue, type 2 diabetes, cognitive and mood disorders like depression, and additional health complications.
ICAO, FAA — and Now TC
The International Civil Aviation Organization (ICAO) requires that pilots not be affected by any condition that could lead to incapacitation in flight. Its Manual of Civil Aviation Medicine (Doc 8984) highlights sleep-related breathing disorders as a concern when there’s excessive daytime sleepiness, high BMI, or similar markers.
The U.S. Federal Aviation Administration (FAA) developed its own structured approach based on those principles many years ago. Under FAA policy, pilots at risk of OSA must undergo a sleep study and demonstrate effective treatment, often via CPAP therapy, before retaining certification.
TC is now reinforcing ICAO standards and pursuing a more consistent approach during medicals.
What’s Actually Changing
The regulations themselves haven’t been rewritten, but TC is informing pilots and CAMEs more frequently that additional results, testing, or examinations are necessary. CAMEs are encouraged to review known risk factors and refer pilots for sleep studies when appropriate.
In practice, this means:
• If you have a high BMI (30 kg/m² or more), a large neck diameter, or persistent daytime sleepiness, or a combination of these, your examiner or TC may suggest require a sleep study.
• If OSA is confirmed, you’ll need to provide proof of effective treatment, usually through CPAP compliance data or a physician’s report.
• Your medical certificate may not be renewed during the next medical exam until you demonstrate that the issue is under control.
• Delays in completing the process could delay your renewal.
How it works
For pilots who are flagged, there are a few options. A more detailed review by your doctor might be enough to show you’re not at risk or that a sleep study isn’t necessary. For those who must undergo a sleep study, it’s important to remember it can take months to get an appointment, and this should be discussed with your CAME and TC, depending on the request for more information.
Sleep studies involve sensors attached to your head, chest, and legs, as well as straps around your chest and stomach to monitor breathing. A device, often a cannula, is used to track nasal breathing. Once set up, you’ll spend the night being monitored while technicians record and observe the data. The results, once analyzed, will indicate which treatment, if any, and to what extent might be necessary. CPAP therapy, while effective, can take some time to adjust to. The good news is that treatment works. Most people with OSA who use CPAP consistently experience better sleep, increased energy, and improved overall health. From a regulatory perspective, demonstrating compliance is relatively straightforward. CPAP machines usually record usage data, which can be downloaded and shared with your physician or CAME. This data shows how often the machine is used, the duration of each night’s use, and whether the treatment is effective. With this information, TC can confidently renew your medical certificate, knowing the condition is well-managed.
Final Thought
If you have been flagged as possibly being at risk for Obstructive Sleep Apnea, or if Transport Canada has specifically requested additional information or documentation, it’s important to speak with your CAME. Your CAME can help you understand the request, guide you through the necessary steps to address it, and assist in identifying and managing any potential underlying health issues that may currently be unnoticed or undiagnosed.
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