Original publication date: April 4, 2024
Last Updated: April 4, 2024
Author: Max Skyler
Topic: Flight Physiology, Hearing
Number of Comments: 0
Tinnitus in and of itself, is not a medically disqualifying condition for pilots. Having said that, the FAA does recognize tinnitus as a condition of potential concern with respect to a pilot’s ability to safely operate an aircraft. Particularly when it comes to radio communications, cockpit communications, and situational awareness, the FAA does require that tinnitus be addressed in order to keep your medical certificate in good standing.
This condition, characterized by a persistent ringing or buzzing in the ears can be a minor annoyance at best, or it could be a chronic hindrance and distraction, indicative of a more serious underlying condition, at worst. Suffering from tinnitus myself, my audiologist recommended that I wear hearing aids as a means to eliminate or reduce its impact.
This article aims to dive deeper into tinnitus among aviation experts. It covers the experiences of afflicted pilots, relevant FAA standards, and the medical clearance needed for affected aviators.
Key Takeaways:
- Tinnitus is a condition characterized by a ringing or buzzing sound in the ears.
- While tinnitus may not directly affect a pilot’s ability to fly, it can have various impacts on their overall well-being and job performance.
- The Federal Aviation Administration (FAA) has established regulations and medical certification requirements for pilots with tinnitus.
- Pilots with tinnitus may need to go through a Special Issuance medical certification process or obtain a Statement of Demonstrated Ability (SODA) to continue flying, if they are unable to qualify for a standard medical certificate.
- Prevention is key to reducing the risk of tinnitus in the cockpit, including measures such as noise reduction and appropriate hearing protection.
Understanding Tinnitus in Pilots
Tinnitus manifests itself as ringing, buzzing, or humming in the ears, even without external noise. Causes range from loud noise exposure to age-related hearing degradation. Given their work environment, pilots face a heightened risk of tinnitus from aircraft noise and other job-related hazards. It is surprisingly common amongst pilots, according to this study conducted by the National Institutes of Health.
Symptoms of Tinnitus
For pilots, being keenly aware of the symptoms of tinnitus and their triggers is crucial. Symptoms include:
| Condition | Description of Symptoms |
|---|---|
| Persistent Noise | Persistent ringing, buzzing, or hissing sounds in one or both ears, not caused by external noise. |
| Variation in Sound | Variation in the pitch and intensity of the perceived sound, ranging from low to high. |
| Intrusiveness | Difficulty concentrating and sleeping due to the intrusive nature of the noise. |
| Intermittency | The sound may be constant or intermittent, affecting daily activities and quality of life. |
| Pulsatile Phenomenon | Some individuals report a pulsating sound, in sync with their heartbeat (pulsatile tinnitus). |
| Associated Symptoms | In severe cases, tinnitus may be accompanied by hearing loss, dizziness, or a feeling of fullness in the ears. |
Pilots recognizing these signs can manage their condition better, minimizing career impact. Awareness of tinnitus triggers, such as loud sounds and stress, is equally important.
Coping With Tinnitus
Several strategies exist for managing tinnitus:
| Strategy | Description |
|---|---|
| Sound Therapy | Using external sounds to partially or completely cover the tinnitus, helping to distract or habituate to the noise. |
| Cognitive Behavioral Therapy (CBT) | Psychological approach focusing on changing negative reactions to tinnitus, improving coping mechanisms. |
| Hearing Aids | For those with hearing loss, amplifying external sounds can make tinnitus less noticeable. |
| Tinnitus Retraining Therapy (TRT) | Combines sound therapy with directive counseling to retrain the brain’s perception of tinnitus. |
| Stress Management | Techniques like relaxation therapy, meditation, or exercise to reduce stress, which can exacerbate tinnitus. |
| Avoid Aggravators | Limiting exposure to loud noises, reducing caffeine and alcohol intake, and avoiding smoking can help manage symptoms. |
Conditions That Trigger Tinnitus
It is also imperative that pilots are aware of what are some things that might trigger or cause tinnitus.
| Trigger | Description |
|---|---|
| Loud Noise Exposure | Exposure to loud noises, such as concerts, machinery, or explosions, can trigger or worsen tinnitus. In the context of aviation, this could be triggered by: * The volume in your headphones being too loud, particularly the squelching that oftentimes occurs over the radio. * The roaring sound of the engines, if you aren’t wearing adequate ear-protection. |
| High-Altitude Flying | Changes in air pressure at high altitudes can trigger tinnitus. As altitude increases, the eustachian tube releases an air bubble into the middle ear to equalize pressure. If the tube is blocked or doesn’t function normally, it can’t release the bubble. This can create a vacuum that pulls the eardrum’s membrane into the inner ear, stretching it unnaturally. This can cause sounds to distort and sometimes pain. It can also amplify ringing in the ear, making it more obvious for people with a dull ringing. |
| Earwax Buildup | Accumulation of earwax can block the ear canal and cause hearing loss or tinnitus symptoms. |
| Age-Related Hearing Loss | Degradation of hearing associated with aging can lead to the development of tinnitus. |
| Ototoxic Medications | Certain medications can damage the inner ear, leading to tinnitus. These include some antibiotics, NSAIDs, and chemotherapy agents. |
| Ear or Sinus Infections | Infections in the ear or sinus can increase pressure and fluid in the ear, causing tinnitus. |
| Stress and Anxiety | High levels of stress and anxiety can exacerbate or trigger tinnitus in some individuals. |
This knowledge empowers pilots to safeguard their hearing and improve their quality of life. It also promotes safer flying practices. Understanding tinnitus is a step towards protecting one’s career and well-being in aviation.
Assessing the Impact of Tinnitus on Pilot Attentiveness
Severity and Frequency of Tinnitus Among Pilots
The severity and frequency of tinnitus vary among pilots, affecting them differently:
For some, a persistent ringing or buzzing complicates focusing on tasks and understanding cockpit communications.
Others deal with sporadic tinnitus, experiencing relief only to be disrupted by sudden intensifications.
Grasping this spectrum is essential for evaluating how tinnitus may influence a pilot’s performance and safety.
Tinnitus Can Interfere With Radio Communications
Clear and effective communication with air traffic control (ATC) and other aircraft is vital for safe flying. Tinnitus can mask or distort incoming radio communications, making it difficult for pilots to understand instructions or important information. This can lead to misunderstandings or missed communications, increasing the risk of in-flight errors.
Tinnitus Can Interfere With Cockpit Communications
In addition to radio communications, pilots need to communicate effectively with co-pilots or crew members. Tinnitus can make it challenging to hear and process these internal cockpit communications, especially if the tinnitus frequency overlaps with the human voice range. This can impact teamwork and the efficient management of cockpit duties.
Tinnitus Can Interfere With Engine Noise Interpretation
Pilots rely on auditory cues from the engine and aircraft systems as part of monitoring the aircraft’s performance. Tinnitus can interfere with the ability to discern changes in engine noise or detect unusual sounds that may indicate mechanical issues. This might delay the recognition of potential problems or reduce a pilot’s situational awareness.
Tinnitus Risk Mitigation
To mitigate these risks, pilots with tinnitus should seek appropriate medical evaluation and management. Strategies may include using specialized hearing protection, employing hearing aids if there’s associated hearing loss, or integrating tinnitus management techniques. Training and adaptations in communication practices, such as using text-based ATC communications where available, can also support affected pilots. Ultimately, careful management of tinnitus and tailored adaptations can help ensure that pilots with this condition maintain their ability to fly safely and effectively.
What are the FAA’s Hearing Requirements?
While there are no explicit regulations that explicitly ban and outright disqualify or ban tinnitus-afflicted pilots from flying, pilots must meet certain medical standards with respect to their auditory capability before they can be medically cleared to fly.
Of particular concern to the FAA would be any hearing loss or hearing impairment that is the direct result of tinnitus, or if your tinnitus is severe enough to the extent that it has the potential to lead to partial or total hearing loss or even hearing discrimination loss.
Pilots must undergo the hearing tests that are a standard part of the AME-administered comprehensive medical exam, which is required in order to obtain your medical certificate.
The FAA has published a set of guidelines on how the hearing test must be conducted and what the expected range of acceptable results should be.
If you would like more in-depth information on the FAA’s requirements for hearing, you may want to check out this resource that we have published.
| Hearing Requirement | Explanation of Requirement |
|---|---|
| Hearing Communications | The pilot must have the ability to hear radio, voice, and signal communications. |
| Understanding Spoken Words | The pilot must have the ability to understand words spoken at a normal, conversational level, whether the engine is on or off, the airplane is in the air or on the ground, and with the engine at all power settings (idle to maximum). |
| Estimating Glide by Sound | The pilot must have the ability to estimate glide by sound in relation to airspeed. |
| Recognizing Stall by Sound | The pilot must have the ability to recognize an approaching stall by change in sound in relation to airspeed. (It perhaps goes without saying that the pilot must also be able to hear the stall warning indicator, although that is not specifically called out as a requirement). |
FAA Medical Certification Requirements And Tinnitus
The FAA provides guidelines to AMEs on the application process for pilots to be evaluated for their hearing acuity.
AMEs are advised to refer to this chart, published by the FAA, of middle ear abnormalities.
As far as hearing standards are concerned, here is what the FAA has published with respect to sound levels:
| Ear Condition | 500 Hz | 1,000 Hz | 2,000 Hz | 3,000 Hz |
|---|---|---|---|---|
| Better Ear | 35 dB | 30 dB | 30 dB | 40 dB |
| Worst Ear | 35 dB | 50 dB | 50 dB | 60 dB |
FAA Guidance on Ear Safety
The FAA has published a brochure, Hearing and Noise in Aviation, which outlines:
- the significance of hearing in aviation
- the anatomy of the ear
- the risks of noise-induced hearing loss
- various protection strategies
- standards for pilots
It further elaborates on the following topics:
- the importance of hearing for situational awareness
- various causes of hearing loss
- how noise levels in aviation can affect hearing
- how to use hearing protection effectively
- specific conditions that affect hearing
- the FAA’s standards and tests for hearing acuity in aviators.
This brochure is intended to raise awareness and offer guidance on preserving hearing health in the aviation environment, and is a must-read for any pilot who may have any concerns about hearing and aviation.
Medical Certification Standards For Pilots
All pilots are required to undergo a medical exam and must earn a medical certificate in order to be legal to pilot an aircraft. The table below lists the different types of medical certificates available to pilots, what they are good for, and their validity period.
| Flight Privileges | Class of Medical Certificate | Federal Aviation Regulations Concerning Ear, Nose, and Throat Health | Validity Period |
| Airline Transport Pilot | 1st Class | 14 CFR 67.105(c) | 12 months, if under the age of 40. 6 months, if over the age of 40. |
| Commercial (Non-Airline) Pilot | 2nd Class | 14 CFR 67.205(c) | 12 months |
| General Aviation / Private PIlot | 3rd Class | 14 CFR 67.305(c) | 60 months, if under the age of 40. 24 months, if over the age of 40. |
| Recreational Pilot | BasicMed | 14 CFR Part 68 | 48 months |
Special Issuance Medical Certification For Tinnitus
If your tinnitus is severe enough that you are unable to pass a hearing test, and are thus denied a medical certificate, all is not lost:
You may apply for what is known as a Special Issuance Medical certificate.
Unlike a standard medical certificate, which is typically issued on-the-spot by an AME upon successful completion of a medical exam, the special Issuance Medical certificate gives pilots an “alternative pathway” to work towards overcoming their medical issue, and thus being able to obtain their medical certificate.
Essentially a “special Issuance” medical certificate is a deferred medical clearance that is contingent upon the patient taking the necessary steps to overcome the issue, be it in the form of a medication regimen, surgery, or some form of rehabilitative therapy.
The FAA has a comprehensive guide that explains how the Special Issuance medical certification process works.
This process requires extra evaluations and tests to ensure the pilot can manage their tinnitus while flying safely.
Medical experts evaluate the pilot’s tinnitus, focusing on how it affects their flying. They review medical history, conduct audiometric tests, and consult specialists. This helps determine the tinnitus’ impact.
Qualifying pilots who can fly safely with tinnitus get a special issuance medical certificate. This certificate permits them to fly, subject to FAA-imposed conditions or restrictions.
The process includes an appeals option for FAA medical decisions. Denied pilots can challenge the ruling by presenting more evidence. Each appeal is examined individually, with all provided medical information considered.
Pilots must learn about the medical waiver process and the requirements for a special certificate. Collaborating with an aviation medical examiner or FAA specialist is key. It boosts the chances of gaining the necessary certification.
Understanding this certification process is vital for pilots with tinnitus aiming to keep their careers. Through following procedures, passing evaluations, and submitting the needed documents, pilots show they can safely fly despite tinnitus.
Statement of Demonstrated Ability and Tinnitus
Pilots facing medical challenges, including tinnitus, may alternatively secure a Statement of Demonstrated Ability (SODA) from the FAA to keep flying, in lieu of Special Issuance certificate. This authorization measures if pilots with medical issues can safely manage an aircraft.
The evaluation for those with tinnitus includes a thorough review of their medical history and audiometric tests. Experts in aviation medicine also provide input. This assessment examines how tinnitus affects a pilot’s hearing, communication, and flight abilities.
A SODA is vital for a pilot’s career, offering the proof needed to meet regulatory standards despite tinnitus. Pilots holding a SODA must abide by designated restrictions and undergo periodic reviews to maintain cockpit safety.
To obtain a SODA, pilots face an extensive process that examines their medical state and how it impacts flight duties. The FAA assesses tinnitus severity, its influence on communication, and the pilot’s competency under various flying conditions.
Case Study: A Fighter Pilot With Tinnitus
To illustrate the real-world challenges pilots with tinnitus face, we delve into the real-life case study of Randy Spear, a fighter pilot who had begun experiencing tinnitus, which threatened his flying career and passion for piloting.
Despite the constant, high-pitched ringing in his ears, Randy refused to let tinnitus ground him. Seeking help, he turned to specialized treatment focused on tinnitus management, which included sound therapy and lifestyle modifications aimed at minimizing the condition’s impact.
Through perseverance and the right support, Randy successfully managed his tinnitus, ensuring it didn’t interfere with his ability to fly. His story is a testament to overcoming adversity, demonstrating that with determination and the proper treatment, pilots with tinnitus can continue their successful careers in aviation.
Long-term Risks: Tinnitus and Noise-Related Fatigue in Aviation
Chronic Exposure to Aircraft Noise and Tinnitus Development
Pilots face significant risks due to chronic exposure to loud aircraft noise. This exposure can negatively affect hearing health, leading to tinnitus. Tinnitus manifests as a persistent ringing or buzzing in the ears. Long-term exposure in aviation can harm inner ear structures, triggering tinnitus. This can irreversibly damage the auditory system, diminishing pilots’ quality of life and cockpit performance.
How Tinnitus Affects Cockpit Communication and Safety
Tinnitus presents communication and safety challenges in the cockpit. The constant noise in the ears can disrupt the clarity of radio communications and crew directives. It hampers pilots’ ability to intercept crucial flight operations sounds. Consequently, this impairs their coordination with air traffic control, raising safety risks.
This condition also leads to increased fatigue and mental stress for pilots. The incessant sound intensifies stress, affecting concentration, decision-making, and performance. Recognizing and managing tinnitus is crucial for aviation professionals. t ensures personal and crew safety by maintaining optimum job performance.
Prevention over Cure: Avoiding Tinnitus in the Cockpit
When dealing with tinnitus, prevention is key. Pilots must take proactive steps to shield their hearing. This involves reducing noise exposure significantly. Utilizing noise reduction strategies and effective hearing protection is crucial. Such actions diminish the chances of tinnitus, ensuring a safer flying experience.
An ounce of prevention is worth a pound of cure.
Employing a few strategies can make a big difference in the cockpit, and can go a long way in terms of preventing the onset of tinnitus, or at the very least, prevent it from getting worse if you already suffer from it:
| Implement noise reduction measures | Utilizing noise-cancelling headsets and adding sound insulation helps lower noise levels. This is vital for preventing hearing damage in the long term. |
| Use suitable hearing protection | High-quality earplugs or earmuffs made for aviation professionals are crucial. They reduce noise without hindering communication or awareness of surroundings. |
| Manage noise exposure | Stay aware of noise levels both in and out of the cockpit. Limit exposure to loud sounds and take breaks, allowing your ears time to recuperate. |
| Adopt best practices for cockpit noise control | Use intercom systems and clear communication techniques. These methods alleviate ear strain and improve communication. |
Taking these preventive actions seriously aids in protecting your hearing health. This is pivotal for a successful career in aviation without the threat of tinnitus.
Your hearing is precious and cannot be replaced. Guard it against excessive noise and be vigilant in your efforts against tinnitus.
Pilot Health and Noise Levels: Identifying Safe Limits
Understanding the relationship between pilot health and noise levels is crucial for ensuring the well-being of aviation professionals. Excessive noise exposure can have detrimental effects on pilots, both in the short term and long term. By identifying safe noise limits and implementing appropriate measures, pilots can protect their hearing and overall health.
Decibel Levels in Cabin vs. Cockpit
Decibel levels can vary significantly between the cabin and cockpit areas of an aircraft. While passengers in the cabin may experience noise levels ranging from 70 to 90 decibels (dB), pilots in the cockpit can be subjected to noise levels exceeding 100 dB. This discrepancy is primarily due to the proximity of the cockpit to the engines and other noise sources.
Prolonged exposure to noise levels above 85 dB can lead to hearing damage and other health issues. Thus, pilots need to be aware of the noise levels they are exposed to. They also must take appropriate precautions to mitigate the risks.
OSHA Standards vs. Pilot Noise Exposure
The Occupational Safety and Health Administration (OSHA) has set limits for noise exposure to protect workers in various industries. According to OSHA standards, the permissible exposure limit (PEL) for an 8-hour workday is 90 dB. However, these standards may not directly apply to pilots due to the unique nature of their work environment.
Pilots often face noise levels that exceed OSHA’s PEL, especially during takeoff and landing. It’s crucial for pilots to understand the potential risks associated with noise exposure. They should take proper measures to protect their hearing.
Implementing noise reduction measures, such as using properly fitted headsets and using quieter aircraft models, can help. Regular monitoring of noise levels and periodic hearing screenings are also vital. They help in identifying early signs of hearing damage and taking necessary preventive actions.
Technical Insights: Aircraft Noise and Its Measurement
To truly understand aircraft noise and how it’s measured, we must delve into the tools and methods used. These enable a thorough assessment of noise levels in aviation. Understanding these elements allows us to grasp the noise’s effect on pilot health. It also leads us to find methods to protect their hearing.
The Role of Headsets in Protecting Pilot Hearing
The right headsets are crucial for shielding pilots from noise. Pilot headsets reduce the noise’s impact, acting as a barrier for the pilot’s hearing. These devices are crafted to lessen noise passively, diminishing the sound that reaches the ears.
Many modern headsets include active noise reduction (ANR) technology. ANR headsets use microphones to pick up ambient noise and generate opposing signals to cancel it out. This technique further lowers the noise level, adding a vital protection layer in loud settings.
ANR headsets are especially good at cutting down low-frequency noise, like that from engines. By targeting these frequencies, they reduce noise-induced fatigue. This makes for a more comfortable flight experience for pilots on long journeys.
There are a number of headsets available for purchase through PilotsHQ.
Implementing Active Noise Reduction Techniques
Beyond headsets, the aviation sector uses other active noise reduction strategies. These methods involve engineering solutions that tackle noise at its source or block it from reaching the cabin or cockpit.
Some active noise reduction examples include:
- Enhanced engine and nacelle designs lead to quieter aircraft through better acoustic lining and optimized components.
- Cabin insulation and acoustic treatments in cabins and cockpits reduce noise from the outside, creating a calmer environment for pilots.
- Ground procedures aimed at lowering noise, like reducing engine run-ups near communities or opting for ground power units, help limit noise pollution.
Through a mix of these techniques and the right headsets, the aviation industry works to protect pilot hearing. It aims for a quieter, more comfortable cockpit atmosphere.
Personal Protection: Best Practices for Reducing Noise-Induced Tinnitus
In this section, pilots will find valuable advice on safeguarding themselves against noise-induced tinnitus. It’s vital for pilots to look after their hearing health. They must shield their ears from high noise levels in the cockpit.
To guard your hearing, consider hearing protection devices (HPDs) made for aviation experts. These devices help mitigate loud cockpit noises. They lower the chances of tinnitus and other auditory problems.
HPDs come in various forms:
| Earplugs | These small, ear canal inserts block out loud sounds effectively. |
| Earmuffs | Covering the entire ear, they act as a barrier against noise. |
| Active Noise Reduction (ANR) headsets | These headsets use technology to cancel cockpit noise, offering a quieter setting. |
Choosing the right HPDs involves selecting ones with the proper noise reduction rating (NRR). They should also be comfortable for long wear. Pilots should seek advice from audiologists or health professionals to find the best HPDs for them.
Aside from HPDs, pilots must also use strategies to manage cockpit noise. This consists of:
- Ensuring aircraft parts are well-maintained and insulated to lessen noise.
- Using noise-cancelling systems for clearer communications without needing to shout.
- Adjusting cockpit designs to reduce noise reflection and increase dampening.
Actively reducing cockpit noise can forge a quieter, more focused work environment. It cuts the risk of developing noise-induced tinnitus.
To maintain hearing health, a proactive stance is essential. Regular hearing checks help track any hearing loss. Breaks from loud settings, practicing effective communication to avoid yelling, and healthy living contribute to hearing preservation.
Guarding your hearing is notjust crucial for career success but for overall quality of life. By adhering to these guidelines to lessen noise-induced tinnitus risks, pilots can secure a healthy and rewarding career in aviation without compromising their hearing.
When to Seek Medical Advice: Symptoms of Hearing Loss and Tinnitus in Pilots
For pilots, recognizing hearing loss and tinnitus symptoms is critical for timely medical care. This vigilance allows pilots to confront health concerns and maintain safety in flight.
Telltale Signs: Difficulty Understanding Speech and Avoiding Social Interaction
Symptoms of hearing loss include the struggle to grasp speech. Pilots might have a hard time hearing cabin announcements or engaging with air traffic control. This may lead them to shun social gatherings due to conversation difficulties.
Tinnitus is marked by hearing non-existent noises like ringing or buzzing. These sounds distract pilots mid-flight, harming their focus and ability to heed crucial sounds.
Pilots must recognize these symptoms of hearing loss and tinnitus. Noticing any hearing changes or symptoms prompts seeking medical guidance. Early consultation helps identify causes and secures treatment.
The Emotional and Physical Toll of Flight-Induced Hearing Loss
Flight-induced hearing loss affects pilots emotionally and physically. The emotional strain comes from communication troubles, affecting their career and life quality.
On a physical level, it challenges pilots’ ability to note crucial cockpit noises. Such difficulty endangers situational awareness, risking safety onboard.
The impact of flight-induced hearing loss stretches beyond work, touching pilots’ personal lives. Therefore, prioritizing hearing health is essential, as is seeking medical intervention and adopting preventive steps in their aviation journey.
Sounding off on Tinnitus in Aviation
The effects of tinnitus on pilots’ careers in aviation are intricate, requiring extensive attention. Insights from pilots who suffer from tinnitus illuminate the difficulties they encounter, impacting their well-being and performance. Understanding FAA regulations and medical certification rules regarding tinnitus is crucial. These stipulations significantly affect their ability to fly.
To mitigate tinnitus risks, pilots must focus on their health and cockpit safety. Using proper headsets and hearing protection can greatly reduce noise-induced tinnitus risks. Complying with noise reduction strategies and adopting noise management practices are key to preventing tinnitus.
The relationship between pilot health and regulatory standards is pivotal in the aviation sector. Tinnitus, within the flying domain, demands continued dialogue and research for the creation of thorough guidelines and support structures for pilots. Prioritizing the health of aviation professionals ensures a more secure, health-conscious flying environment for both pilots and passengers.
FAQ
Can pilots fly with tinnitus?
What is tinnitus?
What are the FAA regulations regarding pilots with tinnitus?
What are the medical certification requirements for pilots with tinnitus?
What is the special issuance medical certification process for pilots with tinnitus?
What is a Statement of Demonstrated Ability (SODA)?
Can you provide a case study of a pilot with tinnitus?
What are the long-term risks of tinnitus for pilots?
How can pilots prevent tinnitus?
How do pilots balance their health and regulatory requirements?
What are the noise exposure limits for pilots?
How is aircraft noise measured, and what role do pilot headsets play?
How can pilots protect themselves against noise-induced tinnitus?
What are the symptoms of hearing loss and tinnitus in pilots?
Source Links
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- https://www.ecfr.gov/current/title-14/part-67/section-67.105#p-67.105(c)
- https://www.ecfr.gov/current/title-14/part-67/section-67.205#p-67.205(c)
- https://www.ecfr.gov/current/title-14/part-67/section-67.305#p-67.305(c)
- https://www.ecfr.gov/current/title-14/section-68.1
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- https://www.osha.gov/sites/default/files/publications/OSHA3953.pdf
- https://www.pilotdiscovery.com/pilotshq