Staff Instruction (SI) No. 404-002

Subject: Civil Aviation Medicine Cannabis Policy

Issuing Office: Civil Aviation, Medicine
Document No.: SI 404-002
File Classification No.: Z 5000-32
Issue No.: 01
RDIMS No.: 15099194
Effective Date: 2019-06-03

Table of contents

1.0 Introduction

1.1 Purpose

  • (1) The purpose of this Staff Instruction (SI) is to provide policy guidance on cannabis use for the purposes of medical certification and education of flight crew and controllers.

1.2 Applicability

  • (1) This SI is applicable to Transport Canada (TC) Civil Aviation Medicine (CAM) Branch personnel, contractors, Civil Aviation Medical Examiners (CAMEs), and other personnel appointed by the Director Civil Aviation Medicine (DCAM) to be involved in aeromedical risk-based decision-making related to the assessment of Medical Certificate (MC) applications.

1.3 Description of changes

  • (1) None in this version.

2.0 References

2.1 Reference Documents

2.2 Cancelled Documents

  • (1) Not applicable.

2.3 Abbreviations

  • (1) Below are the related terms for the following abbreviations:
    • (a) ATC: Air Traffic Controller
    • (b) CAM: Civil Aviation Medicine
    • (c) CAME: Civil Aviation Medical Examiner
    • (d) CARs: Canadian Aviation Regulations
    • (e) DCAM: Director of Civil Aviation Medicine
    • (f) DSM: Diagnostic and Statistical Manual of Mental Disorders
    • (g) GoC: Government of Canada
    • (h) MC: Medical Certificate
    • (i) TC: Transport Canada

3.0 Background

  • (1) As of 17 October 2018, Cannabis became legal in Canada, both for recreational and medical purposes, by virtue of the Cannabis Act and the new regulations that replaced the Access to Cannabis for Medical Purposes Regulations. Whether used recreationally or medically, cannabis has potential to cause impairment and adversely affect aviation safety.
  • (2) The TC prohibition on impairment, whether caused by cannabis or any other substance, remains unchanged. Specifically, CARs 602.02, 602.03, and 801.01 require fitness for duty and direct that no person shall act as a crew member of an aircraft, ATC, or flight service specialist while using any drug that impairs the person’s faculties to the extent that aviation safety is affected. Standard 424 also requires that all MC holders be free of any abnormalities or effects/side-effects of prescribed or non-prescribed medications that would interfere with the reliable function of duties.
  • (3) In the context of cannabis legalization, CAM has developed cannabis policy to guide medical certification of MC applicants. With preservation of aviation safety as the prime consideration, the CAM cannabis policy is evidence-informed, practical, acceptable to stakeholders, legally defensible, consistent with similar policies of other GoC departments, and aligned with the overall GoC philosophy on cannabis. The guidance supports self-disclosure of cannabis use by applicants and also provides the basis for educating aviators and controllers to enable accurate self-assessment of fitness for duty.
  • (4) For the purposes of the CAM cannabis policy, cannabis use is defined as the use of any cannabis product or derivative by any delivery method for any purpose.

4.0 Cannabis Policy

4.1 Medical Certification

  • (1) In accordance with CARs Standard 424.04 (1) and CARs 404.06(1), no MC shall be issued or renewed, and no existing MC shall be used to exercise the privileges of a permit, licence or rating for any person:
    • (a) With a confirmed or suspected diagnosis of Cannabis Use Disorder (or other Substance Use Disorder with concurrent cannabis use) which has not been assessed and/or treated satisfactorily according to CAM;
    • (b) With a problematic pattern of cannabis use which may affect aviation safety or interfere with the reliable function of duties;
    • (c) Who has not been abstinent from cannabis use for at least 28 days; or,
    • (d) With any persistent impairment related to cannabis use.
  • (2) In accordance with CARs 404.04 (2) and (3), in order for CAM to assess issuance or renewal of a MC, persons who disclose or who are suspected of using cannabis shall be asked to provide additional information including:
    • (a) Past or current diagnoses of Cannabis Use Disorder or any other Substance Use Disorder, including treatment, monitoring, remission status, and relapses;
    • (b) Any substance-related problems, such as impaired control, social impairment, risky use, legal or occupational problems, tolerance, withdrawal, or other concerning features (such as DSM substance-related disorder diagnostic criteria);
    • (c) Details of current cannabis use, including type of product, frequency, dose, delivery method, and reason for use;
    • (d) Any underlying medical conditions for or related to cannabis use;
    • (e) Any use of other medications or substances likely to interact with cannabis; and,
    • (f) The results of any additional physical examination, assessment, or testing required by CAM.

5.0 Education of Flight Crew and Controllers

  • (1) The CAM cannabis policy serves as the basis for educating flight crew and controllers to enable self-assessment of fitness to fly and voluntary disclosure of cannabis use. In addition to other general information on cannabis and its effects available through the GoC, the following information and caveats are provided to assist in the education of flight crew and controllers.
  • (2) Key Messages:
    • (a) The CAM cannabis policy is a practical, administrable, and minimally invasive approach that is concerned first and foremost with the preservation of aviation safety.
    • (b) The CAM cannabis policy supports safe recruitment into and return to aviation by enabling and destigmatizing the discontinuation of cannabis use. It provides potential pathways to medical certification/recertification which include:
      • (i) Discontinuing cannabis use at least 28 days before flying or controlling duties;
      • (ii) Successful treatment of a Cannabis Use Disorder or other Substance Use Disorder; and,
      • (iii) Successful resolution or change in treatment of other health conditions previously treated with cannabis.
    • (c) The CAM cannabis policy is based on the well-established aeromedical concept of a washout period which is already applied to other psychoactive and potentially impairing substances.
    • (d) For infrequent cannabis users, the requirement to be abstinent from cannabis use for at least 28 days before being on duty minimizes the likelihood of:
      • (i) Detectable residual cannabis or active metabolites using current testing methods; and,
      • (ii) Impairing effects likely to affect flight safety.
    • (e) The CAM cannabis policy does not remove the responsibility from aviation industry employers and employees to ensure that all personnel are fit for duty at every duty interval, and that flight crew and controllers self-ground in the event that they might not be fit for duty.
    • (f) The CAM cannabis policy neither guarantees compliance with nor eliminates the requirement for flight crew and controllers to comply with the applicable laws or regulations of other countries in which they might operate.
    • (g) The CAM cannabis policy is subject to change based on new research and information on cannabis that may emerge.

6.0 Information Management

  • (1) Information and records collected in the context of this SI shall be managed in accordance with CAM practices for managing confidential medical information provided in support of Medical Certificate applications.
  • (2) Any records created as a result of the processes described in this SI should be cross referenced with classification number 5820 (Aviation Medicine- General).

7.0 Document History

  • (1) Not applicable

8.0 Contact us

For more information, please contact:
Civil Aviation Medicine
Telephone: 613-993-4772
E-mail: tyler.brooks@tc.gc.ca

We invite suggestions for amendment to this document. Submit your comments to:
Civil Aviation Communications Centre
Telephone: 1-800-305-2059
E-mail: services@tc.gc.ca

Document approved by Samantha Wilson-Clark

Samantha Wilson-Clark
Director, Civil Aviation Medicine

Date modified: