Summary
Commercial companies are preparing to send people to live on stations in low Earth orbit and on the surface of the Moon. Many of these missions fall outside the activities that existing licensing regimes were designed to cover. The Office of Space Commerce’s Space Commerce Certification proposal, which explicitly covers lunar missions and commercial space stations, is one of the most promising efforts to close that gap.
The stated goal of the certification is to give novel commercial missions a clear, predictable path to authorization. That is a worthy goal. Our comments focus on one group of systems the pilot should account for from the start: the crew health and habitation systems that keep people alive and well on long missions.
Human physiology degrades in microgravity on a timescale with no terrestrial equivalent. Astronauts lose bone at about 1 to 1.5 percent per month, and NASA’s Human System Risk Board tracks 29 risks to crew health.1 In August 2026 the White House named crewed spaceflight enablers a critical and emerging technology for national security.2 A certification framework that treats these systems as an afterthought would leave the riskiest part of a crewed mission without a clear path forward.
For these reasons, we recommend that future rounds of the pilot explicitly include crew health and habitation missions. We summarize our reasoning below.
Crew systems fall between the gaps
Crew health and habitation technology sits between several existing authorities. Launch and reentry licensing covers the vehicle. Medical device regulation covers equipment used on Earth. Neither was written for an ultrasound system built into the wall of a lunar habitat, or a training device used during a months-long stay in orbit.
Today, NASA programs carry most of this risk on their own missions. As commercial stations and lunar operators take on crews of their own, the question of who authorizes these systems, and against what standard, will become pressing. A certification pathway that names them now would give companies a standard to design to, rather than a gap to work around.
The gap is widest for systems that sit inside the habitat rather than on the vehicle. Launch licensing focuses on public safety during ascent and reentry. It does not address what happens to a crew over weeks or months once they arrive, and it was never meant to. Medical device rules assume a clinic, a trained operator and a patient who can be sent to a hospital. On a lunar base, the crew member is often both the operator and the patient, the nearest hospital is days away, and the device has to work in partial gravity, in dust and on limited power.
The same is true of habitation systems that affect health indirectly. Sleep quarters, lighting, noise control, waste systems and exercise hardware shape bone and muscle loss, sleep, mood and teamwork over a long mission. None of them is a medical device, and none of them is part of the launch vehicle. Today they are judged mission by mission, against requirements written by each program, with no shared standard a company can build to.
For companies, that uncertainty shows up early. A team designing a crew health system cannot tell which tests it will need, which agency will review it, or whether evidence gathered for one operator will count for another. Each new customer can mean repeating the same validation work. A single, published pathway that recognizes these systems would let one body of evidence serve many missions, and would let smaller companies compete with established suppliers on the merits of their hardware.
Certainty is what lets crew health technology get built
Crew health systems take years to mature. They move through laboratory testing, analog habitats on Earth, parabolic flights and orbit before they are ready to fly, and they stall most often between TRL 4 and TRL 6, where research funding ends and flight programs have not yet committed.
In a September conversation at Evermay, a researcher at the Johns Hopkins Applied Physics Laboratory, which leads NASA’s Lunar Surface Innovation Consortium, described the problem as two hard cuts: one at TRL 3, where research support ends, and one at TRL 6, where mission programs begin. The gap between them is less a shortage of money than a mismatch with mission pull. A clear authorization pathway is one way to create that pull before a mission program commits.
Companies and investors will only carry that work if they can see the path to authorization at the end of it. A clear, published standard for what a crew health or habitation system must demonstrate, and when, is what allows a team to hire, plan its testing and raise capital against a defined goal.
Uncertainty about whether a system will be authorized has the same effect as uncertainty about whether it will be funded: rational actors price in the risk or decline to start.
If a team cannot reasonably expect its system to be authorized once it meets a published bar, the hardest and most valuable crew health work will be the first to go unfunded.
Expert review should lead
Judging whether a crew health system is safe depends on specialized knowledge in human physiology, medicine and life support. We recommend that certification reviews for these systems draw directly on that expertise, including NASA’s human research community, flight surgeons and life support engineers, and that their recommendations carry real weight in the decision.
Reviews should also be proportionate to risk. A sensor that records data poses a different level of risk than a system that keeps a crew breathing. Matching the depth of review to the consequences of failure would keep the process fast for lower-risk systems and rigorous where it matters most.
Including crew systems would make the program stronger
Including crew health and habitation missions in a future round would test the certification against the hardest cases early, while the framework is still being shaped. It would also build a record of how the body performs in altered gravity on commercial missions, a record that no single program currently holds.
We recommend that the Office of Space Commerce:
- Include crew health and habitation missions in the next round of the pilot.
- Publish what these systems must demonstrate to be certified, tied to defined test stages.
- Draw on NASA’s human research community and clinical experts in reviews, in proportion to risk.
- Set clear rules for how crew health data collected on commercial missions is stored and protected.
Conclusion
The Space Commerce Certification is a chance to give commercial human spaceflight a durable foundation. Crew health and habitation systems decide how long people can stay in space and how well they come home.
We urge the Office of Space Commerce to bring crew health and habitation systems into the certification early, with clear standards and expert review. It would make the certification stronger and the missions it covers safer.