Not having seen your side of 40 for more than 20 years, I don't get the benefit of the 60 and didn't get the benefit of the 36 either. But I would caution you regarding the assumption of retroactivity, unless the regulation specifically states that the extension of time applies to all medical certificates valid on the date of effectiveness of the new regulation. If yes, The question then becomes was your medical current on the date of the change. If no, Then the answer is presume expiration in 2010. Remember it does not have to say retroactive, but it must apply to all medical certificates in force at the time of the change.