PUBLICATIONS

FAA Issues COVID-19 Interim Health Guidance for Air Carriers and Crews

Date   Mar 19, 2020

Note, SAFO 20003 has been cancelled and replaced by SAFO 20009

Executive Summary: On March 12, 2020, the Federal Aviation Administration (FAA) issued a Safety Alert for Operators (SAFO 20003) that provides interim health guidance for Air Carriers and Crew Members regarding COVID-19. The Centers for Disease Control and Prevention (CDC) and FAA provided this guidance for air carriers and crews to protect crewmembers from exposure and reduce the risk of transmission of COVID-19 onboard aircraft or through air travel.

Background: The CDC is responding to an outbreak of respiratory illness (COVID-19) caused by a coronavirus (SARS-CoV-2) which has now been detected in more than 100 locations internationally, including the United States. Air carriers and crews conducting flight operations that have a nexus to affected countries should be particularly aware of potential exposure and should follow the associated CDC and FAA health guidance.

Recommended Action: The FAA has recommended that crewmembers who are on layovers internationally or in the United States stay in their hotel rooms to the extent possible, limit their activities in public, and practice social distancing. Social distancing means avoiding crowded places, not going to mass gatherings, and, generally staying about 6 feet (2 meters) from others, when possible.

Air carriers are encouraged to remind crewmembers that they should pay attention to their health at all times and remain in communication with their occupational health programs. The FAA and CDC recommend that crewmembers take their temperature twice a day (morning and evening) while working and monitor themselves for fever, cough, or difficulty breathing. If crewmembers develop any of those symptoms, they should immediately self-isolate and be excluded from work on flights until cleared by public health authorities. Crewmembers with high-risk exposures to COVID-19 (defined as exposure to a sick household member or intimate partner, or providing care in a household to a person with a confirmed case of COVID-19) may also need to be excluded from work until no longer at risk for becoming infectious.

Recommendations for housing flight and cabin crews on layovers (in the United States or internationally):

  • Arrange to move crewmembers as a group between the airport and the hotel aboard private ground transport that has been sanitized in advance.
  • Advise your crews to avoid public transport unless it is an emergency.
  • Arrange to house flight crews in hotels that are in close proximity to the airport.
  • Ensure that the hotel rooms are sanitized in advance of the crews’ arrival.
  • Provide crew with at least a 60% alcohol-based hand sanitizer.
  • Encourage crews to:
    • Avoid contact with sick people
    • Stay in their hotel rooms to the extent possible
    • Minimize going out into the general population
    • Use social distancing (maintain a distance of approximately 6 feet, if possible) whenever out in public
    • Avoid crowds, stores, sporting or mass entertainment events, and other situations likely to attract large numbers of people
    • Eat in their hotel rooms with either room service or delivery service.
    • If in-room dining options are not available, they should eat at a restaurant located in or close to the hotel.

The Bottom Line: The current situation is very fluid, especially for air carriers and their employees. Regardless of residence or travel history, crewmembers who have known exposure to persons with COVID-19 should be assessed and managed on a case-by-case basis. Crewmembers with high-risk exposures may need to be excluded from work. Air carriers should develop a plan in the event a crewmember becomes symptomatic during an overnight layover or while at home and know how to contact public health authorities in locations where crew remain overnight.

If you have any questions regarding this Alert, please feel free to contact the Alert’s authors, Jacki Thompson, who is a partner with FordHarrison, at jthompson@fordharrison.com, Jeff Bennett, who is a consultant with F&H Solutions Group at jbennett@fhsolutionsgroup.com, or the FordHarrison Airline attorney with whom you work.

FordHarrison is closely monitoring the spread of Coronavirus and has implemented continuity plans, including the ability to work remotely in a technologically secure environment when necessary, to ensure continuity of our operations and uninterrupted service to our clients. We are following all CDC guidelines and state and local laws as applicable. We are committed to ensuring the health and welfare of our clients, employees, and communities while continuing to provide our clients with the highest quality service. Please see our dedicated Coronavirus Taskforce page for the latest FH Legal Alerts and webinars on Coronavirus, as well as links to governmental and industry-specific resources for employers to obtain additional information and guidance.