The FAA in a pro-active effort with other U.S. government agencies, air carriers, and other aviation stakeholders have established a multi-disciplinary team in a coordinated approach to use existing FAA policies and procedures to explore and address potential harm/hazards that could arise from Transportation of Covid-19 Vaccines.
The storage of several vaccines requires continued cold temperatures during transport, which may require dry ice (a hazardous material) to maintain very low temperature. The FAA works with manufacturers, air carriers and other aviation stakeholders to provide guidance on implementing current regulatory requirements for safely transporting large quantities of dry ice in air cargo as well as recommended safety practices and regulations to be implemented.
As part of U.S. Department of Transportation's overall efforts, the FAA established the FAA COVID-19 Vaccine Air Transport Team in October 2020 to aid in the safely and efficient transportation of vaccines in a timely manner, carried out tests of samples of vaccine packaging containing dry ice to better understand potential changes in dry ice sublimation rates in the air carrier operational environment (i.e., at altitude and during ground operations).
The testing also considered sizes of dry ice pellets to be used and how transportation operations would affect the dry ice sublimation rate. The objective is to ensure that air carriers understand the potential risks, safety risks & assessments and corresponding mitigations when considering dry ice limits. The FAA plans to publish the test results once the agency's analysis is complete. Initial findings have been summarised in a Safety Alert for Operators (SAFO 20017).
"The FAA's testing is not intended to replace testing that packaging manufacturers perform, or the safety risk assessments of air carriers. Packaging manufacturers have the ultimate responsibility to ensure that stated sublimation rates and testing parameters are captured and communicated to entities that use their packaging."
When preparing to transport large amounts of dry ice associated with the COVID-19 vaccine, operators should consider the information in this SAFO. Additionally, operators with an approved Safety Management System must conduct safety risk assessments in accordance with their approved Safety Management System. Operators without an accepted SMS should conduct a safety analysis and apply appropriate risk mitigations.
Also, precautionary measures and simple rules of thumb as recommended (Advisroy circular 91-76A - Hazard Associated with Sublimation of Solid Carbon-Dioxide (Dry Ice) Aboard Aircraft) to eliminate environmentally hazardous conditions affecting crews and passengers aboard aircraft.
Parnda Hedima is a commercial Pilot, Aviation, Business/IT & Research consultant. For inquiries and Consultation please contact (239) 227-5768.
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