FAA Seeks Feedback on Vaccines and Dry Ice Shipped by Air

The Federal Aviation Administration (FAA) is seeking approval of a new information collection request (ICR) related to air transport of COVID-19 vaccines.

Some of the vaccines are temperature sensitive and shipped with large quantities of dry ice. The new information collection request would allow FAA to hear directly from air carriers involved in transporting COVID-19 vaccines.

Dry ice is a solid form of carbon dioxide, which changes state directly from a solid to a gas (i.e., sublimates) at temperatures as cold as -78 degrees Celsius. Aboard an aircraft, there is a risk that gaseous CO₂ will replace the oxygen on board and create an asphyxiation hazard for passengers, employees, and ground crew who load and unload cargo containers.

This risk is the major reason that dry ice is regulated as a hazardous material in air transportation.

FAA released a Safety Alert for Operations (SAFO 20017) concerning dry ice shipped by air in December 2020.

What is an Information Collection Request?

An information collection must be approved before the government can require a private entity or individual to report data, fill out a questionnaire, or record details of their operations. This is true even if responding to the request is voluntary.

Information collection requests that apply to hazmat shippers and transporters include things like registration with DOT, hazardous materials security plans, hazmat incident reports, shipping paper retention, and more.

For the regulated community, compliance with “paperwork” requirements takes time and effort. For each ICR, the agency (FAA in this case) estimates the total “burden hours” they are imposing on businesses or individuals.
Agencies also estimate the total number of regulated persons who are expected to respond.

For the newly requested ICR, FAA estimates that thirty-nine air carriers will spend five hours each responding to the questions FAA poses about shipping COVID-19 vaccines with dry ice.

What’s In the New ICR?

According to FAA’s proposal in the February 17 Federal Register, six questions will comprise the initial information collection:
 

1. Did the volume of vaccines transported per pound of dry ice increase over the duration of the COVID-19 pandemic? Please provide data that captures the change. 

2. Were there observed lower sublimation rates due to improved packaging technology or other factors, and to what factors do you attribute these lower sublimation rates?

3. What risk mitigations have you utilized to enable safe and efficient air operations with large than normal quantities of dry ice?

4. Was there anything that limited your ability to transport COVID-19 vaccines efficiently while maintaining aviation safety? if so, please describe. 

5. What are key takeaways or accomplishments from the COVID-19 vaccine transportation effort over the past year that show the value of working closely with shippers, airframe manufacturers, and the FAA for data-driven safe and efficient operations?

6. What additional regulations, minimum standards, guidance, or other information would you like to see concerning air transport of dry ice?

Because this is an "emergency" action related COVID-19, there will be no public comment period for this proposal.

How to Ship Dry Ice By Air

If you ship dry ice by air, hazmat training is required for employees who can affect the safety of your shipments in transportation (see 49 CFR 172.704).

For personnel who package, mark, label, load, document, or sign shipping papers for dry ice shipments, the Shipping Dry Ice Online Course is built to satisfy hazmat training requirements in 49 CFR, the IATA DGR, and the IMDG Code. 

Ship infectious substances? The Shipping Infectious Substances (w/ Dry Ice) online course provides required hazmat training for employees who prepare infectious substances for transportation by ground or air (with or without dry ice) 

Tags: DOT compliance, hazardous materials, hazmat air shipping, how to ship dry ice, IATA DGR