FAA ISSUES SAFETY ALERT REGARDING TRANSPORTATION OF COVID-19 VACCINES REQUIRING LARGE QUANTITIES OF DRY ICE
January 17, 2021
On December 10, 2020, the FAA released a Safety Alert for Operators, available here, providing information and recommendations to foreign and domestic carriers that will be transporting COVID-19 vaccines by air, which will require carriers to also carry large amounts of dry ice. The FAA notes that the volume of dry ice needed to be carried to maintain the COVID-19 vaccine may present risks that existing mitigations do not adequately address. To this end, the FAA recommends that carriers with an approved Safety Management System (SMS) 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.
The FAA also recommends that operators consider the following information:
- Aircraft manufacturers provide information on maximum recommended dry ice quantities that the aircraft ventilation can accommodate, depending on the sublimation rate (transitions directly from a solid to a gas).
- Note that dry ice continually sublimates at temperatures higher than -78°C (-108.4°F) under normal atmospheric pressure. At reduced pressures, the sublimation rate of dry ice will increase, all other factors being equal.
- An accurate determination of the dry ice sublimation rate is necessary to determine the correct quantity of dry ice that may be safely transported aboard an aircraft.
- As the dry ice sublimates, a loss of weight occurs, affecting the aircraft center of gravity.
- Dispatch with fully operational Environmental Control Systems, including all air conditioning packs and auxiliary power unit (APU), to enable effective ventilation for ground operations and inflight contingencies.
- CO2 sensors installed or carried in the aircraft or worn by the pilots and other crewmembers will assist the operator and crew in recognizing hazardous concentrations of CO2 and implementing effective risk controls.
- Pilot training on specific conditions and procedures can improve pilot decision-making in the event of a CO2 detector alert or other system abnormalities.
- Maximum ventilation, including during the ground de-icing and anti-icing process, will mitigate CO2 accumulation in the aircraft.
Please let us know if you have any further questions, and we will be happy to assist you.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Andy Orr (aorr@eckertsemans.com or 202-659-6625).
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