Earlier this week, the FAA issued its Updated Interim Occupational Health and Safety Guidance for Air Carriers and Crews.  The updated Guidance continues to urge that crewmembers who exhibit any symptoms of COVID-19 cease work, and only return after they meet the CDC’s criteria for Discontinuation of Isolation for Persons with COVID-19 Not in Healthcare Settings.  Similarly, the FAA also recommends that crewmembers with known exposure to COVID-19 not work until 14 days after the last potential exposure. While the CDC does have guidance that can permit critical infrastructure workers to return to work before 14 days have passed, the CDC does not recommend allowing crewmembers with known exposures to continue to work, even if asymptomatic, because of the inability of crewmembers to remove themselves from the workplace if they develop symptoms during a flight and the challenges involved in effectively isolating a symptomatic person on board an aircraft.

The FAA also recommends that the CDC guidance regarding masks be followed, although the FAA also warns air carriers and crewmembers to be “mindful of the regulations regarding the use of oxygen masks where the operation requires an oxygen mask to be rapidly placed on the face, properly secured, sealed, and supplying oxygen upon demand.”  The FAA expects air carriers to complete a safety risk assessment and provide guidance to their crewmembers on procedures for the use of masks as they may affect the donning of oxygen masks.

Finally, the FAA “recommends and expects” that all U.S.-based air carriers and crewmembers, all non-U.S.-based air carriers operating flights with a U.S. nexus, and all non-U.S.-based crewmembers on flights with a U.S. nexus implement and use their company-developed COVID-19 preparedness plans and procedures in conjunction with the FAA and CDC occupational health and safety guidance.

The Guidance also contains an updated Appendix with instructions on what issues should be addressed in a COVID preparedness plan and the standards that should be adopted for health monitoring, health protection, minimizing crew exposure, notification requirements for COVID related incidents and response plans.  For example, the Guidance states that for health monitoring of flight crews:

• Crewmembers should monitor themselves for fever (feeling feverish or a measured temperature of 100.4 F or higher), cough, or shortness of breath, or other symptoms of COVID-19:
  • Crewmembers should take their temperature any time they feel sick.
• Crewmembers should stay home or in their hotel room, notify their employer’s occupational health program, and not report to work if they meet any of the following conditions:
  • Develop fever, cough, shortness of breath, or other symptoms of COVID-19, even if mild;
  • Test positive for SARS-CoV-2, even if no symptoms are present; or
  • Are exposed, as defined below, to a sick person with symptoms of COVID-19, even if the person has not been tested for SARS-CoV-2.
• Exposures of concern include:
  • A sick household member or intimate partner;
  • Taking care of a sick person without using personal protective equipment (PPE); or
  • Being within 6 feet (2 meters) of a sick person (including co-workers and passengers) for a prolonged period of time (i.e., 15 minutes or longer).
  • NOTE: Data are insufficient to precisely define the duration of time that constitutes a prolonged exposure. Brief interactions are less likely to result in transmission; however, it is important to consider the person’s symptoms and the type of interaction (e.g., whether the sick person coughed or sneezed directly into the face of the exposed person).
• Crewmembers who are symptomatic, test positive for COVID-19, or have been exposed to a person with COVID-19, should not return to work until cleared to do so by their employer’s occupational health program.
• If a crewmember develops symptoms during a flight, the crewmember should stop working as soon as practicable, put on a surgical mask or a cloth mask, notify the Lead Flight Attendant or Purser, and maintain a distance of (6 feet [2 meters]) from others to the extent possible.

In light of this new update, and the fact that the CDC updated much of its guidance on these issues at various points over the summer, carriers should review their plans and procedures to ensure that they are consistent with current recommendations.

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