Disappointing: FAA Fails to Mandate EpiPens

FAA Fails to Mandate EpiPens

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The FAA won't mandate EpiPens in airlines' Emergency Medical Kits (EMKs) despite the urging of doctors, lawmakers, and allergic passengers and their families. Over thirty million Americans have at least one food allergy, and more than forty percent of children with food allergies have experienced a severe allergic reaction, such as anaphylaxis.

Nevertheless, the FAA, in its recently published and misnamed “Improving Emergency Medical Kit Efficacy and Flexibility in Commercial Airline Operations” proposed rule is going backwards, by not requiring the airlines to carry Epipens or even specific medicine or equipment, and instead allowing the airlines to stock their kits as they see fit, in order to treat the following nine medical emergencies:

  • Chest pain and cardiac emergencies
  • Airway and breathing emergencies
  • Loss of consciousness
  • Major bleeding
  • Opioid overdose
  • Hypoglycemia
  • Gastrointestinal emergencies
  • Anaphylaxis
  • Childbirth

While the FAA's justification for being less prescriptive and more flexible in its approach is ostensibly to “end the practice of processing and granting exemptions to operators when there are medication shortages in the market affecting the availability of EMK contents” the real benefit for airlines is that, without specific EMK requirements, they can be stingier in terms of what they carry, potentially shaving some dollars off these kits, at the risk of human suffering and lives. Penny-wise, pound foolish.

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Why EpiPens are Needed

Let's start with the obvious: an airline carrying epinephrine in a vial that must be measured, dosed, and injected by a doctor or other medical professional (instead of EpiPens) creates significant risk that, if a passenger suffers an anaphylactic reaction, s/he will needlessly suffer and is more likely to die. There may be no doctor or medical professional on board. If there is a doctor on board, s/he may not volunteer to assist, and there is no requirement that s/he does so.

By contrast, an EpiPen is meant to be administered by a layperson, and it takes just seconds to read and understand how to correctly administer it (after removing it from its case, jab it forcefully into the patient's outer thigh and hold it there at least 3 full seconds (call it 6, to be on the safe side) to ensure the patient receives the complete dose.

Many non-allergy sufferers remain indifferent, but they shouldn't be: it's very possible for an adult to develop a new anaphylactic allergy to a substance s/he was never previously allergic to. Ask my husband, who landed in the hospital in his twenties due to an anaphylactic reaction to something he's never previously had an allergy to. If this had happened on a flight, he most likely wouldn't have survived.

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What You Can Do

If you feel strongly about the proposed rule, please comment on the Regulation Web site.

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