FAA Proposed Rule Change Puts Food Allergy Patients at Greater Risk

McLEAN, Va.—Aug. 5, 2026—Following passage of the FAA Reauthorization Act of 2024, Congress directed the Federal Aviation Administration (FAA) to review and update the requirements for emergency medical kits (EMKs) carried on commercial flights, including evaluating the medications and the medical equipment needed to respond to life-threatening emergencies such as anaphylaxis, cardiac arrest, opioid overdose, pediatric emergencies, and pregnancy-related emergencies.

Yesterday, the FAA published its long-awaited proposed rule. Rather than updating the required contents of onboard emergency medical kits to include modern, FDA-approved options for administering auto-epinephrine to treat anaphylaxis, including autoinjectors and nasal epinephrine, the proposal would eliminate clear national minimum requirements and instead require only that airlines demonstrate the ability to respond to specific medical emergencies. The proposed rule gives the operator flexibility while failing to protect travelers with food allergy through clear national standards for life saving anaphylaxis treatment on board.

Sung Poblete, PhD, RN, CEO of FARE said, “Far too frequently, we hear stories of passengers experiencing life-threatening food allergy reactions in the air, where there is no immediate access to emergency medical care. That is why this proposed rule is so deeply concerning. Rather than taking the opportunity to modernize emergency medical kits to include autoinjectors and nasal epinephrine for the treatment of anaphylaxis, this proposal lowers the standard to in the name of “operator flexibility”—a decision that could cost lives.”

Dr. Poblete continued, “As a clinician who has been called upon to treat a passenger experiencing anaphylaxis caused by a food allergy in-flight, I know firsthand how critical it is to understand what medications and equipment are readily available. A national standard provides certainty for medical professionals and in-flight staff who may be called on to help. A patchwork of airline-specific emergency medical kits creates unnecessary uncertainty in a medical emergency.

It’s time for the FAA to keep true to the intent of the FAA Reauthorization Act. Congress directed the agency to ensure lifesaving medications and equipment are readily available for use by flight attendants without prior approval from a ground-based medical professional. We call on the FAA to reconsider this proposal and strengthen the minimum requirements by replacing outdated epinephrine vials and ampoules with modern, FDA-approved epinephrine administration options, including autoinjectors and nasal epinephrine, to protect passengers when every second counts.”

FARE will provide public comment to the FAA on the proposed rule change.