Food Allergy Safety in Flight: Epinephrine Readiness on Airlines

The Honorable Michael Whitaker 
Administrator 
Federal Aviation Administration 
800 Independence Avenue, SW 
Washington, DC 20591

Subject: Request for Consultation Prior to Rulemaking Implementation under the FAA Reauthorization Act of 2024 (Emergency Medical Kits and In-Flight Allergen Safety)

Dear Administrator Whitaker,

On behalf of Food Allergy Research & Education (FARE), the nation's leading nonprofit organization dedicated to improving the lives of the more than 33 million Americans living with food allergies, we respectfully request the opportunity to provide input in response to the Federal Aviation Administration’s (FAA) proposed regulation entitled, Improving Emergency Medical Kit (EMK) Efficacy and Flexibility in Commercial Airline Operations, published on August 5, 2026 in the Federal Register.

The FAA Reauthorization Act of 2024 presented an important opportunity to strengthen passenger safety by modernizing emergency preparedness on commercial aircraft. We urge the FAA to reconsider its proposal to reverse requirements to include pre-measured, FDA-approved epinephrine devices for the emergency treatment of anaphylaxis.

Current EMK requirements rely on epinephrine vials and syringes, which require manual preparation before administration. During an in-flight medical emergency, every second matters. Requiring pre-measured, FDA-approved epinephrine devices—such as epinephrine auto-injectors or needle-free epinephrine delivery systems—would help ensure that life-saving medication can be administered quickly and accurately when treating severe allergic reactions.

In addition to modernizing Emergency Medical Kits, we encourage the FAA to strengthen guidance around allergen transparency for onboard food and beverage service. Passengers with food allergies should have access to clear ingredient and allergen information before consuming meals and snacks served during a flight. Recent incidents involving undeclared allergens have highlighted the potentially life-threatening consequences of inadequate ingredient disclosure in the unique environment of commercial air travel.

Improved allergen labeling and ingredient transparency would enable passengers to make informed decisions, reduce the risk of accidental exposure, and complement broader efforts to improve in-flight emergency preparedness.

Together, these actions would represent meaningful progress toward creating a safer and more accessible flying experience for millions of Americans living with food allergies.

FARE welcomes the opportunity to meet with you and your team to share clinical expertise, patient perspectives, and recommendations that support implementation of the FAA Reauthorization Act while improving outcomes for passengers experiencing life-threatening allergic reactions.

Thank you for your leadership and your commitment to ensuring the safety of the flying public. We appreciate your consideration and look forward to working with the FAA on this important issue.

Sincerely,

Sung Poblete, PhD, RN
Chief Executive Officer
FARE (Food Allergy Research & Education) 

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.

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