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Airline Passenger Rights "Experts’ Discussion: Peanut Allergies"

Questions for Expert Discussion
By the Regulation Room team based on the NPRM and comments
Agency Documents
1 0

What’s Going on Here?

Scientific evidence about peanut allergies is very important to whether DOT Department of Transportation should ban peanuts on planes or require some other accommodations for peanut allergy sufferers.

People who commented on this issue have very different views about how serious the problem is and what it makes sense to do. (See the Draft Summary of Peanut Discussion [insert link].)   Expert knowledge will help DOT Department of Transportation make the best decision.  Also, DOT Department of Transportation might have to present scientific evidence to Congress before it can do anything.  (See DOT Department of Transportation Clarification.)

On September 1, the Regulation Room team sent email invitations to allergy researchers asking them to join an Expert Discussion. (The last section of this post explains how we identified experts to invite.)  This discussion will be open until September 21. Then the Regulation Room team will prepare the Expert Discussion for submission to DOT Department of Transportation no later than September 23 (when the official comment period closes).

PLEASE NOTE:  Only invited experts can make comments in this discussion.

Want to suggest an expert for us to invite?  See the last section of this post.

2 0 Overview

The Department of Transportation is considering whether the federal government should take steps to accommodate air travelers with peanut allergies.  In the NPRM, it asked for help on several questions. (See what DOT Department of Transportation said here). Those questions are listed below.  Other questions were raised by people who have commented on the possibility of peanut allergy regulation.  (See what people said on the Peanut Allergy Issue Post.)  Those are listed separately.  There is also a section at the end for experts to add relevant information that isn’t covered by the questions.

The last section of this post explains how experts were selected and provides instructions for suggesting other experts who should be invited to join this discussion.

NOTE:  In answering questions, please include information about the state of scientific knowledge on the issue.  It’s as important for DOT Department of Transportation to know where good scientific information is lacking, as to know what questions research has answered.

Please include links or citations to any relevant research that is not already listed on the Peanut Allergy Studies page[add link].

3 0 Incidence, Severity, and Uniqueness

DOT didn’t ask any specific questions about these issues, but they were hot topics for people who commented on peanut allergy regulation.

Commenters ask:  How many people really have allergies to peanuts?  Do many people who think they have an allergy really just have a “sensitivity” to peanuts?  Are children likely to “grow out of” peanut allergies?

What is the range of possible reactions, and how prevalent are life-threatening reactions?

Are peanut allergies so different from other allergies that it’s reasonable for DOT Department of Transportation have air travel regulations about them but not about tree nut, perfume, pet or other allergies?

4 0 How People Are Exposed

DOT asks:  “How likely is it that a passenger with allergies to peanuts will have severe adverse health reactions by being exposed to the airborne transmission of peanut particles in an aircraft cabin (as opposed to ingesting peanuts orally)?”

“Is there recent scientific or anecdotal evidence of serious in-flight medical events related to the airborne transmission of peanut particles?”

“Should any food item that contains peanuts be included within the definition of peanut products (e.g., peanut butter crackers, products containing peanut oil)? Is there a way of limiting this definition?”

Commenters ask:  Is it really possible to have a severe reaction from contact with peanut oil or other residue (without eating peanuts or peanut products)?

5 0 Possible regulatory responses that involve restricting presence of peanuts on the plane

DOT identified three possible approaches to accommodate peanut allergy sufferers:

  1. Complete peanut ban:  Prohibit airlines from serving peanuts or peanut products
  2. Peanut–free flights: Prohibit airlines from serving peanuts or peanut products on any flight where a passenger with a peanut allergy is on board and has requested a peanut-free flight in advance.
  3. Peanut-free zone:  Require airlines to provide a peanut-free buffer zone in the immediate area of a passenger with a medically-documented severe allergy to peanuts if passenger has requested that in advance.

DOT asks:  “We seek comment on these approaches as well as the question of whether it would be preferable to maintain the current practice of not prescribing carrier practices concerning the serving of peanuts.

We are particularly interested in hearing views on how peanuts and peanut products brought on board aircraft by passengers should be handled.”

Commenters ask:  How should passengers requesting a peanut-free flight or zone document that they have a serious peanut allergy?

How big a problem is peanut residue from an earlier flight – can it be handled by just wiping down seats in the immediate area?

How big a problem are peanut particles that might have become airborne during an earlier flight?

Will the airplane’s air circulation system spread airborne peanut particles, either from elsewhere on this flight or from an earlier flight, throughout the plane?

6 0 Possible accommodations by airlines that would not involve restricting peanuts

A number of possible accommodations have been identified during the discussion:

  • Planes should have epinephrine auto-injectors available; flight staff should be trained in using them.
  • Airlines should provide surgical masks, gloves, wipes, and cleansuits.
  • DOT should create a passenger’s bill of rights/responsibilities to encourage people with allergies to carry two or more self-injectors.
  • Airlines should give people with food allergies the option to board the plane early to clean the area around their seat.
  • Airlines should disclose the ingredients of meals and snacks before passengers are required to pay for/receive them.

DOT asks:  “Will taking certain specific steps to prepare for a flight (e.g., carrying an epinephrine auto-injector in order to immediately and aggressively treat an anaphylactic reaction) sufficiently protect individuals with severe peanut allergies? Who should be responsible for ensuring an epinephrine auto-injector is available on a flight – the passenger with a severe peanut allergy or the carrier?”

Commenters ask:  Do people with severe allergies need medical attention within a certain period of time even after using an auto-injector?  Is there a limit to how many could be used during a flight?  Are there side effects?

Are any of these other ideas effective to protect people with peanut allergies from serious reactions?

7 0 Other relevant information for DOT

If there’s anything else you think DOT Department of Transportation should know or consider in making a decision about allergy regulation for air travel, please add it to this section.

8 0 Our process for inviting experts

Commenters cited several studies on allergies.  See them on the Peanut Studies page here.  The Regulation Room team invited all the listed authors of those studies for whom we could find email contact information.  Then we looked at what those studies cited, and did a Google search.  We invited listed authors (when we could get their email contact information) of studies that were published in scholarly journals or had other reasonable objective indicators of bona fide research.  We did not take into account either the way the study was funded, or the substance of the conclusions it reached.  Studies that we identified are listed in a separate section of the Peanut Studies page here.

In the email invitation we encouraged experts to include their real name in their user profiles, because we believe that DOT Department of Transportation will not consider a comment to come from an “expert” unless he/she is identified and his/her credentials are available.

If you know of someone whom you believe should be invited as an expert, please contact us at:  Give the person’s full name, the academic or other institute he/she affiliated with (if you know it), his/her email address, and the study or other work that shows why he/she should be considered an expert in this area.