Aircraft Operational Considerations With the Coronavirus

Updated May 3, 2022

On Jan. 30, 2020, the World Health Organization (WHO) declared that the outbreak of Coronavirus Disease 2019 (COVID-19) constitutes a Public Health Emergency of International Concern (PHEIC), and, on March 11, 2020, WHO characterized the outbreak of COVID-19 as a pandemic.

The evolving situation around the globe also highlights the importance of proper guidance and resources to assist in planning domestic and international operations in the months ahead. The information below reflects guidance from US government agencies for operating restrictions and precautionary procedures that should be observed for travel to, from, or within each region of the world.

U.S. Arrival Restrictions
FAA ATC Facilities Affected by COVID-19
FAA Guidance for Airport Sponsors and Local Authorities
Travel Restrictions to Europe
Global Travel Restrictions
FAA and CDC Passenger Precautions
FAA and CDC Crew Precautions
Be Prepared
Resources

U.S. Arrival Restrictions

As of Nov. 8, 2021, noncitizen, non-immigrant air travelers to the United States are required to be fully vaccinated and to provide proof of COVID-19 vaccination status prior to boarding an airplane to fly to the U.S., with only limited exceptions. In addition as of Dec. 6, 2021, all travelers must show proof of a negative viral test result within one day of travel to the United States.

Fully Vaccinated Travelers

Noncitizen, non-immigrant air travelers to the United States are required to be fully vaccinated and to provide proof of vaccination status prior to boarding an airplane to fly to the U.S.

Proof of Vaccination

For foreign nationals, proof of vaccination is required – with very limited exceptions – to board the aircraft.

Passengers will need to show their vaccination status, and the operator will need to do the following:

Match the name and date of birth to confirm the passenger is the same person reflected on the proof of vaccination
Determine that the record was issued by an official source (e.g., public health agency, government agency) in the country where the vaccine was given
Review the essential information for determining if the passenger meets CDC’s definition for fully vaccinated such as vaccine product, number of vaccine doses received, dates of administration, site (e.g., vaccination clinic, health care facility) of vaccination.

Accepted Vaccines

CDC has determined that for purposes of travel to the United States, vaccines accepted will include FDA approved or authorized and World Health Organization (WHO) emergency use listed (EUL) vaccines.

Individuals can be considered fully vaccinated on, or after two weeks from receipt of the last dose if they have received any single dose of an FDA approved/authorized or WHO EUL approved single-dose series (i.e., Janssen), or any combination of two doses of an FDA approved/authorized or WHO emergency use listed COVID-19 two-dose series (i.e. mixing and matching).

The CDC provides details on the definition of “fully vaccinated” in the Annex to Interim Public Health Recommendations for Fully Vaccinated People.

Read the CDC Order: Implementing Presidential Proclamation on Safe Resumption of Global Travel During the COVID-19 Pandemic

Limited Exceptions from the Vaccination Requirement

There is a limited set of exceptions from the vaccination requirement for foreign nationals:

Children under 18
Certain COVID-19 vaccine clinical trial participants
Those with medical contraindications to the vaccines
Those who need to travel for emergency or humanitarian reasons (with a US government-issued letter affirming the urgent need to travel)
Those who are traveling on non-tourist visas from countries with low-vaccine availability (as determined by the CDC)
Other very narrow categories

Those who receive an exception will generally be required to attest they will comply with applicable public health requirements, including, with very limited exceptions, a requirement that they be vaccinated in the U.S. if they intend to stay here for more than 60 days.

Contact Tracing

To prevent the introduction, transmission, and spread of new variants of COVID-19 as well as to add a critical prevention tool to address other public health threats, the CDC issued a Contact Tracing Order that requires all aircraft flying into the United States to keep on hand – and promptly turn over to the CDC, when needed – contact information that will allow public health officials to follow up with inbound air travelers who are potentially infected or have been exposed to someone who is infected.

All passenger-carrying operations conducted on aircraft arriving into the United States from a foreign last point of departure (including flights with intermediate stops in the United States between the flight’s foreign point of origin and the final destination) are required to collect data as soon as practicable but CDC will use enforcement discretion after the Order effective date to allow airlines and operators to come into compliance. All operators of any passenger-carrying operations shall:

Collect the “designated information” for all passengers before boarding, but not more than 72 hours before departing from the flight’s foreign last point of departure
Maintain the “designated information” for all crewmembers
When collecting the “designated information,” notify passengers of the purpose and intent of the information collection, that the obligation to provide complete and accurate information is a United States Government requirement, and that failure to provide complete and accurate information may result in criminal penalties, as set forth herein. The airline or operator must also obtain confirmation from each passenger that the information provided is complete and accurate
Retain the “designated information” for each flight for a minimum of 30 days from the flight’s departure and, within 24 hours of a request from the CDC Director, transmit it to CDC through secure, electronic means approved by CDC. Data retention is not required for operators who choose to otherwise securely transmit data using established DHS data systems.

‘Designated information’ means the data elements listed below, to the extent that they exist. Data elements listed in subsections (a) through (e) must be provided by the passenger and maintained by the airline or operator for crewmembers and (f) through (m) must be provided to the extent such data elements are already available and maintained by the airline or operator.

(a) Full name (last, first, and, if available, middle or suffix (e.g., Jr.)

(b) Address while in the United States (number and street, city, state or territory, and zip code)

(c) Primary contact phone number to include country and area code, at which the passenger or crewmember can be contacted while in the United States

(d) Secondary contact phone number to include country and area code, which may be an emergency contact number, a work number, or a home number

(e) Email address that the passenger or crewmember will routinely check while in the United States

(f) Date of birth

(g) Airline name

(h) Flight number

(i) City of departure

(j) Departure date and time

(k) City of arrival

(l) Arrival date and time

(m) Seat number

Read the CDC Order: Requirement for Airlines and Operators to Collect Contact Information for All Passengers Arriving into the United States

Crew members are exempt from these requirements when acting in an official capacity or deadheading. Operators may print and provide crews a letter to use as proof of their exemption when deadheading on other air carriers.

Download the sample letter in Word format.

Passenger Attestation

All aircraft operators must collect the passenger attestation on behalf of the U.S. Government, as required by United States federal law.

Download the CDC Combined Passenger Disclosure and Attestation Form

Further, as directed by the CDC and the TSA, and consistent with CDC’s Order implementing the Presidential Proclamation, all aircraft operators must provide the required disclosures (contained on the attestation form) to all passengers prior to their boarding a flight from a foreign country to the United States.

Section 1 must be completed by all passengers.

Section 2 must be completed by any noncitizen (other than a U.S. lawful permanent resident or U.S. national) who is a nonimmigrant seeking to enter the United States by air travel. This section does not apply to crewmembers if such crewmembers and operators adhere to all industry standard protocols for the prevention of COVID-19, as set forth in relevant guidance for crewmember health issued by the CDC or by the Federal Aviation Administration in coordination with the CDC.

FAA ATC Facilities Affected by COVID-19

Review the latest information about FAA Air Traffic Control facilities affected by COVID-19. This map will be updated every evening by 7 p.m. EDT and throughout the day, based on the nature of developments. The information presented is preliminary and subject to change.

Open this map in a new browser window.

Operators are reminded to check NOTAMs prior to flight.

FAA Guidance for Airport Sponsors and Local Authorities

In response to efforts of local authorities to limit access to airports during the COVID-19 crisis, the FAA issued the following guidance to airport sponsors. “The FAA’s primary concern is that federally obligated airports remain safe and open to the traveling public and aircraft. Particularly during this public health emergency, airports play an essential role. The FAA continues to expect all airports to operate safely and to stay open.”

Aircraft operators should be aware that in most cases local authorities do not have jurisdiction to close or restrict aeronautical activity at federally obligated airports without direct approval from the FAA. As expressed in the guidance, the FAA is approaching these requests on a case-by-case basis.

Review FAA Information for Airport Sponsors Considering COVID-19 Restrictions and Accommodations (Updated April 4, 2020)

Review FAA Considerations for State, Local, and Territorial COVID-19 Restrictions That Impact Air Transportation

NBAA has long worked to maintain access to airports and airspace for general aviation, a vital lifeline in times of crisis, and to prevent a patchwork of local policies as some elected officials take hasty actions that exceed their authority.

Travel Restrictions to Europe

On March 16, 2020, the European Commission recommended the EU member states apply a temporary restriction of non-essential travel from third countries into the Schengen area for 30 days. Travel by U.S. citizens to Europe would largely be prohibited during this restriction.

The temporary travel restriction would exempt nationals of all EU member states and Schengen region for the purposes of returning to their homes. This exemption would also apply to:

all EU citizens and citizens of the Schengen Associated States, and their family members
third-country nationals who are long-term residents under the Long-term Residence Directive and persons deriving their right to reside from other EU Directives or national law or who hold national long-term visas

European Commission Bulletin: COVID-19: Temporary Restriction on Non-Essential Travel to the EU

Global Travel Restrictions

Operators seeking the latest updates for flying to a particular foreign destination can find the most recent information from the U.S. Department of State. Each embassy is providing continuous updates on restrictions, practices, and travel bans.

Review the U.S. Department of State – Bureau of Consular Affairs Information.

The U.S. State Department determined travel by pilots and aircrew to the U.S. for the purposes of training or aircraft pickup, delivery or maintenance will qualify under the national interest exemption, a provision strongly supported by NBAA. Accordingly, individuals traveling on B-1/B-2, B-1 or M-1 visas, or through the Visa Waiver Program, are eligible to enter the U.S for these purposes.

Learn more about the State Department announcement.

FAA and CDC Passenger Precautions

Passengers on all forms of public transportation into, within or outside of the U.S., including charter operations and at transportation hubs including FBOs, must wear face masks, according to a Jan. 29, 2021, order from the DC. Private conveyances for personal, non-commercial use are exempt from the rule, meaning passengers of private Part 91 operations are not required to comply.

Review the CDC order: Requirement for Persons to Wear Mask While on Conveyances and at Transportation Hubs

Anyone on layover should stay in their hotel rooms to the extent possible, limit their activities in public, and practice social distancing. Social distancing means avoiding crowded places, not going to mass gatherings and generally staying about 6 feet from others, when possible.

Traveling individuals should also pay attention to their health at all times and remain in communication with their employer’s occupational health program. If anyone develops a fever, cough, or difficulty breathing, they should immediately self-isolate and be excluded from work on flights until cleared by public health authorities.

FAA and CDC Crew Precautions

Crew members with high-risk exposures to COVID-19 may also need to be excluded from work until no longer at risk for becoming infectious. A person is considered high-risk if exposed to a sick household member or intimate partner, or providing care in a household to a person with a confirmed case of COVID-19.

Review SAFO 20009 – May 25 – COVID-19: Updated Interim Occupational Health and Safety Guidance for Air Carriers and Crews

The Federal Air Surgeon determined that FAA medical certificate holders may not act as pilot in command, or in any other capacity as a required flight crew member, for 48 hours after each dose of the Pfizer-BioNTech, Moderna, and Johnson & Johnson vaccines. The Federal Air Surgeon made this determination after evaluation of available medical information about these COVID-19 vaccines and potential side effects.

Review the FAA guidance on post-vaccine crew duties.

Be Prepared

Proper planning begins with conducting a risk profile of your intended destination, including any current issues at the location, such as labor strikes, political unrest, pandemics or extreme weather. If the risk profile indicates that it is safe to travel to the locale but that there is the potential for danger, establish plans for performing an extraction or diversion.

“Use all of the tools available to you, including third-party service providers, NBAA Air Mail groups and onsite handlers to get local information,” recommends Kellie Rittenhouse, director of aviation at Hangar Management. “Continue to evaluate the conditions before and during the trip.”

Also, different scenarios call for different preparations and risk management. An emergency departure due to civil unrest or a political coup will require different plans than an emergency departure from a developing nation due to a medical concern of a crew member or passenger.

Regardless of what unique requirements your operation may have, experts advise that all travelers should notify the U.S. embassy in the destination country of their travel plans. This includes identifying where you are staying locally and how the embassy can contact you while in state. Using the Smart Traveler Enrollment Program (STEP) to convey this information enables the local U.S. embassy or consulate to contact registered U.S. citizens and nationals in the event of an emergency and offer assistance in certain circumstances.

In extreme scenarios, consider sending an additional qualified pilot along on a trip. Pilot illness or injury puts all passengers and crew members at risk and potentially makes the aircraft a useless asset.