Dec. 31, 2020
Businesses that travel internationally, take note: NBAA has met with FAA and CDC officials, who will soon publish a policy to expand pre-departure COVID-19 testing requirements to all U.S. arrivals from international locations, a policy that currently only applies to arrivals from the U.K.
NBAA expects the new, broader policy to closely reflect a CDC order mandating commercial passengers arriving from the U.K. show a negative COVID test from within three days of departure.
“The pending policy illustrates the ever-changing environment of international aviation operations in the COVID-19 era,” said NBAA’s Director of Flight Operations and Regulations, Brian Koester, CAM. “Operators need to plan ahead and stay on top of current guidance and requirements, especially if they’re spending extended time abroad, since these policies change often.”
All aircraft operators – including those conducting general aviation flights – will be required to comply with the following obligations for all passengers:
- Confirm documentation of a negative “qualifying test” result (passengers aged two years or older)
- Verify that the name and date of birth on the qualifying test result match the passenger’s passport or other travel documents
- Confirm the test was performed within three calendar days of the flight’s departure
- Confirm the test result states “NEGATIVE”, “SARS-CoV-2 RNA NOT DETECTED”, or “SARS-CoV-2 ANTIGEN NOT DETECTED”
- Collect and retain for two years an attestation that each passenger age two years or older received a negative qualifying test result (the CDC has provided this sample Attestation for arrivals from the U.K. and the pending order is expected to include similar language), and
- Do not board any passenger without the verifying attestation and confirming documentation, as described above.
Operators should review the CDC order to determine what constitutes a valid test, then provide appropriate guidance to crewmembers, dispatchers or other personnel tasked with the test confirmation activities described above.
Although aircraft operators will be required to review and retain this documentation, liability for falsifying documentation, including test results, will reside with passengers.
The following exemptions are expected to apply for:
- Crewmembers
- Children under 2 years of age
- Emergency air ambulance flights
- Military and law enforcement personnel carrying out orders
Collecting and verifying qualifying test results will be a relatively simple task in many parts of the world, but passengers from some remote or developing areas might not have access to qualifying tests or appropriate documentation.
“NBAA requested the FAA clarify how to handle passengers departing from areas that do not have testing or documentation that meets the CDC requirements for a qualifying test,” said Koester. “Some passengers departing from more remote areas of the world simply can’t meet these requirements.”
Until the new CDC order is published – which NBAA anticipates within the coming days – this information is subject to change. The FAA has indicated the policy may have up to a 14-day implementation, allowing operators to adjust plans. NBAA will continue to keep operators informed as more information becomes available.
International Business Aviation Council Ltd.