As you may know, the Canadian Transportation Agency (CTA) recently released a report from a Ministerial Inquiry that reviewed current practices for managing food allergies for peanuts, tree nuts and sesame seeds on Canadian airlines. The inquiry was mandated by the Minister of Transportation, following the CTA’s rulings on specific allergy-related cases that focused on those three specific allergens.
We were one of several key stakeholders who were asked to provide input during the inquiry. Many of our recommendations were integrated into the final report, however, there were a few key areas we felt required further consideration by the CTA. We met with the CTA in September to discuss these concerns further.
In our discussions, we were informed that the report is final and no further changes could be made at this time. However, we also learned that the CTA was undertaking a public consultation on accessible transportation to garner feedback from Canadians on how to help make federal transportation more accessible to people with disabilities. This consultation would allow us and all Canadians, to provide recommendations for airline travel, as well as other modes of transportation under the CTA’s jurisdiction.
We saw this as an opportunity to provide our input, as well as engage you and others within the community to provide input directly to the CTA before the deadline of September 30th. Our recommendations have been submitted to the CTA and to date over 150 individuals/organizations also provided their response to the CTA regarding food allergies. Thank you to those that submitted a response for helping to make our collective voice heard with the CTA!
To view our full response to the CTA for the Accessible Transportation Consultation as it pertains to food allergies, please click here.
Our recommendations to the CTA are as follows:
All Modes of Transit
We support the CTA’s consideration of regulations that would:
- Apply to all modes of transportation under the CTA’s jurisdiction;
- Be structured to recognize that carriers and terminals are expected to provide many of the same services to a person with disabilities;
- Contain provisions to reflect the services that are mode-specific;
- Create consistent and reliable levels of accessibility within the federal transportation network; and
- Ensure compliance of service providers in meeting accessibility standards.
We have recommended that common standards could apply to all modes of transportation, such as:
- Staff training on food allergies, including the identification of signs and symptoms of an allergic reaction and how to respond in an emergency;
- Having “stock” epinephrine available, an auto-injector (e.g., EpiPen®) that is not prescribed to an individual that can be used to treat someone experiencing a severe allergic reaction;
- Strategies to minimize exposure to common food allergens;
- Development of documented allergy policies and procedures; and
- Clear and easily accessible information on allergy policies for passengers developed by each sector (e.g., on websites).
We also recommended that a sub-committee of stakeholders be created as the regulations are developed, including patient advocacy organizations such as ourselves.
Air Travel
In its Ministerial Report, the CTA rejected two important measures proposed by Food Allergy Canada and the Canadian Society of Allergy and Clinical Immunology (CSACI), which we recommend be reconsidered as part of the consultation process:
- Stock epinephrine: carry stock epinephrine on airlines in the event of an emergency (some international airlines already do this); and
- Staff training: in-flight staff should be trained on how to respond and treat an individual experiencing anaphylaxis.
These two measures were also supported by the CTA’s own medical advisor.
In addition, we also proposed an overall review of the CTA’s initial findings from their Ministerial Report and our recommendations, including:
Buffer zones
- CTA’s finding: Create a buffer zone consisting of the row the allergic passenger is in and not serving meals or snacks containing peanuts, nuts or sesame seeds in the buffer zone.
- Our recommendation: Retain buffer zones requirements currently in place with Canadian airline providers, until additional research is conducted to advise on the effectiveness of buffer zones.
In-flight announcements
- CTA’s finding: Advise other passengers within the buffer zone that they must refrain from eating peanuts, nuts or sesame seeds or foods containing them.
- Our recommendation: Make a cabin-wide announcement informing other passengers that there is someone on board with peanut, nut or sesame allergies. Passengers may be asked to refrain from consuming these products during the flight.
Communication with passengers with food allergies
- CTA’s finding: Advise passengers who provide advanced notification of their allergies about safety measures they can take, such as carrying their auto-injector and bringing their own food.
- Our recommendation: Upon booking and again at check-in, inform the passenger of the airline’s allergy policy, including a reminder for the person to carry their auto-injector onboard and bring their own food for the flight.
Cleaning
- CTA’s finding: Allow passengers to pre-board to wipe down their seating areas.
- Our recommendation: Have specific protocols for airline staff in place for cleaning areas where a person with allergies is to be seated and provide passengers with the option of pre-boarding to clean the area themselves.
Website information
- CTA’s finding: Have allergy policies on air carrier websites.
- Our recommendation: Have written policies in place for accommodating passengers with food allergies, which are easily accessed on air carrier websites.
Quality of life considerations
- The CTA report did not specifically address the significant impact food allergies have on a passenger’s quality of life.
- Our recommendation: When considering appropriate accommodations, it is important to take into account the psychological and social impact food allergies can play in the daily lives of those affected and their families.
We hope to continue collaborating with the CTA and other stakeholders on this important initiative to create universal guidelines for travel.
Our goal, as always, is to work toward establishing appropriate accommodations for the 2.5 million Canadians with food allergies as they travel. We will continue to advocate on their behalf and will keep you posted as the CTA consultation continues.
Tags: air travel, Canadian Transportation Agency, CTA, planes