HomeOur response letter to the Canadian Transportation Agency on their recent air travel inquiry

Our response letter to the Canadian Transportation Agency on their recent air travel inquiry

August 29, 2016

The Canadian Transportation Agency (CTA) recently released its report from a Ministerial Inquiry that reviewed current practices for managing food allergies for peanuts, tree nuts and sesame seeds on Canadian airlines. Food Allergy Canada and other stakeholders participated in the process. To learn more, please read our blog post about the Report.

Below is our letter to the CTA, requesting a meeting and responding to the Report.


Re: The Ministerial Inquiry into Allergies to Peanuts, Nuts and Sesame Seeds in Commercial Air Travel – Report of the Inquiry Officer

Food Allergy Canada welcomed the recent release of the Canadian Transport Agency (CTA) report into the risks associated with airline travel for individuals with food allergies to peanuts, tree nuts and sesame (Decision NO.178-AT-A-2016). We were grateful for the opportunity to participate in this inquiry as key stakeholders during the review process earlier this year. In reviewing the final report, however, we have significant concerns regarding some of the risk-mitigation recommendations put forward that we would like to raise with you before any further decisions are made regarding potential policy changes for Canadian airlines.

While this report contains welcome recognition that reasonable accommodations can and must be taken to help keep air travel safe for people with food allergies, some of the key recommendations in the report ignore the consensus expert medical and patient advocacy advice (as outlined below). As such we request a meeting to discuss specific measures to help keep Canadians with food allergies safe while travelling.

Food Allergy Canada is the leading national advocacy and education organization for the 2.5 million Canadians living with a potentially life-threatening food allergy. As a very small amount of a food allergen, when ingested, can cause a serious reaction, and there is no known cure for food allergies, avoidance is the only sure means to stay safe. While our organization promotes measures to self-protect, air travel can be particularly worrisome for families managing food allergies, especially when emergency medical care is not immediately available.

Among its recommendations, the CTA rejected two important measures proposed by Food Allergy Canada and the Canadian Society of Allergy and Clinical Immunology (Canada’s national body of allergists), and supported by the Agency’s own medical advisor on this report:

  1. Stock epinephrine – an auto-injector not prescribed to an individual, but that can be used to treat anyone experiencing a severe allergic reaction – be carried on airlines in the event of an emergency (some international airlines already do this).

Although there was overwhelming support for this option, the CTA did not include it, as noted in Section 5.2.1: “Although there was significant support expressed by Dr. Greenhawt and the allergy associations for a requirement to carry epinephrine auto-injectors in onboard medical kits in lieu of, or in addition to vials of the medication, most air carriers objected to this, one noting concerns about their limited shelf-life.”

Airline travel poses an exceptional set of circumstances for passengers with food allergies – being in an enclosed space for long periods of time, thousands of feet in the air and away from emergency medical attention. We are particularly concerned about Canadians who may have a serious reaction for the first time on board or those that may need a second dose of epinephrine if they have experienced an allergic reaction in flight. If such events were to occur, and epinephrine was not immediately and easily accessible, the result could be tragic.

  1. In-flight staff be trained on how to respond and treat an individual experiencing anaphylaxis (the most severe form of allergic reaction).

The CTA report did recommend that an effective risk mitigation measure would be “training flight crews on signs and symptoms of an allergic reaction” (Section 5.2.1), but not on how to properly respond and help treat a reaction. This, in our opinion, and that of the medical experts consulted in this report, is a critical oversight in ensuring the safety of allergic passengers.

This was specifically noted in Section 5.2:

“Dr. Greenhawt noted that it is vital that passengers with allergies be prepared to recognize and self-manage a reaction. He also expressed the view that it is crucial that flight crew be able to properly identify the signs and symptoms of an allergic reaction and be able to quickly provide appropriate treatment. Several allergy associations agreed with Dr. Greenhawt’s view and recommended that flight crews receive the necessary training.”

According to the national anaphylaxis guidelines put forward by The Canadian Society of Allergy & Clinical Immunology:

  • Signs and symptoms of a severe allergic reaction can occur within minutes of exposure to an allergen (a substance capable of causing an allergic reaction). In more rare cases, the time frame can vary up to several hours after exposure.
  • Epinephrine is the first line treatment for anaphylaxis. This life-saving medication helps to reverse the symptoms of a severe allergic reaction by opening the airways, improving blood pressure, and increasing the heart rate. It is recommended that epinephrine be given at the start of a known or suspected anaphylactic reaction.
    (Source: Anaphylaxis in Schools & Other Settings, 3rd Edition (© 2005-2015).

Given that allergic reactions can happen very quickly and that prompt attention is needed to treat a reaction, it is imperative that flight crew can not only identify symptoms but also know how to help treat this medical, and potentially life-threatening, emergency.

In addition, we would also recommend an overall review of the recommendations set forth in Section 5.2.1, including the revised buffer zones requirements and communication of airline policies.

In recent years, legislative and regulatory measures at both the provincial and federal levels have been taken to make life safer for people with food allergies, including Sabrina’s Law in Ontario (ensuring each public school has an anaphylaxis plan and includes regular staff training) and federal food labelling reform (to ensure clearer ingredient listings on pre-packaged food).

Food Allergy Canada views discussion around airline safety as another opportunity to identify reasonable accommodations that will improve passenger safety. Many airlines are already taking important measures in response to advocacy from the community, such as allowing pre-boarding for a passenger with food allergies (or their parent) to board early and wipe down their seat, in-flight announcements about food allergies, and buffer zones (where certain allergens are not to be sold or consumed). The importance of these measures was affirmed in the CTA report. Still, greater clarity to existing protocols and some reasonable additions, backed by regulation, will make an important difference in the lives of passengers with food allergies.

Our organization would be pleased to work with your office, and stakeholders from the medical community and industry, to establish such measures. We will follow up in the coming days to schedule a meeting. In the interim, if you have any questions or would like to speak directly, please do not hesitate to contact me via the coordinates below.

Thank you for your attention to this issue.


Laurie Harada
Executive Director
Food Allergy Canada


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