Airline & Aviation Allergy Laws — United States & International

FAA Emergency Medical Kit Rule (FAA-2026-9178)

The FAA's proposed rule (Docket FAA-2026-9178) would eliminate the prescriptive list of required items in airline emergency medical kits (EMKs) and first aid kits, replacing it with a performance-based requirement that lets each airline decide what to stock. While the FAA says this 'modernizes' the kits, the proposal only states that treatment for anaphylaxis 'could include' epinephrine — it does not require modern epinephrine auto-injectors or nasal spray. AAFA, FARE, the American Medical Association, and Senators Duckworth and Schumer are urging the FAA to mandate FDA-approved epinephrine delivery devices on every flight. Public comments are open until October 5, 2026.

Alpha-Gal Allergen Inclusion Act

Adds alpha-gal to the federal list of major food allergens, requiring clear and specific labeling on all U.S. packaged food products to help Americans with AGS identify products that could trigger a life-threatening allergic reaction.

SponsorSen. Mark R. Warner (D-VA) (Bipartisan)

Emergency Medical Services Epinephrine Law

Requires ambulance and aid services to carry epinephrine for administration by emergency medical technicians. Note: This does not apply to commercial airline cabin crews.

FAA Emergency Medical Kit Rulemaking

FAA proposed regulatory framework under the FAA Reauthorization Act governing airline emergency medical kits across all commercial passenger carriers serving Texas airports, addressing performance standards for treating nine in-flight emergencies including anaphylaxis.

Airline Access to Emergency Epinephrine Act

Directs the FAA to require commercial airlines operating flights (including flights originating or landing in Texas) to carry at least two packs of epinephrine auto-injectors and ensure flight crewmembers are trained on symptom recognition and auto-injector administration.

Airline Emergency Medical Kit Update

Requires the FAA to update airline emergency medical kits (EMKs) to include epinephrine auto-injectors and other medications necessary to treat anaphylaxis on commercial flights.

FAA Reauthorization Act

Requires the FAA to review and update airline Emergency Medical Kits (EMKs) to ensure they contain appropriate medications for treating anaphylaxis and requires flight crew training on kit contents and administration.

Airline Access to Emergency Epinephrine Act

Proposed federal law to require airlines to carry epinephrine auto-injectors in emergency medical kits and train flight crews on recognizing and treating anaphylaxis.

ACAA

Prohibits discrimination against air travelers with disabilities, which has been interpreted to include those with severe food allergies and asthma, requiring airlines to provide reasonable accommodations.

DOT Southwest Allergy Ruling

Clarifies that the Air Carrier Access Act (ACAA) requires airlines to provide accommodations, such as pre-boarding, for passengers with nut allergies, though it notes a lack of explicit federal guidance for non-nut food allergies.

FAAMA

Directs the Secretary of Health and Human Services to develop voluntary guidelines for schools and early childhood education programs to manage the risk of food allergy and anaphylaxis.

Airline Allergy Preboarding Guidance

U.S. DOT order clarifying that airlines must permit passengers with severe food allergies to preboard to wipe down seating areas to prevent contact reactions, as part of the Airline Passengers with Disabilities Bill of Rights.

Food Allergy Awareness in Restaurants

Would require food service establishments (including those in PA airports) to display food allergy awareness posters in staff areas and include allergy warnings on menus. It also encourages, but does not yet mandate, formal allergy training for all food handlers.

Nondiscrimination on the Basis of Disability in Air Travel

The ACAA prohibits airlines from discriminating against passengers with "physical or mental impairments" that substantially limit a major life activity (which includes breathing and immune system function). This includes food allergies and asthma. It requires airlines to allow passengers to board early to wipe down seats and requires the accommodation of medical devices like portable oxygen concentrators and nebulizers.

FAA Reauthorization Act of 2024

Requires the FAA to issue a new rulemaking to update Emergency Medical Kits (EMKs) on commercial aircraft. Specifically mandates the inclusion of epinephrine auto-injectors (both adult and pediatric doses) and replaces antiquated vials/syringes that flight attendants cannot easily use. It also requires a review of asthma medications in kits.