A proposed new U.S. federal rule governing airline emergency medical kits has sparked an outpouring of public comments from the food allergy community. Over 700 people have now raised concerns that the kits – called EMKs for short – are not being required to carry modern epinephrine devices in case of severe allergic reactions at 35,000 feet.
The Federal Aviation Administration (FAA) had been widely expected to require epinephrine devices – auto-injectors or nasal spray – in addition to the vial and syringe dose. But that’s not what happened.
Instead, the FAA issued a proposed rule that offers the airlines “greater flexibility” in deciding what goes into their kits. Under the FAA Reauthorization Act of 2024, the FAA was tasked with updating the contents of airlines’ emergency medical kits. Congress even singled out anaphylaxis in this act. It noted the agency must determine whether EMKs included the right medicine and equipment to treat it.
Yet, the proposed rule issued in early August 2026 only states that treatment for anaphylaxis “could include medication such as epinephrine.” This has left troubling uncertainty around epinephrine, the only drug that treats anaphylaxis. The question is: Will airlines carry lifesaving epinephrine in a form, dose and quantity that can be used when seconds count?
It’s this uncertainty – detailed in Allergic Living’s August 5 article – that has fueled the food allergy community’s outpouring of comments. The FAA needs to grasp the level of concern over the medical kits “requiring” epinephrine. We urge those who manage food allergies and healthcare professionals to add their comments to the FAA here. The comment period closes on October 5.
Senator Vows to Fight
Wellness entrepreneur and author Valentina Gaylord and her husband Olympian Mitch Gaylord are among those speaking out to the aviation authority.
The food allergy parents noted that “to leave epinephrine as something a medical kit ‘could include’ is to leave a child and/or person’s life to chance and to the goodwill of strangers seated nearby.”
The FAA’s proposed rule does not explicitly require epinephrine auto-injectors or nasal epinephrine. Nor does it specify availability of doses for children and adults or establish a number of doses available.
Senator Tammy Duckworth (D-Ill) has pushed for stronger in-flight emergency preparedness. She tells Allergic Living that while she understands the FAA’s need to streamline emergency kit requirements, “I have several concerns about the FAA’s proposed rule.”
“Ever since a constituent reached out to me after going into anaphylactic shock while flying home to Chicago, I’ve worked hard to ensure the FAA requires adequate emergency medical kits on board flights, including epinephrine devices,” she says. (Duckworth refers to her constituent Alexa Jordan, who went on to advocate for improved access to epinephrine devices on airplanes.)
“I will continue to fight to ensure emergency medical kits include the critical medications that could save lives in moments of need,” Duckworth says.
Community to FAA: Require Epi Devices
On the federal registrar where the FAA shared its proposed rule, those flying with food allergies are in a fighting mood as well. The regulator’s proposal focuses on nine life-threatening conditions, yet almost all of the over 740 public comments are from allergy parents and individuals. Here are some of the comments (edited for length):
• Sonya White: “Passengers experiencing anaphylaxis may be hours away from emergency medical care, making access to epinephrine critical. While individuals with known severe allergies should carry their prescribed medication, emergencies do not always involve someone with a previously diagnosed allergy. Or medication may be lost, inaccessible, expired, or insufficient.”
• Terri Scott: “Require all airlines to stock their emergency kits with epinephrine. Sometimes people need multiple injections to save their life.”
• Jessica Cory: “As someone who developed tree nut and peanut allergies as an adult, when I first experienced anaphylaxis, I had no epi available. I was minutes from a hospital. If my first reaction had been in the air, I could have died. Making epi mandatory on flights saves lives.”
• Sandy Jarvis: “As a retired pediatric nurse practitioner, I ask that you retool this regulation to require the inclusion of an EpiPen in each airplane emergency kit. This is an easily administered, life-saving medication. To leave it up to the airline to include it or not is irresponsible.”
• Danielle Shay Gum writes of her son eating the wrong protein bar. “He needed three epi auto-injectors and an ICU with an epi IV drip …. I shudder to think what would have happened on an airplane.”
• Tasha Higer: “What if a passenger reacts for the first time and they don’t carry an epi? They’re 35,000 feet in the air. Until you’ve watched someone experience the terror that is anaphylaxis, you might not get it. Please put epis on board.”
• Ruby Grider: “Imagine having a full blown allergy reaction only to realize your lifesaving medication was accidentally packed in luggage that was checked. Do the right thing.”
• Sherri Vecchio, MD: “A person with allergies can be exposed to their allergen in-flight. This happened to my child when we found peanuts under his seat and next to the window. Or the poor child from Pennsylvania who died from an airline meal. Please add epinephrine to all required airline medical kits!”
• Anonymous: “As an airline pilot, and a father of a kid with severe allergies, I’ll say two words. Mandate it.”
FAA Moves Away from Meds List
Epinephrine currently carried in aircraft EMKs is usually in a vial-and-syringe format. Administering from a vial requires calculating the proper dose and drawing up the medication. Even for physicians who step up to assist, turbulence and cramped quarters can make drawing up from a vial difficult.
Allergist organizations and food allergy nonprofits have for years called for epinephrine devices to be carried in airplane EMKs. It appears the regulator has not heard their calls.
The FAA says it seeks to move away from the current “prescriptive list” of required medications for airplane medical kits. It contends this approach “prevents operators’ EMK or First Aid Kit contents from keeping up with the most modern medical scientific developments.”
However, there’s no evidence that the current medication list prevents any airline from carrying epinephrine auto-injectors. Allergic Living’s Airlines & Allergies Guide lists Southwest Airlines and JetBlue Airways as examples of carriers that do carry auto-injectors in their EMKs. That was their choice, under current rules, to update their kits.
Flexibility vs. Uncertainty
The FAA accompanies its proposed rule with a draft advisory circular that “recommends” medications to the airlines. For anaphylaxis, it does reference a “premeasured auto-delivery device.”
However, the advisory circular only provides guidance; it is not a requirement. In the draft rule itself, the strong emphasis is on flexibility and eliminating a “prescriptive list of required items.” When Allergic Living asked what significance the advisory circular’s drug list could have, the FAA said it could not comment on rulemaking in progress.
With the FAA’s flexibility on kit contents, it’s not even certain that epinephrine vials in the anaphylaxis concentration would always be there.
For passengers managing severe allergies, modernizing emergency medical kits should mean greater confidence that lifesaving treatment will be available if needed. It should not mean new ambiguity that an EMK “could include” epinephrine.
As the Gaylords wrote in their public comment: “The flying public deserves certainty, not possibility. We ask the FAA to make epinephrine a requirement, not a suggestion.” Again, Allergic Living urges you to add your comment as well.
Related Reading:
See the full Federal Docket FAA-2026-9178.
Allergic Living: FAA’s Proposal for Epi on Planes – a LetDown for Safety
No Nut Traveler: Sample Letter to FAA and Writing Tips
Gwen Smith is the Editor of Allergic Living. Lianne Mandelbaum is Allergic Living’s airlines correspondent, and the founder of NoNutTraveler.com.
