Aviation Sanitation: FDA Could Better Communicate with Airlines to Encourage Voluntary Construction Inspections of Aircraft Galleys and Lavatories
Fast Facts
Aircraft construction inspections check airplane sanitation systems. Specifically, they help ensure that the aircraft galley and lavatories are easy to clean, that no insects or pests are present, and that the drinking water system is installed correctly. The U.S. Food and Drug Administration does these free inspections at the request of aircraft manufacturers and U.S.-based commercial airlines. But, because participation is voluntary, some aircraft don't get inspected.
To increase the number of inspection requests, we recommend that the FDA inform airlines about the benefits of these voluntary construction inspections.
An Airline Representative Applying Additional Sealant in Response to an FDA Inspection
Highlights
What GAO Found
Most commercial aircraft undergo voluntary inspections to ensure that galleys and lavatories are constructed and assembled to meet the Food and Drug Administration's (FDA) sanitation standards, according to industry representatives. Twenty-seven percent of the inspections FDA conducted between fiscal years 2015 and 2019 found objectionable conditions. But in nearly all of these instances, the conditions identified, such as the need for additional sealant in areas where there was a gap or seam, were corrected by the airline or aircraft manufacturer during the inspection. However, some regional airline representatives told GAO that their aircraft do not receive these construction inspections, either because larger airlines with which they have contracts told them the inspections were unnecessary or because they did not believe the inspections were relevant to them. FDA provides these inspections free of charge, upon request of aircraft manufacturers or airlines, and aircraft passing inspection receive a certificate of sanitary construction. Representatives of one aircraft manufacturer said they view the certificate as beneficial because their customers see it as a guarantee that the aircraft was constructed in a way that decreases the likelihood of microbial contamination, pests, and insects. While the construction inspections are important, they are not required, and FDA does not proactively encourage airlines to request them. By developing a process for communicating directly to all U.S.-based commercial airlines, including regional airlines, to encourage them to receive construction inspections, FDA could better ensure that aircraft meet FDA sanitation standards to protect passenger health.
An Airline Representative Applying Additional Sealant in Response to an FDA Inspection
FDA faces several challenges in providing construction inspections and is taking steps to address these challenges. For example, the demand for inspections by manufacturers and airlines is unpredictable, and FDA inspectors are responsible for inspections at multiple locations. To help mitigate these challenges, officials we interviewed from four FDA field offices said they usually request advance notice from industry to allow the agency time to allocate the necessary resources for construction inspections.
Why GAO Did This Study
Voluntary construction inspections are the primary mechanism by which FDA oversees compliance with its required sanitation standards for the construction of aircraft galleys and lavatories.
A report accompanying the House 2019 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill included a provision for GAO to review FDA's process for ensuring proper sanitation in aircraft galleys and lavatories. This report (1) examines the extent to which aircraft are inspected to ensure compliance with FDA's sanitation standards, and (2) discusses challenges FDA faces in providing aircraft inspections and how FDA is addressing such challenges.
GAO reviewed FDA guidance, interviewed FDA officials in headquarters and four selected field offices with high volumes of construction inspections, conducted site visits to meet with FDA inspectors, and interviewed representatives of selected aircraft manufacturers and airlines.
Recommendations
GAO recommends that FDA develop a process for communicating directly with all U.S.-based commercial airlines to encourage them to request construction inspections. FDA generally agreed with our recommendation.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Food and Drug Administration | The Commissioner of FDA should establish a process for the agency to communicate directly with all U.S.-based commercial airlines, including regional airlines, to encourage them to request construction inspections to ensure compliance with the agency's standards for the sanitary construction of aircraft galleys and lavatories. (Recommendation 1) |
HHS concurs with GAO's recommendation. In March 2021, FDA stated that it was working to consider ways to enhance mechanisms currently in place with airlines to better address communication issues. FDA said it will review its existing outreach channels with airline stakeholders and identify opportunities for more direct and active engagement between the agency and the airlines on construction inspections. As an example, FDA said t is reviewing the Interstate Travel Program (ITP) webpage on the agency's website and identifying potential updates that can make information on airline construction and renovation more prominent. As part of the update, FDA is planning to include a listing of ITP points of contact and information to help guide industry through the construction inspection and certification process. FDA is currently reviewing and updating, as necessary, the program documents so that, once posted, the webpage reflects the most up-to-date information. FDA will also continue to maintain an open dialog with airline organizations, including the Airlines for America (A4A), Regional Airline Association (RAA), and International Flight Services Association (IFSA). Members of A4A are comprised of major national airlines, whereas those of RAA are comprised of regional commuter airlines and those in IFSA include airlines and airline food suppliers. FDA said it will continue to engage with these organizations in written correspondence and at relevant national industry meetings (such as the Environmental Protection Agency biennial meeting on aircraft drinking water safety) and will include the topic of construction inspections. FDA indicated that it will also continue to use these existing mechanisms to develop a better communication process with the airline industry on its efforts to improve industry practice and government oversight. In June 2022, FDA reported that it was working to enhance mechanisms currently in place with airlines to better address communication issues. For example, they met with IFSA via virtual meeting to hear IFSA interests and input for areas of engagement going forward and have planned a second meeting. In addition, FDA noted that its ITP staff are reviewing ways to communicate to the ITP stakeholders more transparently (via the ITP external web page) the process for issuance of a voluntary certificate of sanitary construction and the items needed for its issuance. In July 2023, FDA stated that the agency had held quarterly meetings with the IFSA and had met with A4A once to exchange contact information but did not confirm that it had used these interactions to encourage airlines to request construction inspections. As of April 2024, FDA has established a process to communicate directly with all U.S.-based commercial airlines, including regional airlines, to encourage them to request construction inspections to ensure compliance with the agency's standards for the sanitary construction of aircraft galleys and lavatories. The agency included division-level contacts who have responsibility for issuing voluntary Certificates of Sanitary Construction on its Interstate Travel Program website and is further developing the website to describe certain requirements. According to officials, in April 2024, FDA also sent communication to Airlines for America (and International Flight Services Association reminding them of the requirements to submit construction plans in accordance with the law. The agency also made several attempts to communicate the same information to the Regional Airline Association (RAA) and plan to continue making attempts to communicate with the association, according to officials. Finally, FDA is creating a course specifically for the inspections that lead to the issuance of CSC for aircrafts. Based on these actions, FDA has met the intent of the recommendation.
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