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Slashing red tape helped airlines speed COVID vaccine shipments

Industry, UN agencies rewrote shipping rules for dangerous goods that presented a barrier to vaccine delivery

A Cathay Pacific cargo jet being loaded with a refrigerated container full of COVID vaccines. (Photo: Cathay Pacific)

The airfreight industry has performed well during the first rollout of COVID vaccines, but air cargo professionals say they expect vaccine volumes shipped by air to increase this summer as more doses are produced and developed countries begin exporting more after immunizing their own populations.

Initial fears that huge quantities of temperature-sensitive shipments would overwhelm a system handicapped by a severe shortage of aircraft, limited cold-storage infrastructure in developing nations and lack of clear pharmaceutical shipping specifications never materialized.

Much of the distribution to this point has been in countries or regions producing the eight vaccines approved so far, enabling transportation to be accomplished by truck and domestic air networks that have fewer parked aircraft than international ones due to the pandemic-induced travel decline. Vaccines were also distributed in small, frequent batches, making it easier to manage. UNICEF recently said that in the 117 countries where vaccines were first delivered, the reliability of air transport schedules was 100%.

Lots of preparation by logistics providers, airlines and airports enabled the smooth distribution, but also making it possible was behind-the-scenes collaboration between industry and safety authorities to modify regulations governing transportation of dangerous goods so vaccine shipments weren’t delayed. The International Air Transport Association quickly mobilized late last year to address technical rules associated with genetically modified organisms, lithium batteries, dry ice levels and hand sanitizer — topics that aren’t obviously associated with vaccine distribution and were largely overlooked by the press — to support the speedy movement of doses by airlines.


It was a situation of “overregulation [because] vaccines pose a very minimal risk in transport,” said David Brennan, IATA’s assistant director for cargo safety and standards, during a media briefing last month on the state of the air cargo sector.

The International Civil Aviation Organization, which sets standards and publishes detailed instructions for the safe cross-border transport of dangerous goods by air, in January amended its technical guidance to simplify compliance requirements for vaccine shipments. International standards typically take two years to update, but the organization’s dangerous-goods panel rushed through changes in a few months.

Airline industry officials realized early on that some COVID vaccines under development were subject to dangerous-goods regulations — unless authorized for use by the state of origin, the state of destination or any state through which they move — because they included what are classified as genetically modified microorganisms.

IATA raised the issue with the World Health Organization and ICAO “because we saw this was an unnecessary impediment” considering concerns around GMOs are typically associated with plants, and even animals, that could interact with the natural environment and produce unintended reproductive consequences, Brennan said. 


“We made a case that this didn’t apply to materials such as vaccines because even if you were to break a vial the product would simply be destroyed and doesn’t interact with the natural environment in the way that plants and animals could,” he said. 

A United Nations subcommittee of experts on the  transport of dangerous goods late last year agreed that provisions dealing with transport of genetically modified materials were not intended to deal with vaccines and removed COVID-19 vaccines from being classified as genetically modified microorganisms. ICAO adopted the change for its instructions to air operators.

Data loggers and dry ice

Most pharmaceutical companies put data loggers in the packages holding vaccines because they want to know where their shipments are and that they stayed within a prescribed temperature range required to maintain product integrity. The small devices use a sensor to collect data such as temperature, humidity, vibration and light, and a microprocessor for internal data storage. Some devices include location tracking and can transmit data wirelessly in real time to alert shippers of any warming. 

The COVID vaccine from Pfizer Inc. (NYSE: PFE) and BioNTech , for example, must be kept at subfreezing temperatures (minus 70 degrees Celsius), while the Moderna (NASDAQ: MRNA) vaccine has a storage temperature of minus 20 degrees Celsius — temperatures far below what is required for standard life-sciences shipments.

Data loggers are powered by lithium metal or lithium-ion batteries, which are classified as dangerous goods because under certain circumstances they can overheat and ignite. Lithium batteries are banned as cargo on passenger aircraft and face a host of documentation, labeling and trained-personnel requirements for transport on cargo aircraft. The rules apply regardless of whether the lithium batteries are shipped as cargo by themselves or are in data loggers placed in, or attached to, packages of cargo. 

Hong Kong-based carrier Cathay Pacific this year began a phased rollout of a new track-and-trace system for temperature sensitive and fragile shipments that uses low-energy Bluetooth transmitters placed in individual boxes to record and transmit GPS position and other conditions. Staff in an operations center can take steps to intervene if any cargo experiences a temperature excursion, delays, equipment malfunction or damage on the ground. 

IATA questioned why vaccine packages with a small lithium-ion battery required a special hazardous material mark when the batteries were simply associated with a shipment of pharmaceuticals. The dangerous goods panel and ICAO again agreed that adding the factory mark on the packaging didn’t yield any significant safety benefit and exempted the documentation and marking requirement for packages containing COVID-19 vaccines. 


Dry ice packaged in large insulated containers is frequently used as a refrigerant for vaccines and other pharmaceutical products moving by air, but it also poses a potential hazard during air transport. That’s because dry ice is carbon dioxide in solid form, and when it breaks down it becomes a gas, not a liquid. In an enclosed area, such as an aircraft, higher levels of CO2 can pose a risk to occupants or people working in the cargo compartment.

At reduced pressures, like those in an airplane cabin, the sublimation rate of dry ice will increase. The risk is that CO2 will replace oxygen in the crew or passenger compartments and interfere with the ability to breathe, impairing brain function and leading to asphyxiation. The risk varies based on the amount of dry ice carried, the sublimation rate and the amount of ventilation, according to aviation experts.

The amount of dry ice allowed on an airplane dictates how many refrigerated containers it can carry.

Using data provided by the manufacturer, airlines are required to determine the maximum quantity of dry ice they can carry on their aircraft. Manufacturers like Boeing and Airbus recommend lower dry ice levels because they assume a passenger plane has a full load of people who give off CO2 as they breathe. The guidelines, however, didn’t account for the new innovation of cargo-only flights in which airlines switched aircraft to dedicated cargo operations when passenger travel evaporated. 

Airlines asked U.S. and European regulators for more flexibility because carbon dioxide emissions from passengers could be excluded from the calculations and vaccine manufacturers developed sophisticated packaging systems that were able to keep the sublimation rate at 0.3% per hour compared to manufacturers’ guidance of about 1% per hour, Brennan said.

Manufacturers responded by revising their guidance to include tables that showed the maximum amount of dry ice allowed on passenger aircraft when no passengers are carried and sublimation rates are very low. 

“We have been in touch with Boeing and Airbus to review the dry ice limits,” said Kevin Fung, head of cargo global operations for Cathay Pacific, in a press release earlier this year. “There are even limits as to how much we can carry on freighters, albeit they are more generous limits. There has been progress, especially on the Airbus A350 and aircraft with limited numbers of passengers onboard.”

The United Arab Emirates’ civil aviation authority recently granted Etihad permission to carry five times more dry ice on Boeing 787 and 777 aircraft, enabling it to carry more frozen and deep-frozen vaccines. 

Hand sanitizer

Even getting hand sanitizer on aircraft to keep crews and passengers safe from COVID transmission was tied up in red tape. ICAO’s own recommendations for recovery from the pandemic says airlines should provide sufficient quantities of cleaning and disinfectant products that are effective against COVID-19 for use during flight, but international regulations didn’t permit the product on board unless an airline had specific authorization from a national regulatory body.

ICAO agreed to an IATA proposal that alcohol-based hand sanitizers be added to the list of dangerous goods airlines are allowed to carry on board as part of their service offering to passengers so they don’t have to apply for specific authorization. Under the amended rules, airlines can carry spare quantities of hand sanitizer and related cleaning products for the return flight. 

In announcing its first delivery of the Sinovac vaccine from China to Mexico in late February, Cathay Pacific said one of the operational challenges for airlines is efficiently repositioning empty insulated containers because the origin and destination of vaccine shipments is very different from that of regular pharmaceutical traffic. There usually isn’t medicine to transport on the return so carriers have to haul empty containers, taking up potential space for other revenue-generating cargo.

Usually cooltainers would be returned back to their base when space becomes available on return flights, but the pandemic crisis requires they be returned immediately to enable more vaccine distribution. Cargo divisions need to closely examine their schedules, negotiate deals with freight forwarders that take the trade imbalance into account and line up equipment from vendors to meet demand on various routes. 

Click here for more FreightWaves/American Shipper stories by Eric Kulisch.

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Eric Kulisch

Eric is the Supply Chain and Air Cargo Editor at FreightWaves. An award-winning business journalist with extensive experience covering the logistics sector, Eric spent nearly two years as the Washington, D.C., correspondent for Automotive News, where he focused on regulatory and policy issues surrounding autonomous vehicles, mobility, fuel economy and safety. He has won two regional Gold Medals and a Silver Medal from the American Society of Business Publication Editors for government and trade coverage, and news analysis. He was voted best for feature writing and commentary in the Trade/Newsletter category by the D.C. Chapter of the Society of Professional Journalists. He won Environmental Journalist of the Year from the Seahorse Freight Association in 2014 and was the group's 2013 Supply Chain Journalist of the Year. In December 2022, he was voted runner up for Air Cargo Journalist by the Seahorse Freight Association. As associate editor at American Shipper Magazine for more than a decade, he wrote about trade, freight transportation and supply chains. Eric is based in Portland, Oregon. He can be reached for comments and tips at [email protected]