As COVID-19 vaccines are distributed throughout the United States, the aviation community has looked to the Federal Aviation Administration (FAA) for guidance regarding what restrictions, if any, are to be placed on pilots who receive vaccinations. Fortunately, the FAA has issued guidance which identifies certain limitations for the holders of FAA airmen medical certificates or medical clearances who receive either the Pfizer or Moderna vaccines. Specifically, the FAA, through the Office of Aerospace Medicine (AAM) has stated that those individuals receiving either vaccine must be placed on a 48-hour "no fly/no safety-related duty" hold upon receiving each dose of a Pfizer or Moderna vaccine. Importantly, the FAA has noted the AAM will continue to monitor patient responses to each vaccine dose and may adjust the FAA's policy as necessary to ensure aviation safety.

The AAM has not provided any comments on vaccines which may be developed by manufacturers other than Pfizer or Moderna. As additional vaccines are granted Emergency Use Authorization by the Food and Drug Administration, the AAM will evaluate each vaccine individually and provide additional guidance with respect to such vaccines, as necessary.

Should you have any questions related to the implications of receiving your vaccine, please reach out to a member of Varnum's aviation practice team.

Originally Published by Varnum LLP, January 2021

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