This past week, Jefferey Zients, who serves as the White House Coronavirus Response Coordinator, at a briefing, did not rule out a vaccination or testing requirement for air travelers in the United States. This has led to speculation of over a vaccination requirement to fly. However, the logistics of such a requirement are complex, to say the least.

Leaving open the possibility

Currently, to catch a flight within the United States, there is no federal mandate for air travelers to be fully vaccinated or have proof of a negative test result. Some states, such as Hawaii, have instituted rigorous travel restrictions, but no uniform blanket covers domestic travel. On the international stage, Canada has indicated it plans to require the vaccine for domestic travel.

On September 10th, at a breaking, Mr. Zients stated the following when asked about a domestic vaccination requirement to fly, he stated the following:

"As to travel, we're taking further actions to double the fines for noncompliance of masking on airlines. So, that's a TSA [Transportation Security Administration] action that was announced yesterday. Overall, I think we have a very strong track record that shows we're pulling available levers to require vaccinations, and we're not taking any measures off the table."

This answer was far from a definitive yes, and Mr. Zients does not have the unilateral authority to institute such a requirement. However, it is likely that such a mandate is either being studied or debated, though no firm information has come out.

Stay informed: Sign up for our daily and weekly aviation news digests.

The issue of logistics

Enforcing a mask mandate and enforcing a vaccination or testing requirement are two very different ball games. The first question will be on which actors the burden will fall on to ensure travelers comply with a vaccination mandate.

For the sake of simplicity, we will assume that the only requirement for air travel under a vaccination mandate would be to have passed 14 days from the second dose. This is a fairly common travel requirement already for international travel.

Most people who are getting vaccinated in the United States receive a white CDC-branded card that shows their identifying information, the name of the vaccination received (Pfizer, Moderna, or Johnson & Johnson), identifying information for the vaccine (such as lot number), the date and location where the dose was administered, and a signature from a healthcare professional confirming inoculation.

The question is who would check the vaccination card. Would the burden fall to check-in agents? Would it fall to the TSA agent checking IDs at security? Would it fall to a gate agent? Would a separate vaccination card screening lane or booth need to be set up?

TSA agents have a special scanner that helps them understand the validity of an ID handed to them. A similar kind of system does not exist for the white CDC cards. While there are some telltale signs of a fake vaccination card, imagine a TSA agent with 50 passengers waiting to get through security. They likely would not have the time to verify the accuracy of a card that was just handed to them.

Option two would be to utilize a national database for vaccination status. Essentially, a TSA agent could enter some information from a vaccine card to confirm whether or not they received a vaccination. Again, the issue with this is the time it would take for an individual agent to look up the information.

Another option is to let the burden fall on the airlines. So, when a customer checks in for their flight, they would have to either upload proof of vaccination to an online portal, which some airlines already have in place, or check in physically at a desk at the airport.

This puts an incredible burden on an airline which could, again, be problematic. Not every airline may have the capability to handle a white vaccination card via a mobile portal. This could lead to long lines at airports if check-in agents have to physically verify the validity of each card. A similar issue with confirming validity also applies to airport agents as they do with the TSA.

Children and foreign nationals

In the US, children under 12 are not currently eligible to receive a vaccine. This then raises the question of what a family with tickets in hand for a trip to visit Disneyland are supposed to do. If the parents are vaccinated, and the kids are not yet of age to be vaccinated, would kids be exempt? Would they need to get tested?

Another question is also what happens to foreign nationals. Say, for example, someone comes to the United States from the United Kingdom to study at a university. Then, that student has to go to a conference or on vacation during the holidays to the beaches in Florida, the question becomes what proof of vaccination would be accepted for them.

Another consideration is which vaccines will be accepted. Foreign nationals coming from Europe or Asia may have received a vaccine not approved for use in the United States, like the Astra Zeneca vaccine. Between that and the different methods of verifying vaccination between the US and Europe are just some of the knots that would need to be untangled for it to work.

Hawaii continues to have testing and vaccination requirements for visiting. All children from age 5 through 12 must have a negative test result to avoid quarantine in Hawaii. Anyone not vaccinated in the US or a US territory otherwise has to have a negative test to get out of quarantine.

Airlines are against it

By and large, airlines have shown a willingness to take on initiatives to keep passengers safe in the skies without a government directive. Airlines mandated masks for their passengers before the federal government did. Some airlines started instituting load factor caps which, though there was a movement to get the US government to either require or facilitate, no such action came from it.

According to data from the Centers for Disease Control and Prevention (CDC), 53.7% of the total population in the US is fully vaccinated, with 63% having received their first dose. For those eligible to receive the vaccination (age 12 and up), the number is 73.7% having received at least one dose, with 62.8% being fully vaccinated. So, while a large majority of Americans have received the vaccine already, most would comply with a theoretical mandate for air travel.

No US airline CEO has publicly and overtly come out in favor of a mandate asking the US government to set something up. This contrasts with airlines making overtures to the US government asking for a federal mask mandate in 2020.

On Friday, United Airlines CEO Scott Kirby spoke with NPR's Alisa Chang. He was asked about vaccinations for customers, and this is what he said:

"I think that mandating vaccines for passengers is really a government issue. For us to do that, we would probably require some sort of government directive. We have prepared ourselves with technology to be able to upload vaccine cards and track that and implement it if the government ever chooses to go in that direction."

Ms. Chang pushed Mr. Kirby a little more, asking about why some bars, restaurants, and even Broadway can mandate vaccinations for patrons but United couldn't, he answered with the following:

"Well, we're, you know, a federally regulated industry. And, you know, people are in terminals. They're not just our customers. So you go through a security checkpoint, it's to all airlines. It's TSA employees. It's employees at the airport. And so that's just an environment where I don't think it's appropriate for us as an individual business to make that decision and really one that we would need the federal government to take the lead on."

In more words than one, Mr. Kirby is not expressing interest in a mandate. While he says United would be willing to comply with one if necessary, he is not interested in barring the 47% of all Americans (including those who are unable to be vaccinated) from boarding his planes, nor is he interested in denying boarding to the 37% of people over the age of 12 who are not fully vaccinated from flying with them.

Without the support of the airline industry, the burden could fall on the TSA to enforce a vaccination mandate to fly. The logistics around making vaccination a prerequisite to flying in the US is complicated.