March 15, 2006

Dear Dr. Gerberding:

Every reasonable step must be taken to reduce the opportunity to permit a pandemic to move unchecked through a global travel network. To this end, I am writing to you on behalf of the Association of Corporate Travel Executives (ACTE), an organization representing 2,500 companies in 40 countries -- and thousands of business travelers in the air at any given time.

ACTE supports the intent of a proposed rule-making by the Centers For Disease Control and Prevention requiring the airlines and ship operating companies to maintain passenger lists, and seating manifests (whenever possible), for the sole purpose of alerting travelers who may have been exposed to an infectious disease among the nine listed in the proposal for quarantine (plague, cholera, tuberculosis, yellow fever, diphtheria, smallpox, avian influenza, and the hemorrhagic fevers Ebola, Marburg and Crimean-Congo). The proposed rule change should also make some provision to monitor charter and business flights as well. The proposed rule change requests that this data be saved for 60 days.

In an ACTE poll of US business travel management executives taken last November, seventy percent state they would back regulatory action requiring carriers to store this data and make it available to public health officials in the face of preventing an outbreak.

Yet in providing this support, I am requesting a clarification on how the 60-day period was determined. In the interest of getting the support of the business travel management profession, the proposed rule change should emphasize that these passenger manifests may not be used for any other purpose other than an issue of public health, with access to such information kept highly restricted. This information should not be held any longer than necessary.

The cost of compiling and storing this information is estimated by the airlines to run into the tens of millions of dollars. However, the effort to contain a pandemic should not be solely construed as the responsibility of the nation's airlines nor should it require the replication of any other systems already in place. These costs should be included in the $7 billion that President Bush has asked Congress to allocate for pandemic preparedness. Attempting to recoup the costs of compiling and storing this data by additional taxes on air travel, will be self-defeating and may come at time when the public will be reducing both domestic and international travel due to pandemic concerns.

ACTE also supports the concept of the proposed ruling that would require "the captain of a conveyance" to report passengers displaying the symptoms of the ten diseases listed by the agency for quarantine. Yet this is another area requiring clarification and specific definition. The terms under which a passenger would be determined to be a candidate for quarantine examination must be fully defined. It must be clear the intent is not to quarantine passengers with mild fevers or colds.

This issue of quarantine raise several important questions:
• What exactly will the quarantine process entail?
• What level of medical treatment will be provided to quarantined travelers?
• What redress is open to travelers selected for quarantine in terms of getting a second opinion or seeking their own medical attention?
• Will the 18 quarantine stations in the United States be sufficient to handle the numbers of people likely to be quarantined in the event of a pandemic?

Hurricane Katrina gave us a vivid example of what happens when local, state, and federal resources are simply overwhelmed by numbers. SARS demonstrated the impact of disease on major municipalities and a global economy. This is the time to move forward on an international level, with an international plan. Protocols for alerting passengers, quarantine, and treatment need to be developed and implemented uniformly, throughout the world.

Our Airborne Contagion Advisory Group -- the first of its kind in the industry -- is at your disposal for disseminating information to the traveling public, or for gauging industry response to new proposals

Sincerely,

Greeley Koch
ACTE President

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