Travelling with CPAP for first time

My partner and I are off for a well deserved short break tomorrow - 4 days in Budapest, with me travelling with my CPAP machine for the very first time on an airline (British Airways). I am fully equipped with standard letter from ResMed and letter from my sleep doctor, so hopefully we will have no issues getting through airport security.

I'll post when I get back with news of my experiences.

Magicdave wrote:My partner and I are off for a well deserved short break tomorrow - 4 days in Budapest, with me travelling with my CPAP machine for the very first time on an airline (British Airways). I am fully equipped with standard letter from ResMed and letter from my sleep doctor, so hopefully we will have no issues getting through airport security.

I'll post when I get back with news of my experiences.

You have two issues: (1) going through security and (2) getting on the airplane.

(1) Is pretty straightforward. TSA sees xPAPs all the time. Just take it out of the carrying case like a laptop. You can make them put on clean gloves before they paw it: http://www.tsa.gov/traveler-information ... -and-apaps

(2) British Airways requires advance notification that you are carrying a CPAP onboard: http://www.britishairways.com/travel/ba ... blic/en_us# If you want to run the machine on your flight, check out seatguru.com for electrical outlets on the plane unless you are traveling with a battery.

Hi, Dave.
I cannot stress too much the importance of bringing your cpap as a carry on.
This is the very LAST thing you want damaged or "diverted".
Any meds should also be on your person.
Most baggage handlers are not careless or malicious--most of the time.
Happy trip!

Just contacted BA to inform them - seems like it is not a problem but they have made a note on my booking that I will be carrying the machine.

Magicdave wrote:Just contacted BA to inform them - seems like it is not a problem but they have made a note on my booking that I will be carrying the machine.

I've actually never contacted an airline in advance to inform them that I was carrying a CPAP (because I was ignorant of these policies), but better safe than sorry!

You can pre-board on account of your carrying an "assistive device," and if you do pre-board, your CPAP has priority over all other carry-on items except folding wheelchairs. If you don't preboard, it's first-come, first-served. This is an important tidbit if the flight is overcrowded and the airline starts making people check their carry-on luggage. As noted above, you want to avoid at all costs being forced to check your CPAP machine, and if you have gotten your stuff into "priority stowage," it will be the last to go. So if it looks like it's a full flight, by all means pre-board and put your CPAP in the "priority stowage" section.

I made this luggage tag (the CFR does apply to foreign carriers):

I have travelled overseas several times now and have not had any trouble. I dont bother trying to use it on the plane as its too much trouble and i never sleep well on a plane anyhow. When you go through security just open the top flap and say its a cpap and no problems.Some airlines will not count it as carry on luggage and some will.I also carry a backup battery and a three mtr ext cord as you never know where the point will be.Most hotels supply bottled water and if they dont its because their local water is fine.(eg Sydney)Good luck with your trip.

Drowsy Dancer wrote:(the CFR does apply to foreign carriers):

Maybe.....

§ 382.67 wrote:As a foreign carrier, you must meet the requirement of paragraph (a) of this section for new aircraft ordered after May 13, 2009 or delivered after May 13, 2010.

There are still a lot of aircraft older than that in regular international service to the US.

Also, in general, It is quite moot whether an xPAP qualifies as an Device under 14 § 382 as it is not mentioned explicitly and OSA is not generally regarded as a disability.

There are other FAA regulations which do explicitly mention xPAP devices and it seem likely that they would not be required if 14 § 382 provided adequate coverage.

Lastly 14 § 382 also includes a variety of notifications which are required of the traveller, so if you wished to exercise any perceived right associated with it, you'd need to be quite careful that all the relevant provisions related to notification are adhered to.

For any one who wants to look for themselves at Nondiscrimination on the Basis of Disability in Air Travel 14 § 382, it can be found here http://airconsumer.dot.gov/rules/382short.pdf

billbolton wrote:
Also, in general, It is quite moot whether an xPAP qualifies as an Device under 14 § 382 as it is not mentioned explicitly and OSA is not generally regarded as a disability

This is not a correct statement for purposes of the Air Carrier Access Act.

Look at the definitions section of the current implementing regs of the Air Carrier Access Act, 14 CFR 382.5(a)(1). For the purposes of the ACAA, a "person with a disability" is defined as:

"Individual with a disability means any individual who has a physical or mental impairment that, on a permanent or temporary basis, substantially limits one or more major life activities." 382.5(a).

"Physical or mental impairment" is defined as "Any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: * * * respiratory * * * ."

"Major life activities" include "breathing." 382.5(b). D'oh.

"Assistive device" is defined as: "any piece of equipment that assists a passenger with a disability to cope with the effects of his or her disability. Such devices are intended to assist a passenger with a disability to hear, see, communicate, maneuver, or perform other functions of daily life, and may include medical devices and medications." 382.3. Are you seriously arguing that breathing is not a function of daily life?

One of the difficulties is that the .pdf you have referenced as a source of the implementing regs for the ACAA states that it contains amendments only through July 2003. I can't recommend that anyone rely on this document, which is from ten years ago; the regs have been substantially revised since then, most notably in 2008. A more current version of the regs can be found here: http://www.law.cornell.edu/cfr/text/14/382

It's pretty clear from the subsequent documentation that the DOT does indeed consider CPAPs an "assistive device": airconsumer.ost.dot.gov/rules/Notice_10_28_09.pdf (I travel with a copy of this document in my CPAP bag). Again, if all you're relying on is the DOT's old .pdf as of 2003, you'll miss that.

Finally, if you look at the ACAA Technical Assistance Manuals, available here in the 2005 version: http://www.dot.gov/airconsumer/air-trav ... -employees but 2012 working draft available from the Federal Register here: http://www.gpo.gov/fdsys/pkg/FR-2012-07 ... -15233.pdf , CPAP is specifically referenced as a device eligible for priority stowage. See page 39809 of the 2012 draft TAM. It's very clear there.

Incidentally, it appears that the notice requirements you describe only apply to a request to use CPAP on board , and the regs are generally clear that passengers with disabilities do not need generally self-identify in advance of travel, and the average traveler with a CPAP (i.e., one not using a POC can't be required to produce a medical certificate). Compare 14 CFR 382.25 (no advance notice generally may be required) with 14 CFR 382.27 (notice required to use CPAP). Although there are some weird quirks in the regs, I don't believe a domestic carrier can stop you from carrying a CPAP on board if it meets RTCA/DO-160 standards (and my machine has a manufacturer's sticker on the bottom certifying that it does). I think the regs got a little messed up because of the whole POC issue, but that's another rant for another day.

Drowsy Dancer wrote:2012 working draft available from the Federal Register here: http://www.gpo.gov/fdsys/pkg/FR-2012-07 ... -15233.pdf , CPAP is specifically referenced as a device eligible for priority stowage. See page 39809 of the 2012 draft TAM. It's very clear there.

From that, it looks like the separate regulation on CPAP usage are being amalgamated and harmonised with 14 CFR 382, however, draft regulations need to be ratified before they become effective

It appears from http://www.ecfr.gov/cgi-bin/text-idx?c= ... 64&idno=14 that the 2008 version of the document is the current regulation.

billbolton wrote:

Drowsy Dancer wrote:2012 working draft available from the Federal Register here: http://www.gpo.gov/fdsys/pkg/FR-2012-07 ... -15233.pdf , CPAP is specifically referenced as a device eligible for priority stowage. See page 39809 of the 2012 draft TAM. It's very clear there.

From that, it looks like the separate regulation on CPAP usage are being amalgamated and harmonised with 14 CFR 382, however, draft regulations need to be ratified before they become effective

It appears from http://www.ecfr.gov/cgi-bin/text-idx?c= ... 64&idno=14 that the 2008 version of the document is the current regulation.

By "document" I gather that you mean the TAM, not the CFR. The CFR themselves have been amended since 2008 (and I'm glad that you at least agree that the 2003 version of the 14 CFR 382 is out-of-date). The current, but clearly outdated, TAM is dated 2005, not 2008.

How do we know that the CFR have been amended after 2008? You will note in the reference that you provided that the source for 14 CFR 382 is Docket ID: OST-2004-19482, 73 FR 27665, May 13, 2008, unless otherwise noted (an important qualifier ). When you look at regulations.gov, however, for the history of rule-making with regard to section 382, you will see that technical corrections have been adopted (rules are generally "adopted," not "ratified," IIRC) in 2009 and 2010. http://www.regulations.gov/#!searchResu ... ue;ns=true

And if you really want to drill down into the rule-making process, the Docket ID to track is OST-2005-22298, which allows you to follow the history of the rules specific to "Medical Oxygen and Portable Respiration Assistive Devices" (it's the lumping together of POCs and CPAPs that has led to some of the remaining circularity of the rules IMO).

http://www.regulations.gov/#!docketDeta ... 2005-22298

Other relevant correcting amendments to the ACAA regs can be found by tracking Docket ID: OST-2006-23999

http://www.regulations.gov/#!documentDe ... 23999-0716

And despite that, a flight attendant can over rule everything in the name of "safety" at any time.

BlackSpinner wrote:And despite that, a flight attendant can over rule everything in the name of "safety" at any time.

This is why it is handy to have some knowledge of the significance of all of the rating stickers on the bottom of your machine to plead your case if necessary. I will fight like a wildcat to keep my machine in carry-on, even if I am stopped from using it inflight (everything I know about international electrical ratings I have learned in connection with CPAP).

The main issue I've encountered with FAs is their concern that my machine might emit an electromagnetic frequency that interferes with airplane instrumentation (although not that articulately expressed ). That's where the RTCA/DO-160 rating sticker comes in handy--the FA might not know what that means, but the pilot is highly likely to. A minor digression: on a domestic flight, my particular CPAP is rated as safe to use during 100% of the flight, including takeoff and landing when they usually make you turn off all electronics, because its level of electronic emissions is so low, and I believe there's a reg that in theory would let me do so. I have never bothered to force this point, because who the heck can sleep during takeoff or landing anyway, and I also think it would take more work going through my sheaf of the current regs with the FA to educate him/her than I feel like investing on an airplane.



Fortunately, xPAP machines are now in common enough use that having a machine excluded from carry-on in the name of safety, especially once it's past TSA, is highly unlikely to occur. As I keep saying, I think one of the deepest underlying problems is that people who don't use this kind of equipment seem to lump xPAPs together with (full-time) ventilators and POCs (personal oxygen concentrators) and think of them in the same way. They don't always understand that xPAPs are really just fancy miniature leaf blowers and not dangerous to anyone or anything. They also don't understand that the consequences to someone of not using their CPAP on board are not the same as the consequences to someone of not using their supplemental oxygen on board.

Something on my CPAP advocacy to-do list is to double check the amount of power my CPAP draws when operated without humifier versus the amount of power my laptop draws when operated. It annoys me that the airlines can technically stop you from using the airplane's power to operate an xPAP. There would be riots if they tried that with people's laptops, and a low power draw is another good argument to make to an FA.

None of that matters. Their concept of "safety" overrides everything. If they think your t-shirt will excite someone you can be asked to leave the plane.

BlackSpinner wrote:None of that matters. Their concept of "safety" overrides everything. If they think your t-shirt will excite someone you can be asked to leave the plane.

It's true that their concept of safety overrides everything, but I'm having a hard time envisioning how a simple carry-on bag that has already been cleared by TSA would so incite the FA at pre-boarding that the flight attendant would ask me to leave the airplane, particularly if am remaining calm at all times (as I would be). When discussing these matters at airports I am never shrill or militant about "my legal rights," which tends to put people's backs up, simply pre-boarding to stow my assistive device. Even if they were to stop me from using it on the plane, I'm still on the flight. They won't kick me off the flight midflight just for travelling with a CPAP.

I note that every carrier providing service using aircraft with 19 or more passenger seats has to have a Complaint Resolution Official available at all times (not necessarily in person, but by telephone the very least) and the CRO has must have the authority to overrule everything but a safety decision made by the pilot-in-command. 14 CFR 382.151(e). I think pilots are more concerned about RTCA/DO-60 and the like and are likely to understand the distinction between pressured room air when one sleeps, on the one hand, and supplementary oxygen or a ventilator full-time, on the other.