TECHNICAL REPORT Considerations relating to passenger locator data, entry and exit screening and health declarations - COVID-19
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Background
A significant decline in the incidence of new COVID-19 cases has been observed in all EU/EEA countries and the UK
[1] and there is growing interest in defining a sound approach to the adjustment of physical distancing measures.
When deciding how to adjust measures to allow entry of other nationals into their territories, countries may take
into consideration the following points:
• Despite the significant decline in COVID-19 incidence, so far no country is approaching zero reported cases.
Even if low levels of transmission are detected in a specific area, the actual incidence can only be confirmed by
undertaking extensive, population-based testing (see list of indicators in the
ECDC Rapid Risk Assessment:
Coronavirus disease 2019 (COVID-19) in the EU/EEA and the UK– ninth update) [2].
• The movement of people increases the risk of SARS-CoV-2 virus re-introduction into areas with low transmission
or where only sporadic cases are being observed. For the EU/EEA countries and the UK, the movement of
people refers not only to tourists, but also to commuters, business travellers and migrant workers. However,
virus re-introduction would not necessarily lead to widespread community transmission if strong surveillance,
extensive testing and robust contact tracing measures are in place in the country of arrival, together with
ongoing risk communication about the importance of personal protective measures, physical distancing, and
hand and respiratory hygiene [3]. Furthermore, minimising the risk of transmission while travelling would lead to
less secondary cases from an infectious passenger, which in turn would result in less virus introductions into the
host country [4]. When these public health practices and measures are in place, a virus re-introduction via
travellers is less likely to lead to uncontrolled outbreaks.
Passenger locator data
The current standard for collecting passenger locator data is a form that was developed as a collaboration between
WHO, the International Civil Aviation Organization (ICAO) and the International Air Transport Association (IATA) in
2012. Its aim is to assist public health authorities in conducting contact tracing of passengers potentially exposed
to a communicable disease during a flight or while travelling, in the framework of the International Health
Regulations (2005) [5]. Passenger locator forms can be used for any conveyance but are most relevant for air-
travel. Depending on the public health regulations in the country of arrival, passengers are asked to fill out a hard
copy in-flight and hand it in, either to the aircraft crew or at passport control.
The purpose of identifying and managing the contacts of probable or confirmed COVID-19 cases is to rapidly
identify secondary cases and prevent further spread. Contact tracing is an essential measure to fight the ongoing
epidemic of COVID-19, in conjunction with active case finding and testing and the application of other measures
such as physical distancing [6,7]. Each country needs to adapt their response to the local epidemiological situation
and according to available resources. The rigorous application of contact tracing measures can reduce further
transmission and have a major impact on the spread of the outbreak [6,7]. Contact tracing is crucial during the
current phase of the COVID-19 pandemic when countries are adjusting their control measures.
Passenger locator data should be made available to the public health authorities as soon as possible so that they
can initiate contact with exposed passengers. The prompt availability of accurate passenger locator data is
extremely important for the success and effectiveness of contact tracing operations. This enables public health
authorities to identify and notify contacts of an infected case for active follow-up and the provision of relevant
advice.
Current European legislation requires data provided by passengers during the process of booking and checking in
for a flight to be communicated by the airlines to law enforcement and immigration authorities. For passengers
arriving from countries outside the Schengen area, and with the aim of combatting illegal immigration, the airlines
transfer the advance passenger information (API) data under EU Directive 2004/82 [8]. The Schengen Borders
Code explicitly states that the data gathered under Directive 2004/82 may be used to determine that a person is
not a threat to public health [9]. For passengers within the Schengen area, with the overall aim of combatting
terrorism, a similar set of data – a Passenger Notification Record (PNR) – is collected and shared with certain
competent authorities in the Member States under EU Directive 2016/681 [10]. This is also shared with Australia,
Canada and the USA under international agreements. To date, public health authorities have not been included in
the list of designated competent authorities that can receive PNR data, either automatically or on request. When
airlines receive requests for passenger data for contact tracing purposes due to a communicable disease incident,
they manually extract the relevant flight PNR and communicate it to the requesting authority.
However, obtaining API or manually extracted PNR data is a slow process fraught with challenges, such as double
records, incorrect phone numbers, etc. A recent report by the California Department of Public Health (CDPH) in
USA reviewed work on the identification and monitoring of incoming international travellers from January to
17 March 2020. During that period, the CDPH staff tried to locate and monitor international passengers using the
API and PNR data provided by federal authorities, in an activity similar to contact tracing (although the latter works
backwards from a known confirmed case). Only three passengers, out of 11 574 records (26/100 000 passengers)
were eventually identified as confirmed COVID-19 cases in the state database, at a cost of 1 694 hours of
personnel time, 34% of which was outside normal working hours. Moreover, two of the three identified passengers