GAO-26-108488, COVID-19: Federal Efforts and Stakeholder Views on Expediting the Transportation of Personal Protective Equipment (2026-09-14)

Summary

GAO-26-108488, a September 2026 Government Accountability Office report to congressional committees on federal efforts and stakeholder views on expediting the transportation of personal protective equipment (PPE) during the COVID-19 pandemic. It states that from March through June 2020 FEMA conducted Project Airbridge, funding 437 flights to transport approximately 1.2 billion PPE items, primarily gloves, masks and gowns. It describes DOT's use of legal authorities, including Federal Aviation Administration exemptions allowing certain passenger air carriers to carry cargo in passenger cabins. Many stakeholders GAO interviewed said an increased federal role was unnecessary or could have had negative consequences.

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Cite this document

“GAO-26-108488, COVID-19: Federal Efforts and Stakeholder Views on Expediting the Transportation of Personal Protective Equipment (2026-09-14).” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-26-108488-covid-19-federal-efforts-and-stakeholder-views-on-expedi-e8ecb1f26d/, SHA-256 45546c2a749f99ed4af72afd00287a923529c1a3b810ab620ecc311e45c32851.

Full text

COVID-19:

Report to
Congressional Committees

September 2026

GAO- 26-108488

United
States Government Accountability Office

Highlights

A report to congressional
committees

Contact: Elizabeth Repko at RepkoE@gao.gov

What GAO Found

Personal protective equipment (PPE)—such as masks and
gloves—helps minimize exposure to hazards, including illnesses. In response to
the COVID-19 pandemic (March 2020–May 2023), the Federal Emergency Management
Agency (FEMA) and the Department of Transportation (DOT) expedited the transportation of PPE by air and helped mitigate
supply chain challenges.

· FEMA . From March through June 2020, FEMA conducted Project
Airbridge, in which FEMA paid for the air transportation of PPE from overseas
to the U.S. to reduce shipment times. FEMA funded 437 flights to transport
approximately 1.2 billion PPE items, primarily gloves, masks, and gowns.

· DOT . DOT used selected legal authorities to help expedite
the transportation of PPE by air and to provide transportation industry
stakeholders with regulatory relief that could have expedited the
transportation of PPE. For example, DOT’s Federal Aviation Administration
issued exemptions from certain regulations during the COVID-19 pandemic to
allow certain passenger air carriers to transport cargo in the passenger cabins
of aircraft.

DOT and other federal agencies also coordinated with
transportation industry stakeholders specifically to mitigate supply chain
issues and keep goods moving during the pandemic, which may have expedited the
transportation of PPE.

Boxes of Personal Protective Equipment Transported in
the Passenger Cabin of an Aircraft During the COVID-19 Pandemic

Stakeholders GAO interviewed shared perspectives on methods
to expedite the transportation of PPE used during the COVID-19 pandemic, and
many said that an increased federal role was unnecessary or could have had
negative consequences. For example, two stakeholders cited the use of “peel
piles” to designate areas at ports for containers from specific shippers as a
method used to expedite goods during the pandemic, including PPE. Many
stakeholders said they did not think more federal involvement was needed in
expediting the transportation of PPE during the pandemic, or that increased
federal involvement could have had negative consequences. For example,
stakeholders said that federal involvement in prioritizing a container on a
ship could have caused delays at ports. Furthermore, several of these
stakeholders stated that the private sector and industry partners were better
suited to take the lead in expediting the transportation of goods through the
supply chain.

Why GAO Did This
Study

During the COVID-19 pandemic, significant challenges, including
global demand and supply chain issues, made it difficult to quickly access PPE.
Delays in the transportation of PPE may have contributed to the spread of
COVID-19, which killed nearly 1.2 million people in the U.S. as of June 1,
2024.

Public Law 118-159 includes a provision for GAO to
review the expedited transportation of PPE during the COVID-19 pandemic. This
report describes, among other things, (1) how DOT and other relevant federal
agencies expedited the transportation of PPE during the pandemic, including
using selected legal authorities to do so; and (2) selected industry
stakeholder perspectives on methods used to expedite the transportation of PPE
during the COVID-19 pandemic, including their views on whether an increased
federal role was needed.

GAO reviewed documentation and interviewed officials
from five federal agencies that played a role in expediting the transportation
of PPE: DOT, FEMA, Health and Human Services (HHS), the Department of Defense,
and the Federal Maritime Commission. GAO also reviewed relevant statutes,
regulations, and executive orders and analyzed available data from FEMA and HHS
that described the amount and type of PPE that these agencies transported
during the COVID-19 pandemic.

GAO interviewed a nongeneralizable sample of 21
stakeholders representing three groups relevant to the transportation of PPE:
transportation industries, health care distributors, and port authorities. GAO
selected these stakeholders based on factors including geographic diversity,
involvement in federal efforts to expedite the transportation of PPE, or market
share of their respective industry.

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Letter

September 14, 2026

The Honorable Ted Cruz Chairman The Honorable Maria Cantwell Ranking Member Committee on Commerce, Science, and Transportation United States Senate

The Honorable Sam Graves Chairman The Honorable Rick Larsen Ranking Member Committee on Transportation and Infrastructure House of Representatives

During the COVID-19 pandemic, a range of
challenges—including global demand, supply chain issues, and limited domestic
production—made it difficult to quickly access personal protective equipment
(PPE). [1] PPE—such as face shields, masks, respirators, gowns, and gloves—helps minimize
exposure to hazards, including illnesses. Even when PPE could be manufactured
and purchased, delays in shipping often prevented medical professionals and
others from receiving it quickly. These transportation delays may have
contributed to the spread of COVID-19, which killed nearly 1.2 million people
in the U.S. as of June 1, 2024, according to the Centers for Disease Control
and Prevention.

During the pandemic, federal agencies, including the
Department of Transportation (DOT) and the Federal Emergency Management Agency
(FEMA), as well as the transportation industry, took actions to help expedite
the transportation of PPE. For the purposes of this report, we define “expediting”
the transportation of a good as reducing the amount of time the good spends in
transit using various methods, such as prioritizing the transportation of that
good over other goods.

The Servicemember Quality of Life Improvement and National
Defense Authorization Act for Fiscal Year 2025 includes a provision for GAO to
review the roles that DOT and other relevant federal agencies played in
expediting the transportation of PPE and how relevant stakeholders interacted
during the COVID-19 pandemic to transport PPE, among other things. [2] In this report, we describe

1. how DOT and other relevant federal agencies expedited the transportation
of PPE during the COVID-19 pandemic, including using selected legal authorities
to do so; and

2. selected industry stakeholder perspectives on methods used to expedite
the transportation of PPE during the COVID-19 pandemic, including their views
on whether an increased federal role was needed.

To describe how DOT and other relevant federal agencies
expedited the transportation of PPE during the COVID-19 pandemic, we selected
five federal agencies that played a role in doing so: DOT, FEMA, the Department
of Defense (DOD), the Federal Maritime Commission, and the Department of Health
and Human Services (HHS). [3] We also selected seven relevant offices and operating administrations within
DOT: the Federal Aviation Administration (FAA); the Federal Motor Carrier
Safety Administration (FMCSA); the Federal Highway Administration; the Maritime
Administration (MARAD); the Federal Railroad Administration (FRA); the Office
of the Assistant Secretary for Aviation and International Affairs; and the
Office of Intelligence, Security, and Emergency Response. [4] We reviewed relevant statutes,
regulations, executive orders, and agency documentation. We also interviewed
officials from these selected agencies, offices, and operating administrations
regarding their roles and responsibilities related to transporting PPE; their
legal authorities that could be used to help expedite the transportation of
PPE; and whether they used those legal authorities during the pandemic.

In addition, we analyzed available data from FEMA and HHS
that described the amount and type of PPE that these federal agencies
transported during the COVID-19 pandemic. Because there is no single source of
data describing the total amount of PPE that federal agencies transported, we
obtained these data to provide examples of selected federal agencies’ efforts.
To assess the reliability of these data, we interviewed agency officials
about their data collection and quality control practices. We determined that
these data were sufficiently reliable for our purpose of describing the amount
of PPE that selected federal agencies transported during the pandemic.

We also analyzed U.S. Census Bureau trade statistics from
January 2018 through December 2024 to describe the amount and type of PPE
imported during the COVID-19 pandemic. We chose this period to examine how
imports changed after the pandemic compared with what they were before, for
context. To assess the reliability of these data, we reviewed relevant
documentation and conducted electronic data testing. We determined that these
data were sufficiently reliable for our purposes of describing the amount of
PPE imported during the pandemic. See appendix I for more information on how we
analyzed these data.

To describe industry stakeholder perspectives on methods
used to expedite the transportation of PPE during the COVID-19 pandemic,
including their views on whether an increased federal role was needed, we
interviewed a nongeneralizable sample of 21 stakeholders. [5] These selected stakeholders
represented three groups relevant to the transportation of PPE: transportation
industries, health care distributors, and port authorities. [6] We interviewed representatives from
these groups about a range of topics, such as their role in transporting and
expediting PPE during the COVID-19 pandemic, how they coordinated with
different stakeholders and federal agencies to do so, and challenges they
experienced. We used a range of criteria to select industry stakeholders to
interview, such as geographic diversity, involvement in federal efforts to
expedite PPE, or market share of their respective industry. In addition, in
September 2025, we conducted site visits to Seattle and Los Angeles to meet
with selected port authorities and terminal operators.

We conducted this performance audit from May 2025 through
September 2026 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings
and conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.

Background

PPE Imports During the COVID-19 Pandemic

According to U.S. Census Bureau trade statistics, the U.S.
imported approximately $108 billion in PPE from January 2018 through December
2024; of this, $65 billion was imported during the pandemic (January 2020
through December 2022) (see fig. 1). [7] Nearly 40 percent of PPE imported into the U.S. during the
pandemic—approximately $25 billion in PPE—was imported through West Coast
ports. [8] Approximately $19 billion, or about 30 percent, of PPE imported during the
COVID-19 pandemic was imported through the Los Angeles district (including the
ports of Los Angeles and Long Beach). [9]

Figure 1: Value of Personal Protective Equipment (PPE)
Imported from 2018 Through 2024

Note: We have adjusted all import values for inflation,
using monthly import price indices from the Bureau of Labor Statistics to
identify the average inflation adjustment for 2024, which we used as the base
for the yearly adjustments.

Of the approximately $65 billion in PPE imported during
the pandemic, over $20 billion was for masks, and $27 billion was for gloves
(see table 1).

Table 1: Dollar Value of Personal Protective Equipment
(PPE) Imported During the COVID-19 Pandemic, 2020 – 2022

Source: GAO analysis of U.S. Census Bureau trade statistics. | GAO‑26‑108488

a We adjusted all import values for inflation,
using monthly import price indices from the Bureau of Labor Statistics to
identify the average inflation adjustment for 2024, which we used as the base
for the yearly adjustments.

Challenges at Ports During the COVID-19 Pandemic

We and others identified various factors that contributed
to congestion at ports during the COVID-19 pandemic. [10] After the onset of the COVID-19
pandemic in March 2020, the number of U.S. import shipments overall declined
briefly, before rebounding from July 2020 through December 2021 and exceeding
prepandemic levels. [11] This increase in cargo volume, together with other factors—including limited
storage space, reduced capacity due to labor shortages, and limited technology
and equipment—contributed to congestion at ports. The Congressional Research
Service reported in 2021 that dozens of ships were at anchor waiting to dock at
ports in locations such as Los Angeles and Long Beach. Figure 2 shows examples
of challenges at ports related to transporting goods during the pandemic. These
challenges at ports resulted in delays for all goods, including PPE, during the
pandemic. The Health Industries Distributors Association estimated that medical
supplies, including PPE, were delayed an average of 37 days throughout the
transportation system. [12] This included an average 17-day delay at ports, 11-day delay by rail, and 9-day
delay by motor carrier.

Figure 2: Examples of Challenges at Ports Related to
Transporting Goods During the COVID-19 Pandemic

Labor shortages. The U.S. International Trade
Commission reported that port, rail, and motor carrier industries faced labor
shortages, which caused delays in transporting goods. [13] Specifically, according to Customs
and Border Patrol, the Port of Los Angeles had a backlog of containers in May
and June 2020 because warehouse operators had reduced their staff when cargo
drastically declined at the beginning of the COVID-19 pandemic. This reduction
led to a lack of available staff when cargo volumes increased after a few
months.

Limited equipment and technology. The fluctuations
in demand during the COVID-19 pandemic also highlighted limitations in
technology and equipment. For example, when demand rebounded, some ports
experienced shortages of chassis and storage containers. In addition,
information systems and automated technology, which could be used to increase
efficiencies, varied by port. We previously reported that U.S. ports have
adopted automated technology to varying degrees. Port stakeholders have said
that these technologies’ effects on the workforce and security, as well as
their performance, have been mixed. [14] For example, a port authority representative told us that port automation would
not have prevented many of the supply chain delays and disruptions that arose
during the COVID-19 pandemic.

Federal Supply Chain Roles and the COVID-19 Pandemic Response

We and others have previously reported on the roles of
FEMA, HHS, and DOT in assisting the supply chain during the COVID-19 pandemic,
including their efforts to assist in the transportation of PPE.

· FEMA. FEMA was responsible for reviewing resource requests
and making priorities and allocation decisions for health and medical resources
needed to respond to the spread of COVID-19 within the U.S. [15] In addition, FEMA was responsible
for coordinating the distribution of those resources across the federal
government, private sector, and other strategic partners in the civilian
market. This included distribution to state, local, tribal, and territorial
governments, as well as to private entities, such as hospitals.

· HHS. HHS led the federal public health and medical
response during the COVID-19 pandemic, including transporting PPE from the
Strategic National Stockpile to areas of need. The Strategic National Stockpile
is a multibillion-dollar inventory of drugs, vaccines, and supplies that can be
provided to states, localities, territories, and Tribes during emergencies. HHS
transported approximately $278 million PPE from the Strategic National
Stockpile during COVID-19, including approximately $206 million worth of masks.
We previously reported on HHS’s efforts to distribute PPE from the Strategic
National Stockpile during COVID-19. [16] HHS also could make priorities and allocation decisions for health and medical
resources needed to respond to the spread of COVID-19 within the U.S. [17]

· DOT. DOT regulates and oversees various modes of cargo
transportation—including trucking, rail, and air. Within DOT, FAA oversees the
safety and efficiency of the national airspace system and distributes federal
financial assistance to airports for airport infrastructure. [18] DOT does not generally have a role
in port ownership and operations. DOT supports ports by providing guidance,
participating in training exercises, and providing funding for infrastructure
projects. [19]

In September and November 2020, we reported on the actions
that HHS and FEMA had taken—with support from DOD—to mitigate supply shortages
and expand the medical supply chain, chiefly through the Supply Chain Task
Force. [20] The Supply Chain Task Force, later renamed the Supply Chain Advisory Group, was
the primary federal body coordinating and managing supply chain
responsibilities. We refer to both in this report as the Supply Chain Advisory
Group. Charged with maximizing the nationwide availability of supplies and
equipment, the Supply Chain Advisory Group focused on accelerating the delivery
of supplies, including PPE. [21]

FEMA and DOT Expedited
the Transportation of PPE Primarily by Air, with Support from Other Federal
Agencies

In response to the COVID-19 pandemic, FEMA initiated
Project Airbridge in March 2020 to expedite the transportation of PPE and other
medical supplies by air from overseas manufacturers. FEMA also worked with HHS
and DOD to help ensure that PPE was distributed to locations where it was most
needed. In addition, DOT used selected legal authorities during the COVID-19
pandemic to expedite the transportation of PPE by air and provide regulatory
relief that could have helped expedite the transportation of PPE by rail or
highway. (See fig. 3.) Finally, some federal agencies shared information and
coordinated with other federal agencies and transportation industry
stakeholders to mitigate supply chain issues during the pandemic.

Figure 3: Selected Federal Roles in Transporting Personal
Protective Equipment (PPE) Through the Supply Chain During the COVID-19
Pandemic

FEMA Imported PPE by Air, and Other Federal Agencies Identified Needs and
Provided Support

From March through June 2020, FEMA conducted Project
Airbridge to reduce the time it took to receive supplies, including PPE, from
overseas manufacturers. FEMA initiated Project Airbridge to serve as a
temporary solution to shortages in the domestic supply of PPE. [22] Under Project Airbridge, FEMA paid
for the commercial air transportation of supplies from an overseas port to a
port in the U.S. According to FEMA, it arranged for air transportation to the
US, and the medical distributors received the PPE at the airport for delivery
to the medical distributors’ warehouses. Medical supply distributors agreed to
distribute at least 50 percent of the transported PPE to customers at a
reasonable price to areas FEMA and HHS prioritized.

FEMA officials said Project Airbridge reduced shipment
times from an estimated 40 days to 7 days by using air freight instead of sea
shipments. According to data that FEMA provided, FEMA funded 437 flights from
March through June 2020 as part of Project Airbridge. In addition, FEMA worked
with six medical supply distributors to transport and distribute approximately
1.2 billion PPE items, primarily gloves, masks, and gowns (see table 2).

Table 2: Personal Protective Equipment (PPE) Items
Imported by FEMA Project Airbridge, March–June 2020

Source: GAO analysis of Federal Emergency Management Agency
(FEMA) Project Airbridge data. | GAO‑26‑108488

a N95 masks are approved by the National
Institute for Occupational Safety and Health to filter at least 95 percent of
airborne particles. See 42 C.F.R. § 84.170. KN95 masks are not approved by
the National Institute for Occupational Safety and Health to meet the same
standard. However, for part of the COVID-19 pandemic, the Food and Drug
Administration authorized certain KN95 masks for health care use, provided
certain conditions were met, under an emergency use authorization.

Several federal agencies provided support to FEMA’s
Project Airbridge. For example, FAA prioritized flights, and the Office of the
Assistant Secretary for Aviation and International Affairs expedited economic
licensing processes for certain air carriers, as described below. [23] In addition, Customs and Border
Protection expedited the customs clearance process for Project Airbridge
flights and formed the COVID-19 Cargo Resolution Team to mitigate challenges
related to importing PPE and other pandemic-related products. The team worked
with FEMA daily to alert ports that shipments of critical medical supplies were
arriving and helped expedite the arrival and clearance of 418 of the 437
Project Airbridge flights. [24] FEMA officials also said that the Department of State played a key role in
facilitating the movement of PPE through China and resolving customs issues
with the Chinese government.

In addition to leading Project Airbridge, FEMA worked with
HHS and the Defense Logistics Agency on the Supply Chain Advisory Group to
assess demand for PPE, identify sources of PPE overseas, and procure and
transport medical supplies and PPE for Project Airbridge and the Strategic
National Stockpile.

· Assessing demand for PPE. HHS officials said HHS and FEMA
created the Supply Chain Control Tower to identify COVID-19 outbreaks and
monitor data on the market demand for PPE in each state, to determine where PPE
could be distributed to address shortages. Specifically, HHS officials said
they used the Supply Chain Control Tower to, among other things, monitor weekly
survey data from medical facilities, including from over 2,000 hospitals, on
the number of days’ worth of PPE they had left. HHS used these data to
coordinate the transportation of PPE from medical distributors to areas with
shortages. To do this, HHS worked with its 11 existing motor carriers,
integrated express carriers, and air cargo partners to transport PPE from the
Strategic National Stockpile to medical facilities with PPE shortages.

· Identifying sources of PPE. FEMA officials said FEMA and
HHS worked to identify available PPE from overseas sources. They began this
effort to resupply the Strategic National Stockpile but shifted to identifying
sources of PPE for the overall U.S. market. Once the Supply Chain Advisory
Group assessed PPE demand in states, FEMA and HHS collaborated to identify
manufacturing companies overseas that had available PPE. FEMA officials said
the agency then coordinated with the State Department to verify that the
manufacturer was a legitimate company and with the Food and Drug Administration
to verify the quality of the PPE.

· Procuring and transporting PPE. The Defense Logistics
Agency worked with FEMA and HHS to procure and arrange transportation for the
PPE from overseas manufacturers once they had identified a source. Defense
Logistics Agency officials said the agency supported 43 FEMA agreements to acquire
PPE and antigen tests for states, and 23 HHS agreements to procure medical
goods, including PPE, for the Strategic National Stockpile, nursing homes, and
test sites. [25] Defense Logistics Agency officials said these shipments were delivered to
government warehouses owned by FEMA and HHS. According to officials, FEMA and
HHS then worked with medical suppliers to organize the delivery of PPE to
hospitals or other areas, as needed. [26] According to FEMA, two maritime carriers were used to ship PPE from Asia to the
West Coast along a 10-day direct sailing route. FEMA used these carriers
because they consistently had available space on their direct sailing vessels,
which allowed FEMA to avoid port delays.

DOT Used Selected Legal Authorities to Help Expedite the Transportation of
PPE, Primarily by Air

DOT used selected legal authorities during the COVID-19
pandemic to expedite the transportation of PPE by air and to provide regulatory
relief that could have helped expedite the transportation of PPE. Through our
review of statutes, regulations, and executive orders, and our interviews with
DOT offices and operating administrations, we and DOT identified eight selected
DOT legal authorities that could help expedite the transportation of PPE (see
table 3).

Table 3: Selected DOT Legal Authorities That Could Help
Expedite the Transportation of Personal Protective Equipment (PPE)

DOT office or operating administration | Legal authority | Description of legal authority | Used during COVID-19
pandemic
Federal Aviation Administration (FAA) | 49 U.S.C. § 40103 | FAA may modify or revoke its assignments of the use
of the navigable airspace when required in the public interest. a | Yes
Regulatory relief | FAA may grant exemptions from certain FAA safety
regulations, if it finds that the exemption is in the public interest. b | Yes
Office of the Assistant Secretary for Aviation and
International Affairs | Emergency interstate air transportation by foreign
air carriers | DOT may temporarily exempt foreign air carriers from
certain statutory requirements and limitations to allow them to carry cargo
in interstate air transportation in certain markets, to the extent it decides
an exemption is in the public interest and if it makes certain findings c The Office of the Assistant Secretary for Aviation and International Affairs
may exercise this authority. d | Yes
Expedited economic licensing for foreign air
carriers, upon request | DOT may issue permits to foreign air carriers
authorizing them to transport cargo between a place in the U.S. and a place
outside the U.S. by aircraft and for compensation, if it makes certain
findings. e The Office of the Assistant Secretary for Aviation and
International Affairs may exercise this authority. f Foreign air
carriers can request expedited proceedings for this economic licensing. g | Yes
Federal Motor Carrier Safety Administration (FMCSA) | Regulatory relief | FMCSA may grant temporary waivers of compliance with,
and exemptions from, its safety regulations under certain circumstances. h | Yes
Federal Railroad Administration (FRA) | Regulatory relief | FRA may issue temporary emergency waivers of
compliance with any part of its railroad safety regulations, if it makes
certain determinations, which include that the waiver is not inconsistent
with railroad safety and is necessary to address an actual, or impending,
emergency situation or emergency event. i | Yes
Office of Intelligence, Security, and Emergency
Response | Defense Production Act of 1950 (DPA), Title I j | The President has delegated DPA, Title I authorities
to DOT with respect to all forms of civil transportation. k These
delegated authorities, in part, permit DOT to require the acceptance and
priority performance of certain contracts or orders over others to promote
the national defense. l The Office of Intelligence, Security, and
Emergency Response may exercise DOT’s delegated, DPA, Title I authorities and
oversees the implementation of the Transportation Priorities and Allocation
System, which are DOT regulations that provide guidance and procedures for
the use of such authorities. m | No
Maritime Administration (MARAD) | DPA, Title VII n | The President has
delegated DPA, Title VII authorities to DOT with respect to all forms
of civil transportation. o These authorities,
in part, permit DOT to consult with representatives of business,
industry, and other interests to develop and establish voluntary agreements to help provide for the national defense. p MARAD, in consultation with the Office of Intelligence, Security and
Emergency Response, may exercise DOT’s delegated DPA Title VII, authorities
as they relate to the use of maritime industry-related facilities and
services, such as port facilities and sealift support, and maritime-related
voluntary agreements. q | No

Source: GAO analysis of statutes, regulations, executive
orders, and Department of Transportation (DOT) information. | GAO‑26‑108488

a FAA is required to assign the use of the
navigable airspace by regulation or order necessary to ensure the safety of
aircraft and the efficient use of airspace. 49 U.S.C. § 40103

b See 49 U.S.C. § 44701(f).

c For example, DOT must find that because of an
emergency created by unusual circumstances not arising in the normal course of
business, air carriers holding certain certificates cannot accommodate traffic
in those markets. See 49 U.S.C. § 40109(g).

d See 49 C.F.R. § 1.25a(b)(6)(i).

e Foreign air carriers that do not hold these
permits are prohibited from providing such transportation. See 49 U.S.C.
§§ 40102, 41301‑41302.

f 49 C.F.R. § 1.25a(b)(6)(ii)(B).

g See 14 C.F.R. § 302.11(e).

h See 49 U.S.C. §§ 31133(a)(10), 31136(e);
49 C.F.R. § 1.87(f).

i See 49 U.S.C. § 20103(g); 49 C.F.R.
§ 1.89(a). FRA emergency waivers must be requested. See 49 C.F.R.
§ 211.45.

j See Pub. L. No. 81‑774, 64 Stat. 798
(1950) (codified as amended at 50 U.S.C. § 4501 et seq.). Title I of the
DPA is codified as amended at 50 U.S.C. § 4511.

k See Exec. Order No. 13603, National Defense
Resources Preparedness, § 201, 77 Fed. Reg. 16651, 16652
(Mar. 16, 2012).

l See 50 U.S.C. § 4511(a); Exec. Order No.
13603 § 201. However, DOT may only exercise its delegated DPA Title I
authorities to support approved programs. See Exec. Order No. 13603 § 202;
49 C.F.R. §§ 33.2, 33.20. An “approved program” is a program that the
Secretary of Defense, Secretary of Energy, or Secretary of Homeland Security
has determined to be necessary or appropriate to promote the national defense,
in accordance with Section 202 of Executive Order 13603. 49 C.F.R. § 33.20.
The DPA defines “national defense” to include emergency preparedness activities
conducted under Title VI of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (Stafford Act). 50 U.S.C. § 4552(14); Stafford
Act, Title VI (codified as amended at 42 U.S.C. § 5195 et seq.).

m See 49 C.F.R. § 1.45(q); 49 C.F.R. pt. 33
(Transportation Priorities and Allocation System).

n See DPA § 708 (codified as amended at 50
U.S.C. § 4558).

o See Exec. Order No. 13603 § 401.

p See 50 U.S.C. § 4558; 44 C.F.R.
§ 332.1. However, DOT may only exercise its DPA Title VII authorities
after certain conditions are met. For example, DOT must find that conditions
exist that may pose a direct threat to the national defense or its preparedness
programs and obtain the required findings and approvals from certain other
executive agencies, such as the Federal Emergency Management Agency. See
50 U.S.C. § 4558(c); 44 C.F.R. § 332.2.

q See 49 C.F.R. § 1.93(l).

Expediting Air Operations and Economic Licensing Processes

FAA and the Office of the Assistant Secretary for Aviation
and International Affairs officials used two of the legal authorities described
in table 3 to prioritize flights carrying PPE and to expedite the economic
licensing process for foreign air carriers transporting PPE.

· Prioritizing flights carrying PPE. FAA officials said FAA
used its legal authority to prioritize takeoffs and landings for domestic and
international cargo flights carrying PPE. [27] Specifically, FAA officials said they coordinated with air traffic control
towers, command centers, and industry stakeholders to identify flights with PPE
and to prioritize those flights for departure or arrival. FAA began to use this
authority at the start of the COVID-19 pandemic to support FEMA’s effort to
import PPE through Project Airbridge and continued to use it after Project
Airbridge ended. In total, FAA prioritized 4,417 flights carrying PPE from
April 2020 through September 2020. [28]

· Expediting economic licensing. Officials from the Office
of the Assistant Secretary for Aviation and International Affairs said the
office used its legal authority to expedite the economic licensing process,
upon request, for foreign air cargo carriers transporting PPE for FEMA’s
Project Airbridge. [29] Specifically, officials said they worked with FEMA daily during the pandemic to
help FEMA identify flights carrying emergency supplies for Project Airbridge.
The office informed air cargo carriers and integrated express carriers of the
steps needed to receive an economic license to transport goods to the U.S. and
helped them expedite the licensing process. According to officials, the office
granted licenses for 2,200 flights transporting PPE primarily from China to the
U.S. from March 2020 through March 2022.

Providing Regulatory Relief

Some DOT operating administrations used their legal
authorities during the COVID-19 pandemic to provide relief from their
respective regulations via exemptions or waivers. DOT officials said that DOT’s
operating administrations issued these exemptions or waivers to keep the supply
chain moving for all types of goods, not specifically for PPE.

· Passenger-to-freight exemptions. FAA issued exemptions
from certain FAA regulations during the COVID-19 pandemic to allow certain
passenger air carriers to transport cargo in the passenger cabins of aircraft. [30] FAA issued these exemptions to
ensure continued air transportation, as passenger travel declined during the
pandemic. One association representing the aviation industry said some air
carriers used the passenger-to-freight exemption to expedite the transportation
of PPE during the pandemic. As shown in figure 4, some airlines used this
exemption to transport cargo, such as PPE, in the aircraft’s passenger cabin.
The exemption described actions air carriers must take to address safety
concerns of using the exemption to transport cargo in passenger cabins. For
example, FAA provided specific requirements for restraining cargo on passenger
seats and limitations on cargo weight and loading.

Figure 4: Boxes of Personal Protective Equipment
Transported in the Passenger Cabin of an Aircraft During the COVID-19 Pandemic

· Hours-of-service exemptions. FMCSA issued an exemption, in
part, from its hours-of-service regulations for drivers actively transporting
supplies necessary for community safety and the prevention of community
transmission of COVID-19, including PPE. [31] FMCSA’s hours-of-service regulations generally provide that the maximum driving
time for commercial motor vehicle operators transporting property is 11 hours
within a 14-hour period. [32] This exemption allowed, but did not require, drivers to exceed this maximum. [33] FMCSA officials said that motor
carriers may have used this exemption during the pandemic and, if so, that this
could have helped expedite the transportation of PPE. In August 2021, FMCSA
issued an extension and amendment of this exemption, which provided that motor
carriers were to begin reporting their use of the exemption each month through
FMCSA’s portal. [34] FMCSA officials said that motor carriers were not required to report to FMCSA
on their use of the exemption and that they did not receive any reports from
motor carriers. Representatives of one motor carrier told us that they were
aware this exemption was available but did not experience a driver shortage
that would require them to use this exemption. The motor carrier representative
also stated that a consideration in using these exemptions is that extending
drivers’ hours could lead to a potential safety risk for drivers and
pedestrians.

· Inspections and testing waivers. FRA issued emergency
waivers of compliance with certain FRA regulations upon request, in part, to
address workforce shortages that were preventing railroads from complying with
such regulations. [35] For example, some rail associations requested FRA to permit freight railroads
to move locomotives between facilities even if they had not inspected and
tested the locomotives within the periods specified in FRA regulations, and FRA
granted them a waiver of those regulations. FRA officials said freight cars may
have had reduced inspections, which could have helped expedite the
transportation of PPE. While available, the waivers were not widely used
because most rail companies were able to keep their operations moving without
using the waivers, representatives from a rail association said.

Using Defense Production Act Authorities

The President has delegated DPA, Title I authorities to
DOT with respect to all forms of civil transportation. [36] These delegated authorities, in
part, permit DOT to require the acceptance and priority performance of certain
contracts or orders over others to promote the national defense. [37] These authorities could help
expedite the transportation of PPE during a national emergency. [38]

According to DOT, it did not use its DPA, Title I
authorities during the COVID-19 pandemic. [39] To do so, DOT officials said DOT must receive a request from an agency with
relevant jurisdiction, such as FEMA or HHS, and that it did not receive such a
request during the pandemic. FEMA and HHS officials said they did not have any
transportation concerns that required DOT intervention during that period. [40]

DOT’s Office of Intelligence, Security, and Emergency
Response collaborated regularly with other agencies to determine whether using
DOT’s delegated DPA Title I authorities was necessary to help expedite PPE
during the COVID-19 pandemic. [41] Officials said the office has an established process to receive and process
requests for other agencies to use DOT’s delegated DPA, Title I authorities. [42] During the pandemic, this process
included weekly interagency meetings with DPA Program Managers from agencies
such as HHS, FEMA, and DOD to discuss the execution of priority ratings and
identify needs for agencies to provide DPA support. FEMA and HHS officials told
us they were aware of DOT’s request process but that they used other methods to
increase the supply of PPE, such as through Project Airbridge, as described
above. DOT officials said the agency has continued to participate in a monthly
DPA interagency working group to coordinate with other agencies on potential
DPA requests.

The President has delegated DPA, Title VII authorities to
DOT with respect to all forms of civil transportation, which, in part, permit
DOT to consult with representatives of industry, business, and other interests
to establish voluntary agreements to help provide for the national defense. [43] MARAD, in consultation with the
Office of Intelligence, Security, and Emergency Response, may exercise DOT’s
delegated DPA, Title VII authorities. [44] DOT officials said that DOT did not use its delegated DPA, Title VII
authorities to enter into new voluntary agreements during the COVID-19 pandemic
because neither FEMA or HHS requested it to do so. MARAD has two existing
voluntary agreements with the maritime industry that were established before
the pandemic: the Voluntary Tanker Agreement and the Voluntary Intermodal
Sealift Agreement. DOT officials said MARAD did not use these agreements to
help expedite PPE during the pandemic because their scopes and purposes would
not have been useful to the transportation of PPE. For example, the Voluntary
Intermodal Sealift Agreement provides DOD with access to commercial sealift
services and systems, including intermodal equipment, when DOD deploys military
forces during a national emergency or wartime operation, or when DOD determines
it is necessary for national security or contingency operations, which did not
occur during the pandemic. [45]

DOT and Other Federal Agencies Shared Information and Coordinated with the
Transportation Industry to Mitigate Supply Chain Issues

DOT’s offices and operating administrations shared
information and coordinated with other federal agencies and transportation
industry stakeholders to mitigate supply chain issues during the COVID-19
pandemic. In addition, other federal agencies, such as the U.S. Transportation
Command and the Federal Maritime Commission, coordinated with transportation
industry stakeholders to keep goods moving through the supply chain. These
efforts may have helped expedite the transportation of PPE.

According to DOT officials, DOT operating administrations
also participated in discussions with transportation industry stakeholders to
share information about the COVID-19 pandemic and distribute PPE to their
respective industries.

· Motor carrier industry. FMCSA officials said the agency
held daily calls with the motor carrier industry to discuss the industry’s
immediate needs and transportation challenges, including those related to the
usage of PPE. FMCSA officials said they also helped address the industry’s PPE
needs by representing motor carriers on the Supply Chain Advisory Group and
requesting that FEMA distribute cloth face masks to motor carrier companies. In
addition, FMCSA officials said the agency also issued press releases to inform
the motor carrier industry of exemptions from certain motor carrier
regulations.

· Maritime industry. MARAD officials said the agency hosted
biweekly calls with maritime stakeholders, including port authorities,
longshoremen’s unions, and U.S. flag vessel operators, to provide COVID-19
updates and learn about challenges the maritime industry was encountering.
According to MARAD officials, MARAD also received and processed around 2.4
million cloth face masks from FEMA and distributed them to around 500 maritime
industry stakeholders.

· Rail industry. FRA officials said they participated in
regular calls with rail associations to discuss the pandemic’s impact on
railroad employees and operations, including the daily number of employees
testing positive for COVID-19, staffing issues, and supply chain challenges. As
part of these calls, FRA officials said they received reports from railroads on
their use of emergency relief provisions and distributed cloth face masks to
rail workers.

DOT’s Office of Intelligence, Security, and Emergency
Response responded to requests for information from other agencies, primarily
through the Supply Chain Advisory Group. Specifically, officials from this
office said that one of their roles during the COVID-19 pandemic was to
coordinate requests for information between the Supply Chain Advisory Group and
DOT operating administrations on issues related to transportation.

According to officials, this information-sharing role
sometimes involved the transportation of PPE. For example, Office of
Intelligence, Security, and Emergency Response officials said they facilitated
communications between the Supply Chain Advisory Group and the Office of the
Assistant Secretary for Aviation and International Affairs when the advisory
group had questions about air freight applications.

Other federal agencies also shared information and
coordinated with transportation industry stakeholders to transport PPE outside
of Project Airbridge and Supply Chain Advisory Group efforts.

· U.S. Transportation Command. U.S. Transportation Command
officials said they held calls with sea vessel operators once every other week.
Officials said they worked with sea vessel operators to use these calls to
share information on challenges affecting the maritime supply chain, such as
port congestion caused by lines of ships waiting to offload cargo at ports.
U.S. Transportation Command officials said that while U.S. flag vessels
typically receive priority berthing access at ports, U.S. flag vessels had to
compete with other sea vessel carriers for berthing access due to high volumes
of ships during the COVID-19 pandemic. One sea vessel operator that transported
PPE said the calls helped U.S. flag vessels get to ports and offload cargo
faster.

· Federal Maritime Commission. Federal Maritime Commission
officials said the agency’s role was focused on advocacy and coordination
during the COVID-19 pandemic. [46] For example, Federal Maritime Commission commissioners sent a letter to MARAD
recommending that MARAD prioritize providing critical medical supplies,
including PPE, to the U.S. maritime workforce. Representatives from one health
care distributor industry association said the Federal Maritime Commission also
communicated with industry stakeholders during the pandemic and worked with
medical distributors to help them expedite PPE shipments at ports, as described
below.

Stakeholders Identified
Methods Used to Expedite the Transportation of PPE; Many Said an Increased
Federal Role Was Not Needed

Stakeholders Generally Did Not Know Which Shipments Contained PPE, but Some
Identified Methods to Expedite Goods

Several of the 21 stakeholders we interviewed,
specifically those that transport goods, said that a key challenge in
expediting the transportation of PPE is the difficulty in identifying which
shipments contain PPE. [47] These stakeholders said they have limited information about, or may not know,
the contents of their cargo, which may be due to how the cargo is labeled or
classified. For instance, one stakeholder said that they generally do not have
specific information about the contents of their containers, unless the goods
are hazardous.

Some stakeholders, including representatives of port
operators and a sea vessel operator, said that having more information about
the contents of shipments could help identify which shipments contain PPE and
may need to be expedited. Stakeholders suggested options for providing that
information, such as tracking databases, customs designations, and commodity-
or class-based freight ratings. [48]

Despite the challenge of having limited information about
the contents of containers, the stakeholders we interviewed identified some
methods to expedite goods, including PPE. For example, stakeholders cited three
methods used during the COVID-19 pandemic. [49]

· Priority berthing. All four of the sea vessel operators we
spoke with said that having priority berthing at a port helped them to more
quickly transport goods during the pandemic. These stakeholders were able to
receive priority berthing for different reasons, including having agreements
with port operators and unions, having their own port terminal, or carrying
specific types of goods (such as U.S. government or sustenance goods).

· Peel piles. Peel piles are designated areas at ports for
containers from a specific shipper. Two stakeholders, representing a port
operator and health care distributors, said they used peel piles specifically
to expedite the transportation of PPE during the pandemic. Some stakeholders
told us that peel piles are an effective way of moving cargo efficiently
because they allow drivers to easily access a specific collection of
containers. For example, a representative of a port terminal operator said that
peel piles help port terminals avoid situations in which drivers need to dig
out certain cargo from a big pile. However, stakeholders said peel piles are
generally used for a large number of containers and that PPE shipments
typically are not big enough to warrant a peel pile. One port operator stated
that they made an exception during the pandemic and created peel piles for PPE
because the product was needed.

· “Skip the line” pass. Two stakeholders representing health
care distributors said that systems were available at ports for truck drivers
to pick up medical supplies through a “skip the line” pass to expedite PPE
during the pandemic. For example, one stakeholder said they worked with ports
to develop a system for truck drivers carrying medical supplies to skip to the
front of the truck queue. This method would ensure that truck drivers picking
up needed medical supplies, including PPE, did not have to wait in the same
line as other drivers that were picking up less critical items, such as
furniture. However, the two motor carriers we interviewed were either not aware
of, or did not use, this system to expedite the transportation of PPE.

Some representatives of ports and port terminal operators
suggested that changing the ways that cargo is loaded and stowed on ships and
unloaded at ports could be used as another method to expedite the
transportation of goods, including PPE. For example, stakeholders said that
containers could be placed strategically on a ship for quicker removal and that
using technology or designated chassis could help unload priority containers
faster. However, some representatives of sea vessel operators said that changing
the methods of loading, stowing, and unloading ships would not be an effective
way to prioritize shipments based on their operations. For instance, ships are
loaded based on weight requirements and origin and destination points, making
it challenging to reorganize containers. Additionally, moving containers around
more than necessary increases the risk of damaging their contents.

Many Stakeholders Said an Increased Federal Role in Expediting the
Transportation of PPE During the Pandemic Was Not Needed

Many stakeholders said they generally did not think that
more federal involvement was needed in expediting the transportation of PPE
during the COVID-19 pandemic, or that increased federal involvement in
expediting goods could have negative consequences. Specifically, several of
these stakeholders stated that the private sector and industry partners were
better suited to take the lead in expediting the transportation of goods
through the supply chain. For example, one stakeholder that transports goods said
their networks were already set up to efficiently move goods through the supply
chain and could be designed to optimize service, cost, and the time it takes to
deliver a shipment. Moreover, representatives of a port operator and sea vessel
operator said that, if the federal government had taken steps to prioritize a
certain ship or container on a ship, it could have resulted in more delays at
ports due to the extra time needed to reorganize containers.

Stakeholders in the transportation industry did not
identify any effects that expediting the transportation of PPE during the
COVID-19 pandemic had on the transportation of other goods. However, some
stakeholders had mixed views on the effect of increasing the federal role in
expediting the transportation of PPE on the transportation of other goods. Two
stakeholders representing port terminal operators said it would be possible to
effectively expedite one good without affecting the delivery of other goods. For
example, one stakeholder said that having sufficient communication and planning
across the supply chain could mitigate any potential effects of prioritizing a
specific good to expedite. On the other hand, two other stakeholders thought
that an increased federal role in expediting the transportation of PPE could
delay other goods or have unintended consequences on critical shipments. For
example, a representative of a sea vessel operator that transports sustenance
goods to Hawaii and Alaska expressed concerns about deprioritizing these goods
to accommodate PPE shipments.

Several stakeholders provided examples of ways that the
federal government could have provided additional support to industry in
expediting the transportation of PPE during the COVID-19 pandemic. [50] Specifically, stakeholders suggested
that the federal government could have increased the amount of communication,
guidance, and data it provided to help industry partners leverage
transportation networks and identify which shipments contained PPE and needed
to be expedited. Some stakeholders found that federal information-sharing
efforts during the pandemic were helpful, such as the Supply Chain Control
Tower’s data on identifying priority areas for PPE distribution.

DOT has taken steps to provide more support to industry
and increase the resilience of the national supply chain since the COVID-19
pandemic. In 2021, as required by the Infrastructure Investments and Jobs Act, DOT
established the Multimodal Freight Office, to administer and oversee certain
DOT multimodal freight grant programs. [51] It develops and manages the National Freight Strategic Plan, and facilitates
information sharing on freight issues between the public and private sector.
One such information-sharing effort is the Freight Logistics Optimization
Works, a public-private partnership that facilitates information sharing
between government and industry. According to DOT, this effort can help
industry stakeholders anticipate changes in the supply chain and take proactive
steps to mitigate delays and has helped DOT establish routine communication
with maritime freight stakeholders. [52] One stakeholder that transports goods said that receiving real-time and
forward-looking data as a part of this effort has been helpful and is useful
during a supply chain bottleneck. [53] Additionally, DOT’s 2026 National Freight Strategic Plan details DOT’s efforts
to pursue national freight policy goals, including making the national freight
system more resilient to disruptions. [54] The plan establishes a coordinated national framework for strengthening the
safety, efficiency, resilience, security, innovation, and workforce of the U.S.
freight system.

Agency Comments

We provided a draft of this report to DOT, DOD, the
Department of Homeland Security, the Federal Maritime Commission, and HHS for
review and comment. DOT, DOD, the Department of Homeland Security, and HHS
provided technical comments, which we incorporated, as appropriate. The Federal
Maritime Commission did not have any comments on this report.

We are sending copies of this report to the appropriate
congressional committees, the Secretary of Transportation, the Secretary of
Defense, the Secretary of Homeland Security, the Chairman of the Federal
Maritime Commission, and the Secretary of Health and Human Services. In
addition, the report is available at no charge on the GAO website at https://www.gao.gov .

If you or your staff have any questions about this report,
please contact me at RepkoE@gao.gov .
Contact points for our Offices of Congressional Relations and Media Relations
may be found on the last page of this report. GAO staff who make key
contributions to this report are listed in appendix II.

Elizabeth (Biza) Repko Director, Physical Infrastructure

Appendix
I: Analysis of U.S. Census Bureau Trade Statistics

To describe the amount and type of personal protective
equipment (PPE) imported during the COVID-19 pandemic, we analyzed U.S. Census
Bureau trade statistics trade data from January 2018 through December 2024. We
chose this period to examine how imports changed after the COVID-19 pandemic
compared with what they were before, for context. For the purposes of this
analysis, we identified the pandemic as taking place from January 2020 through
December 2022. [55]

U.S. Census Bureau trade statistics, a widely used source
analyzing U.S. international trade, do not contain precise data on imports of
products related to COVID-19. As a result, we identified Harmonized Tariff
Schedule codes related to PPE at the 10-digit category. [56] Specifically, to identify Harmonized
Tariff Schedule codes related to PPE, we relied on the U.S. International Trade
Commission’s April and June 2020 list of Harmonized Tariff Schedule codes of
medical supplies relevant to COVID-19, which includes codes specific to PPE. [57] Because the U.S. International Trade
Commission revises Harmonized Tariff Schedule codes regularly, we tracked
changes to these categories using documentation it published. [58] Some of these categories represent
more than one product, and some categories contain products that are not
directly relevant to COVID-19 responses. Therefore, the values presented may
overestimate the imports of products directly relevant to COVID-19 responses.
Nevertheless, the values are useful indicators for tracking import trends of
such products. While the U.S. Census Bureau tracks the quantity of items
imported, we excluded quantity data from our review because quantity data were
not required for some products prior to 2019.

We express import values in U.S. dollars to characterize
trends in imports and to establish trends in a single unit of measure. Since
the unit of measure for quantity (e.g., kilogram or dozens of units) may differ
across products, using quantity to portray trends in import volume could be
misleading, since it would be unclear whether changes were driven by changes in
the composition of products being imported, which might have different units of
measurement or weight, or actual changes in quantity. We adjusted all import
values for inflation, using monthly import price indices from the Bureau of
Labor Statistics to identify the average inflation adjustment for 2024, which
we used as the base for the yearly adjustments.

To assess the reliability of these data, we reviewed
relevant documentation, received responses to questions from knowledgeable U.S.
International Trade Commission officials, and conducted electronic data
testing. We determined that the data were sufficiently reliable for our
purposes of describing the amount of PPE imported during the COVID-19 pandemic.

Appendix
II: GAO Contact and Staff Acknowledgments

GAO Contact

Elizabeth (Biza) Repko, RepkoE@gao.gov

Staff Acknowledgments

In addition to the contact named above, Maria Mercado
(Assistant Director), Mikey Erb (Analyst in Charge), Lilia Chaidez, Melanie
Diemel, Sarah Farkas, Chloe Kay, Robert Letzler, Camilla Ma, Mary-Catherine P.
Overcash, Paras Sharma, Alison Snyder, Laurel Voloder, Alicia Wilson, and
Elizabeth Wood made key contributions to this report.

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[1] For the purposes of this
report, we date the pandemic’s onset to March 11, 2020, when the World Health
Organization declared the COVID-19 outbreak to be a global pandemic. The public
health emergency declared by the Secretary of Health and Human Services for
COVID-19 ended on May 11, 2023.

[2] See Pub. L. No. 118-159, §
3522, 138 Stat. 1773, 2311 (2024).

[3] Through our review of GAO,
Congressional Research Service, and Office of Inspector General reports and
discussions with federal agencies and industry stakeholders, we identified
these agencies as having a role in administrative or logistical efforts to
expedite the transportation of PPE during COVID-19.

[4] We identified these operating
administrations and Secretarial offices as relevant to our review based on
discussions with DOT and our review of DOT documentation. We refer to DOT
Secretarial offices as DOT offices in this report.

[5] For reporting purposes, we used
the following indefinite quantifiers to describe collective responses from our
interviewees: “some” is three to five, “several” is six to 10, and “many” is 11
or more.

[6] To represent transportation
industries, we selected 1) two motor carriers, 2) three terminal operators, 3)
one air cargo handler, 4) two rail carriers, 5) four sea vessel operators, and
6) one integrated express carrier. Integrated express carriers operate air and
ground transportation and provide “door-to-door” service (e.g., FedEx and UPS).
In addition, we selected three port authorities, two health care distributors,
and three industry associations—one representing rail carriers, one
representing health care distributors, and one representing air cargo carriers.

[7] U.S. Census Bureau trade
statistics—a widely used source analyzing U.S. international trade—do not
contain precise data on import values of products related to COVID-19. As a
result, we estimated the import value of all product types and categories within
those types, using the Harmonized Tariff Schedule of the U.S. statistical
reporting numbers and associated product groupings listed by the U.S.
International Trade Commission. See U.S. International Trade Commission, COVID-19 Related Goods: U.S. Imports and Tariffs
(Updated), Investigation No. 332-576, USITC Publication 5073
(Washington, D.C.: June 2020). We adjusted all import values for inflation,
using monthly import price indices from the Bureau of Labor Statistics to
identify the average inflation adjustment for 2024, which we used as the base
for the yearly adjustments.

[8] We identified ports and
airports in Oregon, Washington, and California as West Coast ports. These cover
five customs district codes: 25, 27, 28, 29, and 30. For context, there are 47
district codes.

[9] The Los Angeles district
contains 14 ports and airports: the port of Los Angeles, the port of Long
Beach, Ventura, Port Hueneme, Capitan, Morrow Bay, Los Angeles International
Airport, Ontario International Airport, Las Vegas airport, TNT Express, IBC Pacific,
Meadows Field Airport, DHL-HUB, and UPS-Ontario.

[10] For example, the U.S.
International Trade Commission reported that air freight experienced supply
chain challenges during COVID-19, in addition to ports. Air cargo experienced a
decrease in capacity to transport freight in the cargo holds of passenger aircraft
due to cancelled flights. This decreased capacity, coupled with increased
demand, resulted in a steep increase in air freight rates. International Trade
Commission, The Impact of the COVID-19 Pandemic on
Feight Transportation Services and U.S. Merchandise Imports.

[11] GAO, COVID-19: CBP Acted to Mitigate Challenges Affecting Its
Trade Operations , GAO‑22‑105034 (Washington D.C.: Sept. 19, 2022).

[12] To develop this estimate,
representatives from the Health Industry Distributors Association surveyed a
total of 14 health care distributors on the amount of time that medical
supplies were delayed, on average, during the fourth quarter of 2021.

[13] U.S. International Trade
Commission, The Impact of the COVID-19 Pandemic on
Feight Transportation Service s.

[14] GAO, Port Infrastructure: U.S. Ports Have Adopted Some
Automation Technologies and Report Varied Effects , GAO‑24‑106498 (Washington,
D.C.: Mar. 19, 2024).

[15] See Exec. Order No. 13911, Delegating Additional Authority Under the Defense
Production Act With Respect to Health and Medical Resources To Respond to the
Spread of COVID-19 , § 4, 85 Fed. Reg. 18403, 18404‑18405 (Mar. 27,
2020); 44 C.F.R. Part 333. Health and medical resources needed to
respond to the spread of COVID-19 within the U.S. included PPE. Exec. Order No.
13909, Prioritizing and Allocating Health and
Medical Resources to Respond to the Spread of COVID-19 , § 1, 85
Fed. Reg. 16227, 16227 (Mar. 18, 2020); Exec. Order No. 13911 § 1. In
April 2020, the President issued a memo directing FEMA, in consultation with
HHS, to allocate certain PPE for domestic use. See Memorandum on Allocating
Certain Scarce or Threatened Health and Medical Resources to Domestic Use (Apr.
3, 2020).

[16] GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic
Enters Its Second Year , GAO‑21‑387 (Washington,
D.C.: Mar. 31, 2021); COVID-19: Continued Attention
Needed to Enhance Federal Preparedness, Response, Service Delivery, and Program
Integrity , GAO‑21‑551 (Washington, D.C.: July 19, 2021); and Public
Health Preparedness: HHS Should Address Strategic National Stockpile
Requirements and Inventory Risks , GAO‑23‑106210 (Washington,
D.C.: Oct. 17, 2022); Also, GAO, COVID-19: Federal
Efforts Could Be Strengthened by Timely and Concerted Actions, GAO‑20‑701 (Washington
D.C.: Sept. 21, 2020); and COVID-19: Urgent Actions
Needed to Better Ensure an Effective Federal Response , GAO‑21‑191 (Washington
D.C.: Nov. 30, 2020).

[17] See Exec. Order No. 13909
§ 2.

[18] GAO, Air Cargo: DOT Should Communicate Data Limitations and
Identify Stakeholder Challenges , GAO‑25‑107334 (Washington,
D.C.: July 23, 2025).

[19] GAO, U.S. Port Infrastructure: DOT and DHS Offer Funding and
Other Assistance Ports Can Use to Improve Disaster Resilience , GAO‑25‑107159 (Washington,
D.C.: Mar. 20, 2025).

[20] GAO‑20‑701 and GAO‑21‑191 .

[21] The Supply Chain Advisory
Group focused on four key supply activities: helping preserve existing
supplies, accelerating the delivery of supplies, expanding the production of
supplies, and gathering data to help allocate scarce supplies. The Supply Chain
Advisory Group transitioned its responsibilities to HHS in late January 2021.

[22] Although Project Airbridge
reduced shipment times to transport PPE into the U.S., a Department of Homeland
Security Office of the Inspector General report found that FEMA did not
sufficiently assess whether medical supply distributors needed Project Airbridge
to stabilize their supply chains. In addition, FEMA did not ensure that
distributors delivered PPE to health care facilities, as agreed. Department of
Homeland Security, Office of Inspector General, FEMA Did Not Provide Sufficient Oversight of Project
Airbridge, OIG-23-14 (Washington, D.C.: February 2023).

[23] The Office of the Assistant
Secretary for Aviation and International Affairs may issue permits to foreign
air carriers authorizing them to transport cargo between a place in the U.S.
and a place outside the U.S. by aircraft and for compensation, if it makes
certain findings. Foreign air carriers that do not hold these economic licenses
are prohibited from providing such transportation. See 49 U.S.C. §§ 40102,
41301-41302; 49 C.F.R. § 1.25a(b)(6)(ii)(B) (delegating these authorities to
the Office of the Assistant Secretary for Aviation and International Affairs).

[24] GAO‑22‑105034 .

[25] DOD officials said that these
agreements resulted in over $360.3 million worth of PPE to support FEMA and
$3.2 billion worth of PPE to support HHS.

[26] DOD’s U.S. Transportation
Command supported HHS with six requests for assistance during COVID-19. Four
requests were for the U.S. Transportation Command to transport needles and
syringes from overseas to the U.S.; one was to airlift personnel between two
points in the U.S., and one was to move personnel and COVID-19 test kits from
overseas into the U.S. However, none of these efforts involved the
transportation of PPE.

[27] FAA is required to assign the
use of the navigable airspace by regulation or order necessary to ensure the
safety of aircraft and the efficient use of airspace and may modify or revoke
its assignments when required in the public interest. See 49 U.S.C. § 40103.

[28] According to data from DOT’s
Bureau of Transportation Statistics, U.S. airlines operated around 1.7 million
domestic flights from April through September 2020.

[29] The Office of the Assistant
Secretary for Aviation and International Affairs may issue permits to foreign
air carriers authorizing them to transport cargo between a place in the U.S.
and a place outside the U.S. by aircraft and for compensation, if it makes
certain findings. Foreign air carriers that do not hold these permits are
prohibited from providing such transportation. See 49 U.S.C. §§ 40102,
41301‑41302; 49 C.F.R. § 1.25a(b)(6)(ii)(B) (delegating these authorities
to the Office of the Assistant Secretary for Aviation and International
Affairs). Foreign air carriers can request expedited proceedings for this
economic licensing. See 14 C.F.R. § 302.11(e).

[30] See e.g., Federal Aviation Administration, Exemption No. 18584, Partial
Grant of Exemption, Regulatory Docket No. FAA-2020-0492 (July 10, 2020). FAA
may grant exemptions from certain FAA safety regulations if it finds that the
exemption is in the public interest. See 49 U.S.C. § 44701(f).

[31] See Federal Motor Carrier Safety Administration, Emergency
Declaration No. 2020-002 Under 49 CFR § 390.23 (Mar. 13, 2020).
FMCSA may grant temporary waivers of compliance with, and exemptions from, its
safety regulations under certain circumstances. See 49 U.S.C.
§§ 31133(a)(10), 31136(e); 49 C.F.R. § 1.87(f).

[32] See 49 C.F.R. § 395.3.

[33] I n
addition, FMCSA’s extension of its exemption clarified that drivers are not
exempt from its regulations prohibiting them from operating commercial motor
vehicles when they are, for example, fatigued, in such a way that impairs, or
is likely to impair, their ability or alertness so as to make it unsafe for
them to drive. The extension also stated that motor carriers may not require or
permit fatigued drivers to operate these vehicles, and drivers who inform motor
carriers that they need immediate rest must be given at least 10 consecutive
hours of rest before driving again. See Federal
Motor Carrier Safety Administration, Extension and
Expansion of Emergency Declaration No. 2020-002 Under 49 CFR § 390.25 (Apr.
8, 2020).

[34] See Federal Motor Carrier
Safety Administration, Extension and Amendment of Emergency Declaration No.
2020-002 Under 49 CFR § 390.25 (Aug. 31, 2021).

[35] See Federal Railroad Administration, Re: Request
for Relief in FRA Emergency Docket FRA-2020-0002 related to Coronavirus Disease
2019 (COVID-19) (Mar. 25, 2020). FRA may issue temporary emergency
waivers of compliance with any part of its railroad safety regulations, if it
makes certain determinations, which include that the waiver is not inconsistent
with railroad safety and is necessary to address an actual or impending
emergency situation or emergency event. See 49 U.S.C. § 20103(g); 49
C.F.R. § 1.89(a).

[36] See Pub. L. No. 81‑774, 64
Stat. 798 (1950) (codified as amended at 50 U.S.C. § 4501 et seq.);
Exec. Order No. 13603, National Defense Resources
Preparedness , § 201, 77 Fed. Reg. 16651, 16652 (Mar. 16,
2012). Title I of the DPA is codified as amended at 50 U.S.C. § 4511.

[37] See 50 U.S.C. § 4511(a);
Exec. Order No. 13603 § 201. However, DOT may only exercise its delegated
DPA, Title I authorities to support approved programs. See Exec. Order No. 13603 § 202; 49 C.F.R.
§§ 33.2, 33.20. An “approved program” is a program that the Secretary of
Defense, Secretary of Energy, or Secretary of Homeland Security has determined
to be necessary or appropriate to promote the national defense, in accordance
with Section 202 of Executive Order 13603. 49 C.F.R. § 33.20. The DPA
defines “national defense” to include emergency preparedness activities
conducted under Title VI of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (Stafford Act). 50
U.S.C. § 4552(14); Stafford Act, title VI (codified as amended at 42
U.S.C. § 5195 et seq.)

[38] We previously reported that
DOD used other DPA authorities to increase domestic manufacturing capacity of
medical supplies during COVID-19. GAO‑20-701 .

[39] In our prior review, we found
that DOT had not placed a priority rating on contracts or orders during fiscal
years 2018 through 2024. See GAO, Defense Production
Act: Information Sharing Needed to Improve Use of Authorities , GAO‑25‑107688 (Washington
D.C.: June 12, 2025).

[40] Both agencies used their
delegated DPA Title I authorities to issue one allocation order in April 2020
to control the distribution of certain scarce or threatened health and medical
resources, including PPE, within the commercial market during the pandemic.
They issued this allocation order to ensure that companies were not hoarding or
exporting these resources outside of the U.S., and the order was unrelated to
DOT’s delegated authority to issue a priority rating. Allocation orders control
the distribution of materials, services, or facilities in the U.S. commercial
market deemed necessary to support national defense. GAO‑25‑107688 .

[41] The Office of Intelligence,
Security, and Emergency Response may exercise DOT’s delegated DPA, Title I
authorities and oversees the implementation of the Transportation Priorities
and Allocation System, which are DOT regulations that provide guidance and
procedures for the use of such authorities. See 49
C.F.R. § 1.45(q); 49 C.F.R. pt. 33 (Transportation Priorities and
Allocation System).

[42] The Office of Intelligence,
Security, and Emergency Response receives Form OST F 1254, which other agencies
and entities can submit to the Office of Intelligence, Security, and Emergency
Response to request special priorities assistance from DOT. See 49 C.F.R. §
33.40.

[43] See DPA § 708 (codified
as amended at 50 U.S.C. § 4558); Exec. Order No. 13603 § 401.

[44] See 49 C.F.R. § 1.93(l).
However, MARAD may only exercise these delegated authorities as they relate to
the use of maritime industry-related facilities and services, such as port
facilities and sealift support, and maritime-related voluntary agreements, and
only if certain conditions are met. For example, MARAD must find that
conditions exist that may pose a direct threat to the national defense or its
preparedness programs and obtain the required findings and approvals from
certain other executive agencies, such as FEMA. See 50 U.S.C.
§ 4558(c); 44 C.F.R. § 332.2; 49 C.F.R. § 1.93(l).

[45] MARAD’s other voluntary
agreement, the Voluntary Tanker Agreement, was designed to provide DOD with the
commercial tanker capacity to transport petroleum and petroleum products
necessary to meet national defense contingency requirements.

[46] The Federal Maritime
Commission is an independent federal agency responsible for the economic
regulation of the commercial transportation of cargo by water between the U.S.
and foreign countries. See 46 U.S.C. § 46101(a); 46 C.F.R. § 501.2.
It does not have specific authorities that would allow it to expedite the
transportation of PPE at ports.

[47] Many stakeholders also cited
challenges they experienced transporting all types of goods, including PPE,
during the pandemic. These challenges were similar to those described above and
included port congestion, port infrastructure and equipment limitations, labor
shortages, and maintaining worker safety.

[48] We and other federal agencies
have reported on challenges related to supply chain visibility and tracking the
shipments of medical supplies during the COVID-19 pandemic, as well as on how
limited information about commodities coming through ports can impact port
congestion. Following a period of port congestion at West Coast ports in 2014
and 2015, we reported on the need for additional information on supply chains
and commodity flows to address freight bottlenecks. We recommended that DOT
identify and collect freight information and develop high-quality, reliable
supply chain information, which DOT addressed in its 2020 National Freight
Strategic Plan. According to DOT officials, by improving freight data on supply
chains, DOT can better identify problems, aid in prioritizing and planning
infrastructure investments, and support national freight policy goals. GAO, West Coast Ports: Better Supply Chain Information Could
Improve DOT’s Freight Efforts, GAO‑17‑23 (Washington,
D.C.: Oct. 31, 2016). A Congressional Research Service report on PPE production
during the COVID-19 pandemic suggested that Congress could consider authorizing
federal agencies to collect more data on supply chain information and the
status of U.S. production and distribution. Congressional Research Service, COVID-19 and Domestic PPE Production and Distribution:
Issues and Policy Options , R46628 (Washington, D.C.: December 2020). A Department of Homeland Security Office of
the Inspector General report found that FEMA, under pressure to expedite
critical medical supplies, did not follow established business practices for
tracking shipments, which limited its visibility into the resources shipped and
received. Department of Homeland Security Office of Inspector General, FEMA Did Not Effectively Manage the Distribution of
COVID-19 Medical Supplies and Equipment, OIG-23-34 (Washington, D.C.: July 2023).

[49] Representatives of rail
carriers said that rail carriers have limited ability to expedite goods, such
as PPE, because rail carriers are on fixed networks with fixed speeds. In
addition to the methods described below, one health care distributor adapted its
distribution process to ensure that PPE reached its destination sooner. This
stakeholder said the company saved weeks by working with third-party logistics
companies to deliver PPE to the destinations immediately surrounding ports,
instead of shipping these products to their regional hubs before sending them
out for distribution.

[50] Stakeholders also suggested
other ways the federal government could support industry in expediting goods
generally, such as increasing information sharing, providing port
infrastructure investments, supporting the availability of truck drivers, and
improving coordination and leadership across federal agencies.

[51] See Pub. L. No 117-58, §
21101, 135 Stat. 429, 652-657 (2021) (codified at 49 U.S.C. § 118).

[52] In 2025, we recommended that
DOT fully assess the reliability of the air cargo data it collects and
communicate the limitations of these data. We also recommended that DOT
evaluate existing sources of information and routinely communicate with air
cargo stakeholders to identify challenges to the efficient movement of air
cargo. DOT identified steps it plans to take to address these recommendations. GAO‑25‑107334 .

[53] In June 2026, DOT announced
DOT’s American Supply Chain Sovereignty Initiative in which DOT plans to
develop a high-visibility dashboard linking major logistics hubs, including the
Port of Los Angeles, with ocean carriers, trucking companies, rail operators,
and retailers. This initiative aims to increase operational efficiency and
enhance security across supply chains. According to DOT, if certain proposed
legislation is enacted, DOT and the Department of Homeland Security will be
able accelerate the movement of cargo being imported by participants in a
certain Customs and Border Protection’s program through this initiative.

[54] U.S. Department of
Transportation, 2026 National Freight Strategic Plan (Washington, D.C.: May 2026).

[55] For the purposes of this
report, we date the pandemic’s onset to March 11, 2020, when the World Health
Organization declared the COVID-19 outbreak to be a global pandemic. The public
health emergency declared by the Secretary of Health and Human Services for
COVID-19 ended on May 11, 2023. Because we report yearly values of imports, we
decided to include all of 2020, as most months of that year were included in
the pandemic, and to exclude 2023, as most months of that year were not
included in the pandemic.

[56] The Harmonized Tariff Schedule
comprises a hierarchical structure for describing all goods in trade for duty,
quota, and statistical purposes. This structure is based upon the international
Harmonized Commodity Description and Coding System, administered by the World
Customs Organization in Brussels; the 4- and 6-digit product categories are
subdivided into 8-digit unique U.S. rate lines and 10-digit nonlegal
statistical reporting categories. According to the U.S. International Trade
Commission, classification of goods in this system must be done in accordance
with the General and Additional U.S. Rules of Interpretation, starting at the
4-digit heading level to find the most specific provision and then moving to
the subordinate categories.

[57] See U.S. International Trade
Commission, COVID-19 Related Goods: U.S. Imports and
Tariffs, Investigation No. 332-576 , USITC Publication 5047 (Washington,
D.C.: April 2020); and COVID-19 Related Goods: U.S.
Imports and Tariffs, (Updated) Investigation No. 332-576 , USITC
Publication 5073 (Washington, D.C.: June 2020).

[58] The Committee for the
Statistical Annotation of Tariff Schedules, more commonly known as the “484(f)
Committee,” is an interagency committee made up of representatives from the
U.S. International Trade Commission, Customs and Border Protection, and the
U.S. Census Bureau. The 484(f) Committee adds, removes, or modifies the
nonlegal 10-digit statistical reporting numbers in the Harmonized Tariff
Schedule and Schedule B. The 484(f) forms have been published twice annually
since 2019.

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