Select Committee on Transport Written Evidence


Memorandum submitted by the Independent Pilots Association

  The Independent Pilots Association is a Professional Association that was formed by Flight Crew, promotes the welfare and interests of Flight Crew, is managed by Flight Crew and numbers in excess of 1,500 members.

  We would like to pass comment on just one field of the work of the Civil Aviation Authority (CAA) whose only reason for existence is to promote, safeguard, regulate and enforce the required safety standards that permit the safe conduct of flight within the United Kingdom.

  The field we wish to pass comment on is Aviation Health and in particular the aircraft cabin environment. Responsibility for this rests with the CAA and also the Secretary of State who is charged under section 7 (1A) of the Civil Aviation Bill with the general duty of organising, carrying out and encouraging measures for safeguarding the health of persons on board aircraft.

  A situation can exist on some widely used types of aircraft whereby contaminated air enters the aircraft cabin and this is of concern to our members and us because of the potential long-term health effects that may be experienced by some individuals. The phenomena of contaminated cabin air can occur when pyrolised engine oil seeps past engine seals and enters the air supply from the engine to the air conditioning system in aircraft.

  The contaminants can be made up of harmful substances including Tricresyl Phosphate (TCP), a known neurotoxic substance that breaks down into various toxic ortho-isomers (TOCP, MOCP, DOCP) that affect the brain and nervous system, similar to the organophosphates in sheep-dip that are linked to neurological damage in farmers.

  Indeed, a warning from the manufacturer of one of the most frequently used jet engine oils appears on the can of their product and states:

    Contains Tricresyl Phosphate. Swallowing this product can cause nervous system disorders including paralysis. Prolonged or repeated breathing of oil mist, or prolonged or repeated skin contact can cause nervous system effects".

  Having stated that the phenomena can exist, what does this have to do with our comment on the CAA?

  Our comment, simply put, is that the CAA appears to adopt a head in the sand" attitude to the existence of the phenomena and to be barely paying lip service to considering the long-term health effects of both aircraft crew and the travelling public, should exposure to a contaminated air event take place.

  We believe this to be the case because:

  1.  The CAA issued a document on air quality in 2004 indicating that aircraft cabin air quality was within exposure limits, however, they acknowledged they had not investigated the long-term health issues. The conclusion they reached was based upon:

    (i)  air sampling research that was never undertaken during a contaminated air event; and

    (ii)  data presented in a commercially restricted document in which limited toxicological testing was undertaken and the research methodology was not subject to independent review;

and opposes the view of many eminent medical professionals around the world that have researched the phenomena.

  2.  In that same 2004 document, the CAA stated in para 3.5.1 (reporting on tests conducted on aircraft engine oil) ... significantly, no tri-ortho-cresyl-phosphate was detected in the new, used or pyrolised oil analysed...". How can it not have been detected when the major manufacturer of aircraft engine oil admits the presence of the parent compound TCP and places a warning to that effect on the can? This comment is grossly misleading and misinforms the reader.

  Also, the comment appears to show that only tri-ortho-cresyl-phosphate (TOCP) was tested for, but this is neither the most toxic nor the most concentrated ortho-isomer of TCP in engine oil. TOCP is acknowledged to be present in the industry's most widely used jet engine oil (Exxon Mobil Jet Oil II) via it's parent compound TCP at approximately 0.006ppm, whereas, the more toxic mono-ortho-cresyl-phosphate (MOCP) is present in the same TCP at approximately 2,000ppm (ie 333,333 times more). MOCP is 10 times more toxic than TOCP so referring to TOCP only is understating the toxicity by a factor of 3,333,330 (ie 333,333 x 10).

  3.  Despite concerns expressed, the CAA would appear to have:

    (i)  failed to acknowledge sufficiently that the phenomena of contaminated cabin air exists;

    (ii)  failed to collate sufficient data via aircraft cabin air quality monitoring;

    (iii)  failed to encourage reporting of contaminated air events by flight crew;

    (iv)  failed to investigate the presence of the organophosphate TCP in aircraft;

    (v)  failed to carry out health monitoring or investigate health effects of flight crew, or endorse research studies into this issue;

    (vi)  failed to provide a medical protocol to deal with affected crew and passengers;

    (vii)  failed to ensure that passengers are informed if they have been exposed to a contaminated air event;

    (viii)  failed to set guidelines or requirements for the installation in aircraft of existing technology (airfilters) that could reduce the potential for contamination; and

    (ix)  failed to appreciate the limitations of current toxicological data.

  In making this submission to the Committee we seek to draw attention to what we believe are serious failings on the part of the CAA in the critical area of flight safety. It is our hope that the CAA can:

    (i)  be encouraged to participate in the growing world-wide debate on Cabin Air Contamination; and

    (ii)  further be encouraged to take much more positive steps towards research into the phenomena that has already been and continues to be conducted around the world by various eminent medical professionals, as well as Aviation Regulatory Authorities in other countries,

whilst at the same time taking seriously its duty of care towards both flight crew and the travelling public and not burying its head in the sand over this issue.

10 November 2005

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