Memorandum submitted by the Independent
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
(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
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