Memorandum submitted by British Airways
Plc (SAGE 37)
INTRODUCTION
British Airways welcomes the opportunity to
submit evidence to the House of Commons Science & Technology
Select Committee's inquiry into `Scientific advice and evidence
in emergencies'. It comes at a time when the aviation industry
has experienced two challenging and different emergency situations
where scientific advice was key to its daily global operation.
British Airways is one of the world's largest
international airlines, carrying almost 32 million passengers
worldwide on almost 750 daily flights in the financial year to
31 March 2010. The airline employs 40,000 people, the vast majority
of these at its sites throughout the UK.
The airline's two main operating bases are London's
Heathrow and Gatwick airports, with a smaller base at London City
airport serving New York and European business destinations. From
these, British Airways flies 238 aircraft to 155 destinations
in 70 countries. In addition to passengers, the airline also transported
760,000 tonnes of cargo around the globe.
The evidence provided below refers to the two
emergencies of which we have direct experience—the swine
flu pandemic in 2009 and the volcanic ash eruptions in 2010.
CASE STUDY
1. SWINE FLU
PANDEMIC 2009
Question 1. What are the potential hazards
and how were they identified? How prepared was the Government
for the emergency?
1.1.1 The potential hazards and risks of
a swine flu pandemic have been well-documented and discussed by
the medical and emergency planning communities. British Airways
considers that the Government was well prepared for the emergency.
The planning at all levels and within the National Health Service
was good.
Question 2. How did the Government use scientific
advice and evidence to identify, prepare for and react to an emergency?
1.2.1 The Government and its agencies used
the experience gained in the SARS outbreak of 2003 as the basis
for its response in 2009. The agencies carried out an extensive
review following the 2003 outbreak and lessons were learned. New
procedures were introduced and processes and advice were improved.
1.2.2 During the SARS emergency, communications
from Government were inconsistent and erratic, although the advice
provided by the international aviation governmental body, ICAO,
was good. Post SARS, ICAO established a global working group to
co-ordinate action.
1.2.3 There was co-ordinated action by the
NHS, the Health Protection Agency (HPA), International Air Transport
Association (IATA) and UK airlines. The main benefit was the extensive
sharing of information with involved parties.
Question 3. What are the obstacles to obtaining
reliable and timely scientific advice and evidence to inform policy
decisions in emergencies? Has the Government sufficient powers
and resources to overcome the obstacles? Was there sufficient
and timely scientific evidence to inform policy decisions?
1.3.1 For the swine flu pandemic, the main
obstacle was that it was a new situation. There was limited experience
and knowledge of how such an emergency might develop, but this
was common among many Governments. In the UK, this was countered
by the development of contingency plans at all levels where possible,
building on the experience of 2003. However, there will always
be `known unknowns'.
1.3.2 In 2003, the speed and scope of the
spread of SARS, and aviation's role within this most recent modern
global epidemic, could only be estimated. In 2009, Governments
worldwide were far better prepared—and connected—to
deal with the swine flu outbreak.
1.3.3 With regard to powers available to
the Government, British Airways believes the UK appeared to have
sufficient powers and resources.
Question 4. How effective is the strategic
co-ordination between Government departments, public bodies, private
bodies, sources of scientific advice and the research base in
preparing for and reacting to emergencies?
1.4.1 The co-ordination by all organisations
involved in the swine flu pandemic emergency was very good in
our experience.
1.4.2 The Cabinet Office had well-developed
contingency plans and airlines were included in both the domestic
and global contexts. The Foreign & Commonwealth Office was
in regular contact with British Airways regarding repatriation
of UK citizens from overseas at the same time as recognising the
risk to the airline's staff and the difficulties in dealing with
infected citizens overseas. The sharing of information was co-ordinated.
1.4.3 Advice from the HPA was excellent,
and the creation of a single point of contact for British Airways
was very useful. This allowed a strong working relationship with
an HPA adviser who knew the specific concerns of our business
and was fully abreast of the developments within the industry.
We could contact the liaison manager at any time without having
to explain our issues from scratch, and be confident that the
advice was consistent.
1.4.4. Post SARS, generic advice and guidelines
were tailored to suit the industry, for example for cabin and
flight crew, engineers, cleaning and airport check-in staff. This
enabled us to provide a consistent message to our customers and
staff based on the knowledge and expertise of the HPA specialists.
1.4.5 There was inter-agency co-operation
in the UK and further co-ordination on a worldwide level. Co-operation
was successful, led by a small group of specialists. The aviation
and international perspective was particularly well understood
and the UK authorities are to be praised for its efforts and achievements.
A notable example was the scientific advice for passengers presenting
with symptoms are check-in.
1.4.6 CAA was very quick to issues advice
on passenger and crew fitness to fly and the medications required.
It was not expected to provide specific aviation medical advice
but it did fill in the gaps left by the general medical advice
for the airline industry that were consequently identified. There
is no criticism of its actions.
Question 5. How important is international
co-ordination and how could it be strengthened?
1.5.1 For the swine flu pandemic, international
co-ordination was and remains vital. Aviation is a global transport
industry and it is essential that issues affecting it are dealt
with in a co-ordinated and coherent manner.
1.5.2 Development of a universal landing
card would have been of benefit. Many States required passengers
to complete landing cards detailing contact information and medical
symptoms, and many States required specific announcements to be
made on arrival. Compliance with such a variety of similar, but
different, requirements is difficult.
CASE STUDY
2. ICELANDIC VOLCANIC
ASH ERUPTION
2010
Question 1. What are the potential hazards
and how were they identified? How prepared was the Government
for the emergency?
2.1.1 The risks of flying in an ash plume
are well known. ICAO has published procedures in this situation
and established Nine Volcanic Ash Advisory Centres (VAACs) worldwide.
2.1.2 The UK is responsible for the London
VAAC that covers parts of Northern Europe including Iceland .
The London VAAC is part of the Meteorological Office and reports
to the Ministry of Defence, and is thus under Government control.
The output of the London VAAC is then published as a —Notice
to Airmen— (NOTAM) by NATS, a public/private company.
2.1.3 The LVAAC model is dependent upon
accurate estimation of volcanic output and it is evident that
the actual output of Jake was very different from the estimates
being input into the LVAAC computer model.
2.1.4 NATS had a contingency plan but it
appears that it had not been run through to the end in a mock
practice session ie if a volcano erupts, what do we, the UK, do—would
there be airspace closures? There had been no contact with UK
aviation operators prior to the live situation in April.
Question 2. How did the Government use scientific
advice and evidence to identify, prepare for and react to an emergency?
2.2.1 The Government used the VAAC model
to plan and to react to the emergency situation. It appears the
Met Office was more intent on proving the accuracy of the model
and justifying its decisions that accepting that the data input
was inaccurate. The Met Office was either not willing or unable
to review the data, resulting in the unnecessary closure of airspace
over much of Western and Northern Europe for six days.
2.2.2 ICAO guidance to aircraft operators
is clear and unambivalent—avoid visible ash at all times.
The areas of predicted contamination produced by the VAAC model
were vastly over-conservative: the Met Office has since admitted
this. Blue skies prevailed over much of the predicted area of
contamination for the majority of the time that the volcano was
erupting but this evidence was not taken into account by government
agencies. They contradicted ICAO guidance and imposed unreasonable
restrictions upon operators against established protocols.
2.2.3 The arrangements for utilisation of
aircraft fitted with scientific sensing equipment are inadequate.
There is no system in place to utilise such aircraft in a co-ordinated
manner or indeed, to use the data provided by such aircraft to
improve the fidelity of the theoretical model.
Question 3. What are the obstacles to obtaining
reliable and timely scientific advice and evidence to inform policy
decisions in emergencies? Has the Government sufficient powers
and resources to overcome the obstacles? Was there sufficient
and timely scientific evidence to inform policy decisions?
2.3.1 There was insufficient and untimely
scientific evidence. The collection and assessment of data was
poor, there was a lack of understanding and interpretation of
the modelling and data output, and a reluctance by the regulatory
community to admit that an incorrect assessment had been made.
2.3.2 There was an inability to measure
ash output from Eyjafjallajökull which is now a cost issue.
Five months after the eruption, on behalf of the EU, ICAO is working
on installing the correct equipment to measure the ash concentrations.
This will cost approximately only £2 million, and although
now approved, the granting of funding was an obstacle for EU governments.
2.3.3 To work effectively, the London VAAC
relies on accurate input data. On this occasion, the VAAC insisted
on standing by its evidence, rather than considering other available
scientific evidence, which would have opened EU airspace sooner.
Worldwide ICAO standards require satellite imagery at all other
global VAAC, but this was not used in London. The London VAAC
position creates a problem, in that there is inconsistency in
the VAAC modelling for the industry.
2.3.4 A further obstacle was the decision
by NATS and the CAA to remove responsibility for ash avoidance
from the operators and to reduce the flow rate to zero (effectively
to close the airspace). This was contrary to worldwide practice,
which is a proven and safe way for aviation operations through
volcanic eruptions. There has been no loss of aircraft or life
incurred through the worldwide system where responsibility for
operational decision rests with airlines, based on the available
VAAC data.
2.3.5 In contrast, the CAA International
division, which includes the Montserrat volcano in its remit,
follows a different process to the London VAAC. It adheres to
ICAO guidance and publishes information on the ash concentrations
and other hazards. The decision on how and when to operate is
then left to the airline operators. In 2008 and earlier in 2010,
British Airways reviewed the evidence presented in the NOTAM and
took the decision to cancel flights that would operate close to
the Montserrat ash concentrations.
2.3.6 The airline did so because it believed
the risk was unacceptable; it was not instructed to do so by the
UK CAA International. This is the basis upon which all operators
(including UK operators) act anywhere else in the world.
2.3.7 Government has the power and resources
to override the London VAAC evidence but did not to do so. British
Airways believes it did not have sufficient or timely scientific
evidence. The evidence presented by test flights and by commercial
airlines, many of which are well experienced in volcanic ash situations
and procedures elsewhere in the world, was not given due or timely
consideration.
2.3.8 Instead, a—no-risk—model
was applied, ie no risk was acceptable. In reality, all airlines
operate on a known-risk basis, for example aircraft are allowed
to depart with Allowable Aircraft Defects on the basis that the
remaining redundancy is sufficient to ensure the safety of flight.
We are not aware of any flight safety issues with clear skies
anywhere in the world.
Question 4. How effective is the strategic
co-ordination between Government departments, public bodies, private
bodies, sources of scientific advice and the research base in
preparing for and reacting to emergencies?
2.4.1 The strategic co-ordination between
Government departments, public bodies, private bodies and sources
of scientific advice was not effective. The aviation industry
had to press the Government and its agencies for review and action—the
Government did not approach the industry experts, the engine manufacturers
or the airlines who have extensive experience of flight operations
in such conditions.
2.4.2 Both the engine manufacturers and
airlines are united in the requirement to avoid flying in visible
ash. However, the Government is calling for the engine manufacturers
to determine the safe levels of ash for operations despite there
being no method of measuring it at the levels expected for the
proposed limit. Avoiding visible ash is the safest way forward,
as it is throughout the rest of the world, but this is not recognised
in the UK.
2.4.3 The process for night-time flying
is similar but necessarily stricter. Aircraft operators review
the visible ash in daylight and build safe margins into night
operations. The Montserrat situation mentioned above is one such
example.
Question 5. How important is international
co-ordination and how could it be strengthened?
2.5.1 International co-ordination for the
global aviation industry is vital. There must be a worldwide system
and standards for worldwide operators. British Airways urges the
Committee to press Government to ensure it works towards implementing
the internationally-agreed standard for air operations in volcanic
ash situations.
2.5.2 The solution should be based on management
of overall operational risk and not solely an airworthiness solution
based on the redefinition of tolerance levels.
SUMMARY
British Airways has worked closely with the
Government and its agencies during the two recent emergencies
reviewed by the Committee. We have had a markedly different experience
on each occasion. We would hope and expect that a major review
of the handling of the volcanic ash emergency will be held as
a matter of urgency to ensure that lessons are learned and the
difficulties encountered in April 2010 will not be repeated.
British Airways Government Affairs
September 2010
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