A. GENERAL POLICY QUESTIONS
20. PROPOSAL FOR A DIRECTIVE ON SAFETY REQUIREMENTS AND
ATTESTATION OF PROFESSIONAL COMPETENCE FOR CABIN CREWS IN CIVIL
AVIATION (10309/97)
Letter from Lord Tordoff, Chairman of the Committee,
to the Rt Hon Dr Gavin Strang MP, Minister for Transport, Department
for the Environment, Transport and the Regions
The above proposal, which was sifted to Sub-Committee B for
scrutiny, was considered at the Sub-Committee's meeting on Thursday
6 November. In addition to your explanatory memorandum of 15 September,
the Sub-Committee invited written evidence from British Airways,
Britannia Airways and British Midland (as airline representatives),
Cabin Crew 89 and the Transport and General Workers' Union (as
trades union representatives), and the British Airline Pilots'
Association (BALPA). Copies of these submissions, considered by
the Sub-Committee, are attached to this letter.
The views of the witnesses were broadly divided between the
airlines and the cabin crew representatives. British Airways and
Britannia Airways supported the view of the Government and the
Civil Aviation Authority (CAA) set out in paragraphs 14-16 of
your memorandum. However, the TGWU and Cabin Crew 89 supported
the aims of the Directive, especially insofar as it aims to raise
safety standards across the industry.
British Midland stated that they had addressed [their] opinions
to the Civil Aviation Authority" and BALPA said that they
could not give a considered response within the timescale. The
views of the other witnesses can be briefly summarised as follows:
- The airlines raised a concern that the proposed Directive
overlapped" the existing regulations contained in JAR-OPS
(the Joint Aviation Authorities' technical requirements which
include training standards for cabin crews). They believed that
the ensuing confusion over regulations would lead to increased
inefficiencies which would have a detrimental effect on safety
levels.
- The TGWU and Cabin Crew 89 believed that the present
safety system has some weaknesses and that the proposed Directive
would improve safety by ensuring consistent standards across the
European Community. They also welcomed the Directive as addressing
their concerns over the growing conflict between commercial needs
and safety obligations in an industry which has undergone liberalisation
and deregulation in recent years. The TGWU thought that JAR-OPS
needs to be complemented by systems that ensure crews' professional
competence, integrity and independence". Britannia Airways
expressed the view that if the Commission believes JAR-OPS is
not sufficient to ensure safety requirements then this is the
issue which should be addressed, and not dealt with by a European
Community Directive. Community action would be an anomaly and
set a precedent.
- British Airways and Britannia Airways felt that imposing
centralised standards by means of a Directive would not recognise
the differences which exist between each individual airline's
training in safety drills, equipment and procedure. These differences
arise both from the different models and layouts of aeroplanes
used by companies, and from cabin crews' training to act as a
representative of the values and standards of their individual
employer".
- Both airlines agreed that issuing certificates of
competence would not facilitate the mobility of cabin crew any
more than at present. British Airways believed that there is no
automatic ease of transfer between carriers which would in all
cases require retraining in their procedures". This view
was supported by Britannia Airways, who currently award certificates
of competence to successful trainees, but who recognise that they
are not valid for, nor accepted by, other airlines".
- Cabin Crew 89 were concerned that present regulations
made it possible for an airline to operate with a complete cabin
crew who, while trained to the legal standard, have no other training
and have very little flying experience". They proposed that
any change to safety standards should include a provision that
each airline should be required to have a percentage of cabin
crew trained to a higher standard set independently of the airline.
The Committee endorses most of the concerns expressed by
the airline witnesses and by you in your memorandum. In particular,
we question the efficacy of the proposed Directive as a means
of harmonising safety standards given the existence of JAR-OPS,
and the Commission's claims that the proposed Directive would
facilitate movement of labour between airlines.
We consider that the safety issue would be dealt with more
effectively by JAR-OPS and not by a Directive which would overlap
with existing regulations. On this point, we concur with the views
expressed by some witnesses that the confusion arising from two
separate requirements would cause inefficiencies and therefore
undermine the safety enhancement the proposed Directive aims to
achieve.
We consider, however, that there may be some merit in considering
enhanced safety requirements given the changing nature of the
airline industry in recent years. We are sure that the Government
will satisfy itself as to weaknesses, if any, in the present system
for ensuring safety.
We take the view that the proposed Directive would set an
unsatisfactory precedent for Commission activity in this area.
We support the Government's view that it is preferable to treat
safety requirements as a whole, rather than separating out this
particular aspect. For these reasons we strongly support your
view and that of the CAA that the proposed Directive should be
opposed.
This letter lifts the scrutiny reserve and I look forward
to receiving your supplementary memorandum in due course.
12 November 1997
Letter from the Rt Hon Dr Gavin Strang MP, Minister
for Transport, Department of the Environment, Transport and the
Regions, to Lord Tordoff, Chairman of the Committee
Thank you for your letter of 12 November with regard to the
Proposal for a Directive on safety requirements and attestation
of professional competence for cabin crews in civil aviation.
I have noted the issues raised by the Sub-Committee with
interest and will bear these in mind in future consideration of
the Directive.
3 December 1997
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