Memorandum by the British Airline Pilots
Association (BALPA)'s Occupational Health & Safety Group
INTRODUCTION
The BALPA Occupational Health & Safety Group
is a specialist focus group within the Association, whose remit
is to deliver Health & Safety guidance and improvements for
members, to train and support its Health & Safety Representatives,
and to represent the occupational health & safety interests
of its pilot and flight engineer members. This currently represents
some 10,000 flight crew members in the UK.
The BALPA Occupational Health & Safety Group
consists of current operational pilots who have received training
in accordance with accredited standards, including some holding
post-graduate level qualifications in Occupational Health &
Safety Management and membership of the Institute of Occupational
Safety & Health (IOSH) Aviation Specialist Group Committee.
The Group meets regularly with Airlines and Regulators—both
the Civil Aviation Authority and Health & Safety Executive—in
a variety of forums.
AIR TRAVEL
AND HEALTH
The identification, management and communication
of health risks in air travel are of paramount importance and
have are in significant need of further funding and a renewed
stakeholder commitment, if the industry is to demonstrate that
it regularly achieves what could be deemed best practice. It is
very much our belief that such funding and investment must also
provide for varied research projects into the various aspects
of air travel on a cross-industry basis which includes all stakeholders
and that a new culture of openness and sharing of health information
is needed to provide that which an increasingly interested public
expects.
We agree with the Committee's comments in Para
1.8 that health has been "woefully neglected", and in
particular we wish to record our concerns regarding the trends
in increasing risk and pressure suffered by flight crews due to
lengthening duty periods as a result of increasing delays, allied
to ever reducing rest periods between flight sequences in airline
efficiency drives, whilst still attempting to maintain the highest
of standards in ever more densely crowded skies. There is a need
for a review of the fundamental applications of crew fatigue and
stress management standards being applied to flight crew—for
too long the perception that pilots are able to cope with all
forms of adversity has been an accepted industry norm—and
this culture needs to change. It is a culture which promotes acceptance
of excesses of stress, and re-enforces a lack of fatigue reporting
through concerns over job-security.
Quite rightly over the last half-century, the
aviation industry has focused its efforts on the primary provision
of flight-safety, but this now needs to be augmented with a new
determination to govern and protect the health and safety of the
individual crew members who have provided this given.
BALPA Occupational Health & Safety Group
fully supports the recommendation of Para 1.9 and we endorse the
view that the Government actively promote both the health of crews
and passengers, as a specific goal in the immediate future.
We also recognise the inertia referred to in
Para 1.10 of the safety focused regulatory structures and recommends
that the widespread knowledge available through bodies such as
IOSH be fully utilised and integrated into new health & safety
related management structures which now apply to aviation. The
funding levels of the HSE and CAA SRG by Government are something
which we believe needs urgent attention, with a significant injection
of investment into each—to be ring-fenced specifically for
health related issues.
BALPA'S RESPONSE
With regard to Para 1.11—the European
Working Time Directive in 2006, was the instrument responsible
for the extension of UK Health & Safety Legislation (HASAWA
1974 etc.) to mobile transport workers, and until the implementation
of this Directive under the Civil Aviation Working Time Regulations,
flight crew had no recourse to Health & Safety legislation.
In response to this, BALPA established its Occupational Health
& Safety Group in November 2005, to provide both a service
to its members and a focus point for engagement with other parties
with an interest in the subject, including the relevant governmental
and regulatory bodies, employers and fellow Trade Unions. The
Group meets on a monthly basis establishing policy, setting goals,
monitoring trends and to supply training.
BALPA now has qualified H&S Representatives
across a broad spread of UK airlines. The training of new volunteer
reps and the ongoing professional development of existing Reps
and members continues apace. However, the release of pilot H&S
Representative volunteers to complete their training and to carry
out their activities by some airlines—is a problematic issue.
Some airlines still refuse release for these activities.
Our belief is that this is partly due to resistance
on the part of some airlines to accept that H&S legislation
be applied equally to pilots as it is to ground based workers.
Indeed, we find that we are often frustrated by the disapplication
of certain specific legislation to flight decks—for example
the Display Screen Regulations. The whole is far from satisfactory
at present, leading to both delays and difficulties in the application
of health and safety standards enjoyed by ground based staff.
DEEP VEIN
THROMBOSIS (DVT)
We support and are pleased to see that the Committee
accept that DVT is an issue which is not solely confined to air
travel. We believe that the additional risks in air travel only
augment the overall risk of a DVT development in a minor manner
and that the Department of Health, CAA and AOA should provide
clearer, more uniform advice covering all forms of travel.
With regard to the taking of health providing
exercise on aircraft, we wish to record that the necessary locking
of the flight deck door system post the 9/11 events, has led to
a culture of pilots being stuck in a confined area with little
opportunity to stretch and move the legs for significant periods
of time. This may have longer term health implications.
AIR QUALITY
BALPA's Occupational Health & Safety Group
see no sensible reason for not adopting the JAA requirement for
a fresh air only supply to the flight deck, and to this extent
are at odds with the recommendation of the Committee. The pilots
are the two singularly most expensive pieces of flight safety
equipment on board and we believe that this status deserves recognition
and that includes the provision of a fresh air supply. There may
be other security related issues which further re-enforce this
opinion. We do not concern ourselves with the view in some circles
that this would imply that re—circulated cabin air is intrinsically
bad, but add that scientific evidence suggests that on the whole
cabin air is normally of acceptable quality—with occasional
acute exceptions.
The Committee is no doubt aware that BALPA along
with DfT and several other key industry stakeholders are undertaking
joint research into cabin air quality to establish further scientific
facts.
SMOKING
We believe that the EU smoking ban in confined
spaces from July 2007 be applied to all aircraft cabins operating
within the boundaries of UK territorial airspace. We fully support
no smoking legislation.
AIR FILTRATION
BALPA Occupational Health & Safety Group
fully endorses the Committees recommendation regarding air filtration,
and we urge all airlines to adopt a positive and pro-active stance
towards HEPA filtration and accept that any improvements in filtration
are cost-effective in terms of crew and passenger health.
NOISE
BALPA continues to press for further flight
deck noise research and for airlines to be responsible for providing
adequate hearing protection for flight crew—both whilst
in the aircraft and whilst exposed to noise hazards when carrying
out external duties on the ground. Noise levels at the ear should
be controllable to levels as defined under the Control of Noise
at Work Regulations 2005. Noise induced hearing loss is both permanent
and prevalent in the industry yet protection is easily affordable.
Sadly, we note that few UK airlines provide legally adequate levels
of information, instruction and training along with personal protection
equipment for pilots to be able to protect their hearing—which
can lead to a loss of flying licence and hence career due to health
failings.
Whilst the causes of in-flight noise may be
costly to rectify, the cost of suitable protection is reasonable
and we continue to press all UK airlines to put into place adequate
noise control programs for flight crew including the provision
of suitable training.
STRESS AND
FATIGUE
With regard to stress our principle concern
is to record the increasing levels of work-related stress felt
by our members, with empirical evidence suggesting that rates
of increase in stress are rising year on year. In our unique role
the committee should appreciate that our stress is augmented by
constant jet-lag and fatigue and that the industry poorly supports
the health issues surrounding this situation.
The Occupational Health Group at BALPA would
like to see a review of flight crew scheduling and rest limitations
to introduce systems which support more suitable rest breaks between
flights and thus help to reduce chronic fatigue prevalence towards
the latter stages of many long-haul flights. Additionally, we
recognise that increasingly hectic short-haul work patterns for
crews add to fatigue levels in a very stressful environment, and
ask that this Committee recognise the need for research and serious
review of planned rest patterns. Fatigue is cumulative, but our
rostering systems assume that the tiredness counter in each pilot
is reset to zero on the first day of each month and take no account
of the previous months experiences. This is a potential flight
safety hazard which needs a fresh approach.
More effort has to be placed through regulators
into re-aligning crew rest periods with a proper regard to fatigue
of crews during subsequent flights. We support more research in
this area.
COSMIC RADIATION
EXPOSURE
This report, has quite surprisingly, made no
reference to the effects of cosmic radiation exposure of flight
crews. Whilst much research has been conducted we feel that more
is required. Indeed to this extent we have developed a methodology
for an epidemiological study into flight crew schedules and exposure
on various types of long-haul aircraft. Our concern is that the
latest generation of ultra-long haul aircraft are able to climb
shortly after take-off to high cruise altitudes and remain at
high altitudes for considerably longer than older aircraft types
on whose performance much data is based.
This allied to a trend towards increasing annual
flying hours amongst long-haul crews is of concern to us. We wish
to see the DfT to sponsor a major new research effort into this
field.
June 2007
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