Memorandum by the Global Cabin Air Quality
Executive (GCAQE)
I have been investigating the contaminated air
issue since 2001 when a fellow airline Captain called me and advised
me how he had been exposed to toxic fumes in a British Airways
Boeing 757 and asked me to investigate these issues.
I am currently a non salaried co-chairman of
the Global Cabin Air Quality Executive (GCAQE) which is "A
global coalition of health and safety advocates committed to raising
awareness and finding solutions to poor air quality in aircraft."
The GCAQE is the leading organisation globally representing air
crew with regard to cabin air quality, specifically contaminated
air issues and representing over 400,000 aviation workers globally
in three continents. GCAQE members have been actively involved
in working with crews, global experts, scientists, doctors and
the aviation industry for many years on this subject, including
being members of several international committees such as the
FAA OHCRA project, ITF, SAE and ASHRAE committees.
I have also published papers on the contaminated
air issue and was responsible for providing all the evidence that
was originally sent to the Committee on Toxicity (COT) for their
investigations into the contaminated air issue. Sadly, many say
the COT investigation is not only flawed but industry biased and
I would agree.
May I start my submission by highlighting that
the contaminated air issue which is the basis of my submission
is a highly political and industrial issue with many vested interests
at stake. These vested interests frequently work to protect the
airline industry from the massive financial cost which would be
incurred if the issue was accepted for the serious health and
flight safety issue it currently is, not just in the UK but worldwide.
The contaminated air problem has many dimensions
which I will summarise as follows:
1. Crews under-report contaminated air events
to the extent that less than 4% of events are actually reported
in the first place. This is due to commercial pressures, lack
of education and a lack of will within the airline industry to
ensure all events are reported;
2. Crews that do report contaminated air
events are rarely contacted by the AAIB and never contacted by
the CAA medical section;
3. Last year the US FAA stated and finally
agreed, that under-reporting of contaminated air events is occurring,
yet the CAA remains in denial of the problem;
4. Aircraft have no detection equipment
for contaminated air yet aircrews are not required to even have
a sense of smell to be able to fly. Many compounds present in
contaminated air are also odourless like carbon monoxide;
5. The breathing air for passengers and
crews comes from "bleed air" in flight, which is taken
from the engines. This is not filtered and is known to become
contaminated with engine oils and hydraulic fluids;
6. A typical jet engine oil, BP2380 states
on the MSDS that when heated the oils will give off toxic fumes
and that is what they are doing;
7. Airlines do not tell passengers they
have been exposed to contaminated air and never check up with
exposed passengers to investigate any medical effects of exposure
after an event;
8. Airlines fail to warn passengers of the
serious health effects that can occur from exposure to contaminated
air;
9. Most passengers assume the air they breathe
is free of hazardous chemicals as they trust the airline they
fly with to supply clean air. Should they get sick, few if any
ever make the link;
10. The CAA is entirely funded by the airlines
it regulates. This results in a serious conflict of interest.
This has resulted in the CAA dealing with the ongoing contaminated
air exposure issue in a negligent manner. The CAA in this regard
fails to protect the travelling public and working crews;
11. COSHH regulations are neither enforced
by the CAA or the HSE;
12. The CAA lacks expertise in the area
of contaminated air;
13. The 2004 paper by the CAA was seriously
lacking in technical accuracy and would never have stood up to
a peer review process. The paper was clearly written to protect
the industry, not the travelling public and crews. No independent
medical doctors or crews were contacted and asked to provide any
input. The paper relies in part, on research carried out by BAe
Systems which remains confidential and not available for public
review. The CAA paper was a poor attempt to claim contaminated
air causes no long term health effects which they even acknowledge
they have never investigated;
14. Serious failures in flight safety have
resulted from exposure to contaminated air as few crews actually
use oxygen when they suspect the air is contaminated as they ought
to. The airlines and CAA know this, but do nothing to rectify
this hazardous condition. Why? As to do so, would be costly to
the industry;
15. Lip service is being payed to regulations
regarding the reporting of contaminated air events or the airworthiness
of an aircraft which is suffering from such events;
16. Filtration systems, detection systems
and less toxic oils are all available today but the industry lacks
the will or desire to take steps to protect the travelling public;
17. The Government and regulator who are
entrusted to protect the public are in the eyes of many either
protecting British industry (British Aerospace) or failing to
enforce regulatory change.
In 2000 the House of Lords Science and Technology
Committee published its report Air Travel and Health. The
report was technically flawed and very misleading in relation
to the contaminated air debate. The report had numerous serious
errors. Many industry submissions were inaccurate and can only
be seen as attempts to mislead the Committee. This has allowed
the airline industry and government departments to hide behind
flawed data, an inaccurate report and resulted in further delay
in addressing this ongoing health and flight safety problem.
For instance, the report mentions on 18 occasions
the chemical isomer of tricresyl phosphate (TCP), notably
Tri-ortho-cresyl phosphate (TOCP). Yet the report amazingly
fails to ever mention the other more toxic isomers in the TCP
used by most commercial jet engine oil manufacturers, notably
Mono-ortho-cresyl phosphate (MOCP) or Di-ortho-cresyl
phosphate (DOCP). In doing so the report therefore under stated
the toxicity of the ortho isomers of TCP by a factor of 6.14 million,
based on their amounts present and relative toxicity as stated
by Mobil to the Australian Senate in 1999 and in papers published
by their head toxicologist also in 1999.
Why was Rolls Royce allowed to misinform the
Committee by stating:
"4.38 Rolls-Royce stated that all current
TCP used in the formulation of aviation lubricants contained far
less than 0.1% TOCP and that, in fully formulated oils, TOCP was
at practically undetectable parts-per-billion levels (p 271)."
Why did Rolls Royce not declare the significant
higher amounts of DOCP and MOCP?
Another example is as follows. The report stated:
"4.37 TCP exists in three different
forms or isomers, of which the "ortho" form (tri-ortho-cresyl
phosphate—TOCP) is highly toxic. As noted by the Medical
Toxicology Unit and OPIN, the most significant adverse effect
of overexposure to TOCP, which might arise from improper use of
the parent material such as swallowing or prolonged or repeated
inhalation or skin contact, is peripheral neurotoxicity (nerve
damage). This can lead to pain and serious paralysis of limbs,
and bowel and lung disorders. After exposure ceases, some recovery
usually ensues but a degree of permanent disability is not uncommon
(pp 96, 257)."
This is totally untrue, TOCP is in fact the
least toxic of the ortho isomers, with DOCP being five times more
toxic and MOCP 10 times more toxic than TOCP itself. That was
published in 1958. Also in 1958 it was clearly stated that it
was totally inappropriate to only refer to TOCP toxicity and forget
DOCP and MOCP toxicity which is exactly what the Lords report
did. Secondly "peripheral neurotoxicity" can not be
stated as the most significant adverse effect of TOCP. All medical
conditions resulting from exposure to contaminated air need to
be looked at. These are well documented and range from chronic
neurotoxic effects to lung injuries. Many published papers outline
doctors concerns in this regard. TCP is obviously part of the
equation as it is a known neurotoxin. Swab testing of UK registered
aircraft in the last two years has to date shown that 100% of
tests were positive for TCP on the passenger walls, cockpit Boeing
757 roof top filters, HEPA filter analysis, pilots' trousers and
even in pilots' blood. Additionally TCP exposure is now also linked
to chronic neurotoxic effects being seen in crews and confirmed
by way of SPECT and PET scans. Soon a blood test allowing passengers
to confirm TCP exposure and time of exposure will be available.
This is research I as a former crew member had to finance to get
started.
Another example of errors in the report are
as follows. The report stated:
"4.41 The absence of confirmed cases
of TOCP poisoning from cabin air and the very low levels of TOCP
that would be found in even the highly unlikely worst case of
contamination from oil leaking into the air supply lead us to
conclude that the concerns about significant risk to the health
of airline passengers and crew are not substantiated."
and
"4.39 Calculations by Airbus Industries
(Q 461 and refined in subsequent correspondence) showed that the
worst-case scenario of the total discharge of an engine's lubricant
into the engine would result in about 0.4 kg of oil passing into
the cabin ventilation systems. Assuming that the oil contained
3% TCP, of which 0.1 percent was TOCP, the peak cabin atmosphere
TOCP level would be about 0.025 mg/m3, reducing as a result of
normal ventilation thereafter. The peak level would be a quarter
of the workplace limit of 0.1 mg/m3 (and less than a tenth of
the emergency workplace limit of 0.3 mg/m3). Contamination at
much lower levels would result in visible smoke and odour which
would normally result in the crew switching off the ventilation
feed from the affected engine."
These comments are extremely misleading as it
is the effect of exposure(s) to the complex chemical mixture that
occurs during a contaminated air event that needs to be looked
at, not single compounds. Exposure standards for this scenario
do not exist. The exposure limit referenced by Airbus is for a
pure compound, not for a mixture of chemicals. Exposure standards
do not apply at altitude and only apply to workers in an eight
hour shift, not to passengers or crews inflight.
The issue of exposure to numerous chemicals
simultaneously was addressed by Lord Davies of Oldham who was
very clear on this matter when answering a question from the Countess
of Mar:
"The Countess of Mar asked Her Majesty's
Government: What exposure standards currently apply to any synergistic
effects of simultaneous exposure to numerous chemicals which may
be experienced by aircraft passengers and crew during a contaminated
air event in a reduced pressure environment. [HL1761]
Lord Davies of Oldham: None. European airworthiness
regulations for aircraft and engine design are written in objective
terms that stipulate that the air provided to the passenger and
crew compartments must be free from harmful or hazardous concentrations
of gases or vapours."
Another example of errors in the report is as
follows.
The report stated:
"4.40 This question, including the potential
effects on aircrew from any long-term exposure, has been looked
at in much greater detail by a Committee of the Australian Senate
inquiring into particular allegations of such contamination in
the BAe 146. Although its Report 58 referred extensively to cabin
air quality and chemical contamination in the aircraft, and recommended
that the engine lubricating oil used (a Mobil product) be subjected
to a further hazardous chemical review, it made no specific points
about TCP or TOCP that have given us additional concerns."
This is complete misinformation as it fails
to highlight that the Australian Senate looked at the effect of
exposure to the cocktail of chemicals people are exposed to, not
single compounds. May I remind you that the Australian Senate
spent about 100 times more time investigating these matters than
the Lords did and concluded that crews were being adversely affected
from exposure to contaminated air and described this as "Aerotoxic
Syndrome."
I could write a paper just on the House of Lords
inaccuracies but I am sure you can see the points I am making.
The important matter is to look forward and to what can be done
today and in the future to protect passengers and crews from contaminated
air exposures.
What I would suggest would be of most benefit
to the House of Lords Science and Technology Select Committee
would be to receive a presentation with questions and answers
from the GCAQE, especially as the GCAQE is the leading crew group
in the world on these matters. In fact I would say that there
are three people who know this issue back to front in the world
from a global perspective. Myself and two others. Susan Michaelis
a former pilot and who called for the Australian Senate investigation
in 1999 and who is the GCAQE researcher and author of the first
ever Contaminated Air Reference Manual published in 2007. The
third is industrial hygienist based in the USA called Judith Murawski
who co-chairs the GCAQE with me and who also sits on the industry
ASHRAE SPC-161 committee with me and industry representatives.
Both Ms Michaelis and Ms Murawski have published numerous papers
on these matters and made countless presentations around the world
over the last 10 years.
I hope this frank submission will help the Committee
realise the urgency with which these matters need to be addressed.
I urge the Committee to allocate the time and resources appropriate
to the seriousness of the issue at hand in relation to flight
safety and public health. However in view of the limited time
and resources at your disposal, I feel the only appropriate way
of unmasking the corporate scandal contaminated air has become,
would be by way of a Royal Commission which would allow the truth
and facts to be voiced and revealed once and for all.
The only people saying there is no problem is
the airline industry and those there to protect it.
13 June 2007
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