Select Committee on Science and Technology Written Evidence

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."


    "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."

    October 2005

  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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