Memorandum by Unite the UnionTransport
and General Workers' Section
The Transport and General Workers' Union (T&G)
and Amicus Sections of UNITEthe Union is the largest trade
union representing cabin crew staff working on United Kingdom
registered commercial aircraft.
We welcome the invitation by the Select Committee
for "evidence on the health effects of air travel" and
we would like to specifically address concerns about the Aviation
Health Working Group (AHWG) and then a brief comment on cabin
air quality. This area is being covered in more detail in a submission
by one of our members who is an H&S representative working
in the civil aviation industry.
The responsibility for the policy on air transport
issues lies with Health and Safety Executive's (HSE) Special Transport
Sectors Unit. This is part of HSE's Policy Group's Civil Contingencies
and Special Sectors Division.
The HSE's main responsibility is for policy
in relation to ground operations at UK airports. However, because
the Health and Safety at Work (HSW) Act also applies to aircraft
in Great Britain's airspace, the HSE also needs to consider the
effect of the application of health and safety legislation to
aircraft in flight.
Unfortunately the HSE does not seek to enforce
the HSW Act in relation to aspects of aviation health and safety
which are the current remit of the Civil Aviation Authority (CAA).
There is a Memorandum of Understanding (MOU)
between the HSE and the CAA which established a framework for
liaison between the HSE and the CAA Safety Regulation Group (SRG)
which was supposed to ensure effective co-ordination on policy
issues, enforcement activity, and investigation in relation to
CAA/SRG and HSE responsibilities for safety in relation to aircraft
and the systems in which they operate.
In the Fifth Report of House of Lords Select
Committee on Science and Technology published in November 2000
one of the recommendations to Government was that a central source
should be given responsibility for advising Government on the
issues relevant to aviation health. The Department for Transport
(DfT) consulted the aviation industry and other interested parties
with a number of options, the preferred one of which was to give
responsibility to the CAA.
As a result of the consultation in 2003, the
DfT asked the CAA to set up the Aviation Health Unit (AHU). We
would draw the Committees' attention that at the time the T&G
opposed this. We believed then and still do that the HSE is the
appropriate "central source be given responsibility for advising
government on the issues relevant to aviation health" not
the DfT. This was not a criticism of the DfT as we work with the
Department almost on a daily basis. It is just that we believe
that in this instance the HSE is and should be the competent authority.
Despite our concerns the AHU was formed on 1
December 2003. Based at Gatwick within the Civil Aviation Authority's
(CAA's) Medical Department, its main role is to advise government,
through the Aviation Health Working Group (AHWG), on passenger
and crew health issues. As this is a different requirement from
the safety regulation role of the CAA, the DfT retains responsibility
for any policy changes arising from health recommendations.
From 1 April 2007 the AHU's funding has been
provided by industry in common with the other functions of the
CAA. The AHWG is an interdepartmental organisation, chaired by
the DfT, with representatives from the CAA, HSE and the Department
of Health. We have major reservations about the funding of AHU
which is being provided by industry. Health and safety funding
should be separate and independent from any overt or covert influence
of the funding providers.
Despite the Draft Mission Statement for the
Aviation Health Working Group
"The Aviation Health Working Group will
meet on a regular basis and will work in partnership with other
interested parties to give effect to the Government response to
the House of Lords Inquiry into Air Travel and Health."
According to the CAA website the AHWG meets
every two months to discuss issues relevant to aviation health
and was instrumental in the decision to form the AHU. At alternate
meetings, industry and passenger representatives attend. However,
it is not our experience that the AHWG has met on a regular basis.
A search of the DfT website resulted in minutes for the two last
meeting of the AHWG dated 4 April 2006 and 23 April 2007.
Nor do we believe it has it worked effectively
in partnership with other interested parties within the industry.
A specific example of the latter is the Independent Pilots Association
(IPA) which was prevented from joining the AHWG. The IPA and the
British Airline Pilots Association (BALPA) are the only other
UK unions representing flight crews in the UK. The IPA is an interested
party in all issues relating to aviation health and safety issues
relating to cabin crew so we find it difficult to understand why
they have been prevented from joining the AHWG.
The T&G Section of UNITEthe Union
has been a member of the Aviation Health Working Group since 2004
and drawing on this experience we firmly believe there is an ongoing
need for a simple and effective communication system about Aviation
Health issues. We believe it is of paramount importance that this
communication system is facilitated by regular meetings of the
The T&G Section of UNITEthe union
take the issue of the health and safety of its members, and indeed
the travelling public, very seriously. We remain very concerned
that the breathing air supply to the cabin, provided by bleed
air, is delivered completely unfiltered and that this and any
re-circulated air is not monitored to ensure it is "free
from harmful or hazardous concentrations of gases or vapours."
Currently the detection of potentially contaminated
air relies on the sense of smell of the air crew and we believe
that is totally unacceptable. Currently there is no requirement
for air crew, either cockpit or cabin, to be tested during their
mandatory medical for a minimum level of sense of smell.
Until proper standards are introduced contaminated
air events will continue to occur on commercial aircraft creating
potentially dangerous situations for both passengers and crew.
We are asking the Committee to recommend that
the AHWG should meet on a more regular basis and to be inclusive
in regard to the composition of the working group.
The HSE should become the competent authority
for civil aviation health and safety and not the CAA.
There is a need to establish a simpler and effective
communication system dealing with aviation health and safety issues.
We are asking for proper standards to be introduced
to prevent contaminated air events.
140 See http://www.dft.gov.uk/pgr/aviation/hci/ahwg/minutes/4may2001minutes. Back