Letter from H&S Representative T&G
section of Unite the Union
You may be aware that Unite the Union is the
only union representing cabin crew staff on British registered
commercial aircraft and has been a member of the Aviation Health
Working Group since 2004 as the Transport and General Workers
Union.
This evidence enhances that submitted by the
Transport and General Workers Union (T&G) and Amicus Sections
of Unite—the union on Cabin Air Quality.
Further to the invitation by the Select Committee
for "evidence on the health effects of air travel" we
would like to specifically address concerns about the efficacy
of the Aviation Health Working Group(AHWG) and cabin air quality.
Despite the Draft Mission Statement for the
Aviation Health Working Group[141]
stating:
"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."
the AHWG has not met on a regular basis nor
worked entirely in partnership with other interested parties.
On the latter point the Independent Pilots Association, prevented
from joining the AHWG unlike the British Airline Pilots Association
who are able to attend, is the only other UK union representing
flight crew. They are very much an interested party in all aviation
health issues. We firmly believe there is a continuing need for
simple and effective communication about Aviation Health and it
is of paramount importance that this be facilitated by regular
meetings of the AHWG.
As to cabin air quality it is noteworthy that
whilst the House of Lords Report (HL Paper 121) called for:
"9.3(c) real-time monitoring of air quality
(see paragraph 5.50) and other aspects of the cabin environment,
with a view to establishing new and clear regulatory minima for
passenger cabin ventilation"
the lack of equipment capable of undertaking
this task was emphasised over 5 years ago[142]
at the meeting on 16 October 2002 chaired by Peter Smith:
"On the `collection of basic cabin environment
data' [recommendation 1.25), Nigel Dowdall outlined the lack of
available equipment to provide the sort of `routine monitoring'
recommended by the House of Lords. He indicated that material
had been published on a number of websites including BA's, Boeing's
and also in a number of articles and journals. He also confirmed
that this material would include some of the routine data continuously
monitored on-board flights. The Secretary confirmed that MLD had
received a list of websites from BATA, and the Chair concluded
that this action point had been achieved."
and, it is understood, nothing has changed.
At paragraph 3.33 the House of Lords Report
stated:
"Until 1996, both FAA and JAA had the same
basic requirement for cabin ventilation rates. FAR 25.831 and
JAR 25.831 required a minimum supply of 10 cubic feet per minute
(cfm)[26] [27] of fresh air per flight crew member, which `must
be free from harmful or hazardous concentrations of gases or vapours'
with specific maximum concentrations for:
— carbon dioxide at 5,000 parts
per million by volume (ppm)[28];
— carbon monoxide at 50 ppm; and
— ozone at 0.1 ppm (short-term
emergency maximum 0.25 ppm)."
and yet, to this day, carbon monoxide detectors
are not fitted to commercial aircraft and in answer to a written
question by Lord Tyler the Government have indicated they have
no intention of ensuring such detectors are fitted in the majority
of commercial aircraft:
"Lord Tyler asked Her Majesty's Government:
What steps they have taken to ensure that carbon monoxide detectors
are fitted in aircraft to enable the commander to monitor emissions.
[HL1941]
Lord Davies of Oldham: The Civil Aviation Authority
(CAA) has recently drafted a European Technical Standards Order
(ETSO) that provides an up-to-date technical specification for
a carbon monoxide detector for aviation use. This draft ETSO has
been submitted to the European Aviation Safety Agency (EASA) with
a recommendation for adoption as a European standard. At the same
time the CAA submitted a proposal for changes to EASA's certification
specifications that would mandate the installation of carbon monoxide
detectors in future aeroplane designs.
These proposals were made as a direct result
of experience of accidents, and they were supported by a preliminary
Regulatory Impact Assessment. The proposals, if adopted, would
require installation of carbon monoxide detectors only in single-engined
aeroplanes with forward mounted engines, since the world-wide
experience of accidents and incidents does not support the need
for installation of carbon monoxide detectors in other aircraft."
Government further confirmed that aircrew relied
on their sense of smell to determine whether a contaminated air
event was taking place and that there is no requirement for fitting
air quality monitoring equipment, or for air crew to be tested
during their mandatory medical for a sense of smell:
"The Countess of Mar asked Her Majesty's
Government: Further to the Written Answer by the Lord Davies of
Oldham on 19th October (WA 126), how, in the event of a system
failure and a contaminated air event occurring, aircrews know
that such an event has occurred in the absence of monitoring devices
when the contaminated air is caused by compounds, such as carbon
monoxide, that have no odour. [HL2313]
Lord Davies of Oldham: In the absence of odour,
and in the absence of any discernible effects, aircrew will not
know that a contaminated air event has occurred. In such a case
reliance is placed upon routine maintenance actions to find and
fix the system failure.
The Countess of Mar asked Her Majesty's Government:
Why contaminated air detection systems are not fitted to all British
commercial aircraft. [HL1641]
Lord Davies of Oldham: There are no statutory
requirements for the fitting of air quality monitoring equipment
in aircraft. Such equipment is not required because aircraft ventilation
systems are designed to supply air of an acceptable standard.
This is confirmed at initial certification and each aircraft is
subject thereafter to scheduled maintenance actions to ensure
those standards are maintained. Air quality monitoring exercises
have confirmed the acceptability of cabin air supplied. Where
problems are encountered in service these are investigated and
changes are introduced as necessary."
In consequence, it is quite clear that, despite
specific maximum concentrations for ozone, carbon monoxide and
carbon dioxide being stated (3.33), there is still no real time
equipment installed to monitor, control, or warn flight crew if
these levels are exceeded. Additionally, there is no warning possible
of a contaminated air event when substances hazardous to health,
such as Tri-cresyl phosphate (TCP), enter the cabin.
Furthermore, and relevant to the House of Lords
Report (9.3(e)), there has been little consideration of the synergistic
effects posed by chemicals:
"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."
IN CONCLUSION
1. The T&G take the issue of the health
and safety of its members, and indeed the travelling public, very
seriously. We remain exceptionally concerned that the breathing
air supply to the cabin, provided by bleed air, is delivered completely
unfiltered and that both this supply and any recirculated air
is not monitored to ensure it is "free from harmful or hazardous
concentrations of gases or vapours." Current detection of
potentially contaminated air relies on the nasal passages of the
crew and that is not acceptable.
Contaminated air events continue to happen on
commercial aircraft.
2. We trust the AHWG will meet on a regular
basis and will work in partnership with other interested parties.
17 June 2007
141 http://www.dft.gov.uk/pgr/aviation/hci/ahwg/minutes/4may2001minutes Back
142
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