Mind the Gap? Identifying, Managing and Preventing Some Aircraft Crew Occupational Health and Safety/Flight Safety Problems

Abstract

KEYWORDS crew health, organophosphate, regulations, cabin air, memorandum of understanding ABBREVIATIONS CAA Civil Aviation Authority OP Organophosphate MOU Memorandum of understanding ABSTRACT The paper explores a number of obstacles to and key approaches on the recognition and management of occupational health problems, relevant interactions and possible multi-causality in the context of aircraft crew health and safety. The dominant approach has all too often been-'don't look, don't find, where is the problem?' Control and removal of these problems has failed even where there is a regulatory system that theoretically applies the standard occupational health and safety management hierarchy. Some solutions to address this failure and examples of good practice both within Europe and internationally are then identified and analyzed.

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JOURNAL OF HEALTH AND POLLUTION
Mind the Gap? Identifying, Managing
and Preventing Some Aircraft Crew
Occupational Health and Safety/Flight
Safety Problems
Andrew Watterson, Susan Michaelis
University of Stirling, Stirling, UK
Corresponding author:
Andrew Watterson
a.e.watterson@stir.ac.uk
KEYWORDS
crew health, organophosphate, regulations, cabin air, memorandum of
understanding
ABBREVIATIONS
CAA Civil Aviation Authority
OP Organophosphate
MOU Memorandum of understanding
ABSTRACT
The paper explores a number of obstacles to and key approaches on
the recognition and management of occupational health problems,
relevant inter-actions and possible multi-causality in the context of
aircraft crew health and safety. The dominant approach has all too
often been – ‘don’t look, don’t find, where is the problem?’ Control
and removal of these problems has failed even where there is a
regulatory system that theoretically applies the standard occupational
health and safety management hierarchy. Some solutions to address
this failure and examples of good practice both within Europe and
internationally are then identified and analyzed.
INTRODUCTION
The identication of occupationally-caused and
occupationally-related diseases is all too often a very
lengthy process. This impacts on ocial recognition,
prescription and scheduling of the disease by
governments, compensation for victims and most
importantly preventative actions. The result is that
those with occupational diseases from a process or
product are often left behind decades after an industry/
occupation and its materials and technology change or
cease. The dominant approach to many occupational
diseases has all too often been – don’t look (or don’t
have the means to look), don’t nd ( or don’t have the
means or knowledge to make sense of ndings or
omit crucial ndings), where is the problem – and in
the process important information from crew can be
discounted or simply dismissed as ‘hysteria? Sometimes
the techniques to identify potential problems or make
sense of a variety of data relating to them have been
lacking. National health and safety regulations are usually
underpinned by basic principles of removing hazards at
source and, if that is not possible, adopting a hierarchy
of approaches linked to substitution of less hazardous
materials, isolation, engineering controls and personal
protective equipment. Yet these principles have sadly
all too often been subverted by industry, governments
and complicit or captured regulators as the former
head of the United States Occupational Safety and
Health Administration, David Michaels, has carefully and
recently documented.1
Table 1 illustrates how such approaches have either
crudely or at times in a more subtle manner been
adopted to air quality threats to crew linked to their
possible organophosphate exposures (OPs).2,3
This is against a backdrop of a range of aviation
regulations, standards and guidance material dealing
with cabin air quality aecting crew and passengers
in various ways. Examples of these include CS/FAR
1309 Equipment and Systems Design – Airframe:
CS E510…. FAR 33.7 – Safety analysis engine/APU
– Bleed air- Incapacitation /Impairment; CS E 690….
– Bleed air purity engines & APU; CS & FAR 25.831
a/b - Airworthiness - Ventilation and Heating (CO, CO2,
O3); AMC 21.A.3B(b) – Unsafe condition – Impairment/
discomfort – Increased frequency; (EU) 2015/1018 -
Reporting: for example on contaminated air- could
endanger aircraft/occupants. In addition, a range of
occupational or occupationally-related regulation on
health and safety within the EU either apply or would

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be relevant to aircrew and passengers on the ground
and perhaps in the air in some circumstances. These
include the following directives: the OSH Framework
Directive EU 89/391; Directive – EU 98/24/EC – chemical
agents; Directive – 2004/37 EC – Carcinogens; Directive
– 2000/79/EC – Working time- mobile workers – mobile
sta in civil aviation will have safety and health protection
appropriate to the nature of their work.
DISCUSSION
To what extent can such regulations, directives and
guidance be applied to cabin air, at what stages in a
plane’s travel form one airport to another? Can they be
enforced? Are they enforced? How does inter-agency
collaboration work when covering dierent stages of
‘ight’? Do agencies have the knowledge, skills, sta,
resources and time to enforce? The answers to these
questions are not fully available and can vary depending
upon who provides the information. Mechanisms exist
to do this depending on interpretation and application
of guidance as for example Figure 1 which illustrates the
UK and Northern Ireland memorandum of understanding
(MOU) with the CAA and related guidance.4,5
The MOU is only as eective as its scope and
application. The Civil Aviation Authority (CAA), the
aviation regulator, takes the aviation health and safety
lead and provides advice to Government/media/
passengers on health issues which must present sta
at times with potential conicts of interest because
government and passenger interest can conict. The
CAA would be expected to assess dermal and inhalation
exposures and altitude and exposure issues. It may
be oered technical expertise by others working and
researching in the eld as for example happened with
free blood testing, but such oers have been turned
down. Eectively there appears to some to be an opaque
if not closed loop between for example CAA, HSE Public
Health England, EASA, the UK Committee on Toxicity
(COT) and the Industrial Injuries Advisory Council on air
quality advice and information used and any recognition
of occupational ill-health due to cabin air. The HSE
will cover non-air crew workers who are on the ground
and have no intention of ight but can raise concerns
with CAA when aircraft are in GB airspace. To outside
observers, it seems they are given lesser priority where
other regulators are better placed.
Under the 2008 MOU, there has been to our knowledge
Table 1 — The Procrustean Regulatory and Policy Approach to Assessing Air Cabin Quality Threats Relevant to OHSM?

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Figure 1 — UK and Northern Ireland Memorandum of Understanding between HSE, HSENI and CAA and Memorandum of
Understanding Guidance. (Text in italics represents authors contribution)

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no or no eective Control of Substances Hazardous
to Health Regulations enforcement by HSE of or CAA
enforcement of the Working time regulations relating
to chemical exposure. Workplace exposure standards
for chemicals used by HSE in the UK would not be
applicable in ight which is a major concern especially
with eects of complex mixtures at altitudes above 5000
feet.
What should be done to x the many gaps in regulatory
oversight, transparency, information, accessibility and
ow, occupational disease recognition and monitoring,
standard setting, application, eective occupational
and environmental hygiene controls, design, inter-
agency cooperation and eective coverage of air crew,
passengers and ground crew with regard to chemicals
and processes known to cause or suspected to cause
cabin air pollution? Better application of existing laws
and regulations and their logical extension to air as
well as ground exposures could be done partly through
well resourced, trained and staed regulators being
more active in monitoring and enforcement and also
through tweaking existing regulations. Such an approach
should be cost eective as well as raising health and
safety standards for both workers in the industry
and passengers as knowledge of exposures to toxic
chemicals in the industry grows.
In addition, building on, properly evaluating and applying
widely the good practice on occupational health and
safety management systems that is developing for the
industry under such initiatives as the ICAO’s Guidelines
on Education, Training and Reporting Practices related to
Fume Events 2015 will be valuable (Figure 2).6
It must of course not be viewed as a tick box exercise
but lead to action at all appropriate levels where
problems are identied. It would underpin the proposed
improved regulatory framework and mechanisms. The
OHSAS 18001 that incorporated key aspects of ISO
45001 which now replaces it as the new international
standard for occupational health and safety indicated
Figure 2 — The ICAO approach – Moving in the right direction with work to do? (Text in italics represents authors contribution)

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some necessary generic features for raising health and
safety standards relevant to cabin air.7 These include
eective systems integration and greater attention to
worker ‘wellness’ and collection of occupational health
data linked to increasing crew participation, recording
and perceptions. Evidence suggests that all too often
the critical resource of air crew on fume incidents has
been marginalized or dismissed rather than used in ways
that OHSAS indicates. In addition, the approach requires
a linkage to mechanisms to improving responses on
technology and materials; increasing attention paid to
suppliers, contractors and health and safety bodies
relevant to issues identied; identifying substances with
known/ potential risks to human health at various levels;
ongoing and new hazard identication activity including
non-routine as well as routine work and product design
and emergency situations such as a ‘fume’ incidents.
What is clear, however, is that the issue has been seriously
neglected all too often by industry and regulators at
both national and international level. Only the actions of
individual pilots and cabin crew and their trade union and
professional bodies in the rst place over many years
have led to recognition of the problem that only now are
beginning to increase recognition of the issue.8–10
References
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the International Congress on Occupational Health Conference. 4-6
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danger-for-passengers/. Published June 18, 2015.