The use of occupational exposure limits and threshold limit values in the aircraft environment is examined in relation to aircraft air supplies contaminated by engine oils, hydraulic and other fluids used in aircraft

Michaelis, Susan

Watterson, Andrew

English

Stirling Online Research Repository

Use of Exposure Standards in Aviation

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

JOURNAL OF HEALTH AND POLLUTION2017  INTERNATIONAL AIRCRAFT  CABIN AIR CONFERENCEC O N F E R E N C E  P R O C E E D I N G SSessions presented at the 2017 International Aircraft Cabin Air Conference19-20 September 2017Imperial College London	 Index  Overview            S03 ‘Fragmentation of Information’ in International Data Gathering from Aircraft Fume Events   S04 Arie Adriaensen Aerotoxic Syndrome: A New Occupational Disease?       S12 Jonathan Burdon, Susan Michaelis, C. Vyvyan Howard         Aircraft Cabin Air Supply and the Internal Air System       S17 Peter RN Childs Aircraft Operator Safety Case for Managing Fume Risk      S22 Cliff Edwards Have You Been Exposed to Aircraft Engine Oil? Candidate Biomarkers of Exposure   S26 Clement E. Furlong, Judit Marsillach, Michael J. MacCoss, Rebecca J. Richter, Thomas R. Bukowski, Andrew N. Hoofnagle, Matthew G. McDonald, Allan E. Rettie Association and Causation: Bradford Hill Approach to Aerotoxic Syndrome    S32 David Gee Progress Report: Diagnostics of Health Disorders and Bio Monitoring in Aircraft Crew  Members after “Fume Events”— Preliminary Results After Analyzing Patient Files   S38 Astrid Rita Regina Heutelbeck Pathogenesis of Non-Specific Neurological Signs and Symptoms in Aircrew on Civil Aircraft S43 C. Vyvyan Howard Lubricant and Lubricant Additive Degradation: Implications for Cabin Air Quality   S45 David W. Johnson Airline Captain’s Case Study of Jet-Engine Oil Based Contaminated Cabin Air   S52 Michael Kramer Origins of Contaminated Air          S55 Tristan Loraine Air Accident Investigation Findings and Recommendations: Aircraft Contaminated Air Events S59 Tristan Loraine Case study: BA 286 & BA 12          S64 Susan Michaelis EASA and FAA Research Findings and Actions—Cabin Air Quality     S69 Susan Michaelis Mechanisms and Regulatory Implications of Oil Leakage into the Cabin Air Supply   S75 Susan Michaelis, John Morton GCAQE Meeting Introduction          S83 	Margaret of Mar Hair Analysis: An Innovative Biomonitoring Tool to Assess Human Exposure to  Tri-Cresyl-Phosphate (TCP)          S86 Vincent Peynet Moving Towards Total Cabin Filtration: Realtime Monitoring      S89 Chris Savage, Stephen Simpson, Paul Roux Aircraft Cabin Air and Engine Oil— An Engineering View      S93 Dieter Scholz Installation and Data Acquisition from a Real Time Air Quality Sensor (RTAQS) Monitoring  Pilot Breathing Air           S99 Grant M. Slusher, Jennifer A. Martin, Brian A. Geier, Kathy L. Fullerton,  Claude C. Grigsby, Darrin K. Ott A Win-Win-Win Path for Flight Safety, Health, and Corporate Profits     S104 Colin L. Soskolne Moving Towards Total Cabin Filtration: Filtering the Fresh Air Supply    S109 David Stein, Stephen Simpson, Paul Roux GCAQE Closing Speech          S115 Keith Taylor Organophosphate-Based Chemicals, Axonal Transport, and Cognitive Dysfunction   S118 Alvin V. Terry Jr. ICAO Circular 344 Guidelines on Education, Training and Reporting of Fume Events  S121 Antti Tuori REACH Substance Evaluation of TCP         S122 Petra van Kesteren,W.P. Jongeneel, N.G.M. Palmen, M. Beekman Tricresyl Phosphate Measurement Methods Used to Identify Flight Crew  and Passenger Exposure          S124 Chris van Netten Use of Exposure Standards in Aviation        S132 Andrew Watterson, Susan Michaelis Mind the Gap? Identifying, Managing and Preventing Some Aircraft Crew  Occupational Health and Safety/Flight Safety Problems      S138 Andrew Watterson, Susan Michaelis S138journalhealthpollution.org J Health Pollution 24: (191201) 2019JOURNAL OF HEALTH AND POLLUTIONMind the Gap? Identifying, Managing and Preventing Some Aircraft Crew Occupational Health and Safety/Flight Safety ProblemsAndrew Watterson, Susan MichaelisUniversity of Stirling, Stirling, UKCorresponding author:Andrew Wattersona.e.watterson@stir.ac.ukKEYWORDScrew health, organophosphate, regulations, cabin air, memorandum of understandingABBREVIATIONSCAA Civil Aviation Authority OP Organophosphate MOU Memorandum of understanding  ABSTRACTThe 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. INTRODUCTIONThe identification of occupationally-caused and occupationally-related diseases is all too often a very lengthy process. This impacts on official 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 find ( or don’t have the means or knowledge to make sense of findings or omit crucial findings), 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.1Table 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 affecting 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 S139journalhealthpollution.org J Health Pollution 24: (191201) 2019JOURNAL OF HEALTH AND POLLUTIONbe 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 staff in civil aviation will have safety and health protection appropriate to the nature of their work.DISCUSSIONTo 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 different stages of ‘flight’? Do agencies have the knowledge, skills, staff, 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.4,5The MOU is only as effective 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 staff at times with potential conflicts of interest because government and passenger interest can conflict. The CAA would be expected to assess dermal and inhalation exposures and altitude and exposure issues. It may be offered technical expertise by others working and researching in the field as for example happened with free blood testing, but such offers have been turned down. Effectively 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 flight 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?S140journalhealthpollution.org J Health Pollution 24: (191201) 2019JOURNAL OF HEALTH AND POLLUTIONFigure 1 — UK and Northern Ireland Memorandum of Understanding between HSE, HSENI and CAA and Memorandum of Understanding Guidance. (Text in italics represents authors contribution)S141journalhealthpollution.org J Health Pollution 24: (191201) 2019JOURNAL OF HEALTH AND POLLUTIONno or no effective 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 flight which is a major concern especially with effects of complex mixtures at altitudes above 5000 feet.What should be done to fix the many gaps in regulatory oversight, transparency, information, accessibility and flow, occupational disease recognition and monitoring, standard setting, application, effective occupational and environmental hygiene controls, design, inter-agency cooperation and effective 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 staffed regulators being more active in monitoring and enforcement and also through tweaking existing regulations. Such an approach should be cost effective 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 identified. 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)S142journalhealthpollution.org J Health Pollution 24: (191201) 2019JOURNAL OF HEALTH AND POLLUTIONsome necessary generic features for raising health and safety standards relevant to cabin air.7 These include effective 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 identified; identifying substances with known/ potential risks to human health at various levels; ongoing and new hazard identification 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 first place over many years have led to recognition of the problem that only now are beginning to increase recognition of the issue.8–10   References1. Michaels D. Doubt Is Their Product: How Industry’s Assault on Science Threatens You Health. Oxford: Oxford University Press; 2008.2. Loomis T, Krop S. MLSR No. 61 - Cabin Air Contamination In RB-57A Aircraft. Maryland: Army Chemical Center; 1955.3. Winder C, Balouet J. Aerotoxic Sydrome : Adverse Health Effects Following Exposure To Jet Oil Mist During Commercial Flights. In: Eddington I, ed. Towards a Safe and Civil Society. Proceedings of the International Congress on Occupational Health Conference. 4-6 September, 2000. Brisbane. Vol ICOH; 2000.4. CAA, HSE, HSENI. CAA/HSE/HSENI Memorandum of Understanding Guidance: CAP 1484.; 2017. https://publicapps.caa.co.uk/docs/33/CAP 1484 MAR17.pdf.5. HSE, HSENI C. Memorandum of Understanding Between The HSE, HSENI and CAA for Aviation Industry Enforcement Activities.; 2016. https://www.caa.co.uk/uploadedFiles/CAA/Content/Standard_Content/Our_work/About_us/Files/HSE CAA Memorandum of Understanding.pdf.6. ICAO. Cir 344-AN/202. Guidelines on Education, Training And Reporting Practices Related To Fume Events. Montréal: International Civil Aviation Organization; 2015.7. British Standards Institute (nd). BS OHSAS 18001. Occupational Health and Safety Management. https://www.bsigroup.com/en-GB/ohsas-18001-occupational-health-and-safety/.8. EASA. Research Project : CAQ Preliminary Cabin Air Quality Measurement Campaign. Final Report EASA_REP_RESEA_2014_4. Cologne: European Aviation Safety Agency; 2017. https://www.easa.europa.eu/system/files/dfu/EASA CAQ Study Final Report_21.03.2017.pdf.9. WSOCTV. 9 Investigates: Toxic air on board passenger jets - March 6, 2017. 2017. http://www.wsoctv.com/news/9-investigates/today-at-5-toxic-air-onboard-passenger-jets/498575431.10. Loraine T. How Safe Is Your Cabin Air? “Toxic air on planes is a danger for passengers.” Daily Telegraph. http://www.telegraph.co.uk/travel/news/How-Safe-Is-Your-Cabin-Air-Toxic-air-on-planes-is-a-danger-for-passengers/. Published June 18, 2015.

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

Stirling Online Research Repository (RIOXX)

https://dspace.stir.ac.uk/retrieve/befd91de-01e8-4270-b075-d658656f222c/Watterson-Michaelis-2017Paper.pdf

Use of Exposure Standards in Aviation

Abstract

Similar works

Full text

Available Versions

Stirling Online Research Repository

Stirling Online Research Repository

Stirling Online Research Repository (RIOXX)

Stirling Online Research Repository (RIOXX)