The effectiveness of the CAA - Call for Evidence by the Department for Transport UK - Closing on 29th January 2023
‘About the call for evidence
This call for evidence relates to the effectiveness and efficiency of the Civil Aviation Authority (CAA). It is part of evidence-gathering for the Department for Transport’s review of the CAA. It does not cover departmental policy.
The CAA is the United Kingdom’s independent specialist aviation and airspace, safety, security, consumer rights, spaceflight, and economic regulator. The CAA ensures:
• the aviation industry meets the highest safety standards
• consumers have a choice, value for money, and are protected and treated fairly when they fly
• the efficient use of airspace to manage the environmental impact of aviation on local communities and the reduction of CO2 emissions
• compliance with regulations so that security risks are effectively managed by the aviation industry’
We ask that everyone who uses air travel as a passenger or who works as cabin or flight crew completes this ‘call for evidence’ and leaves their comments on the very important problem of contaminated air in aircraft, which affects both flight safety as well as consumer rights because everyone has a right to clean air.
https://www.ohchr.org/en/special-procedures/sr-environment/clean-air-and-human-rights
In an enclosed environment, with little or no possibility of removing yourself from that environment, it is even more important.
‘Statements on the right to healthy indoor air
Introduction
Everyone has a right to healthy indoor air. It is the dual purpose of this document to:
1. inform those who have an influence on public health about this right and of their obligations related to this right, and
2. empower the general public by making people familiar with this right.’
https://www.euro.who.int/__data/assets/pdf_file/0019/117316/E69828.pdf
The CAA, UK Department for Transport and U.K. Government clearly missed the memo’s from the UN and WHO.
This issue has not been dealt with either effectively or efficiently by the CAA and is a very serious health and safety issue.
Is the CAA effective in ensuring the airline industry meets the highest standards?
This is your opportunity to let the UK Government Department for Transport know your views on the subject, but you have to be quick as it closes on Sunday 29th January 2023.
You do not have to complete all of the sections and can finish at this point and leave your own comments -
‘If you don’t know or have not had direct experience of the CAA in the last 5 years and the remainder of this consultation is about that experience, you may now either continue answering the consultation questions or go to the final comments section.’
https://www.gov.uk/government/consultations/the-effectiveness-and-efficiency-of-the-civil-aviation-authority-caa/the-effectiveness-and-efficiency-of-the-civil-aviation-authority-caa?fbclid=IwAR0t9cIlospkdyzx271UUwFkypdbMmD4VQOkEiiCTiO0lxhyzNp3liH4l9Q
A few suggestions in support of our campaign for clean, uncontaminated air onboard aircraft are shown below along with some of the history on the topic:
• Pilot incapacitation as a result of intoxication from fumes still occurs. The implications of both pilots becoming incapacitated during a flight remains a serious threat to flight safety.
• Cabin crew incapacitation affects flight safety also. Surely passengers would prefer that their cabin crew are ready and able to deal with any medical or emergency eventuality rather than sitting down on a crew seat feeling unwell or in the case of serious fume events, wearing a smoke hood.
• Fume events as well as repeated or prolonged low level exposure to chemicals (including organophosphates)onboard aircraft continues. Short term health effects can be extremely unpleasant and the long-term health effects can be devastating.
• You could question why the practice of permitting toxic air in aircraft cockpits and cabins has been allowed to continue for decades and why the air provided on commercial aircraft (except the Boeing 787) comes direct from the aircraft engines without filtration or elimination of toxins known to be harmful to human health.
• Why is there no monitoring of known harmful chemicals onboard aircraft?
• Why has there been no evaluation of the synergistic effects of the chemicals?
• You could question why the the CAA produced a ‘Care Pathway’ in partnership with the NHS, when those who are referred by their GP’s to St. Thomas’ Hospital Toxicology Department in London are only interviewed, receive no support, advice or toxicology testing and are then referred back to their GP’s.
• You could also question why the research recommended by the House of Lords Enquiry in 2007 into Cabin Air were not undertaken.
This is from P34 - House Of Lords Enquiry 2007.
‘Recommendations:
4.49. We recommend that the CAA carries out an awareness campaign aimed at airlines and pilots to highlight the importance of reporting contaminated air events and encourages airlines to follow the spirit as well as the letter of the rules on reporting these events.
4.50. We recommend that the AHWG-sponsored research to identify the substances produced during a fume event be completed urgently. It should be followed up by an epidemiological study on pilots to ascertain the incidence and prevalence of ill health in air crew and any association there might be with exposure to the chemicals identified in the AHWG-sponsored study, paying particular attention to the synergistic effect of these chemicals.
4.51. We recommend that the Government works with manufacturers, airlines and the regulator to take effective action in preventing oil and hydraulic fluid leakages into the aircraft cabin.
4.52. We recommend that a protocol should be made available to health professionals, in particular Authorised Medical Examiners, on how to deal with air crew who suffer contaminated air events. We recommend that airlines, the regulators and the Government work together to improve the support given to pilots claiming to suffer ill health following a contaminated air event.’
https://publications.parliament.uk/pa/ld200708/ldselect/ldsctech/7/7.pdf
The recommendations made by the House of Lords were ignored except for an Air Sampling Study by Cranfield University which confirmed the presence of Tricresyl phosphate (TCP) and Tributyl phosphate (TBP) inside aircraft cockpits and cabins. However, due to there not being any fume events on any of the aircraft in that study and the levels measured were said to be within acceptable exposure standards and guidelines, the U.K. Government used the results to state that the air onboard aircraft is safe.
They failed to take into account the known cumulative effects of many of the chemicals used in aircraft oil, hydraulic fluid, exhaust from ground equipment and from other aircraft as well as individual genetic variability.
They also failed to take into account the effects of the various chemicals which usually present in aerosol form (nano particles capable of crossing the blood-brain barrier) on vulnerable passengers such as the elderly, frail, infants and unborn.
In 2018 swab samples were taken onboard British Airways Airbus A380’s which also confirmed the presence of the organophosphates TCP and TBP:
https://www.flyaware.nl/wp-content/uploads/2018/05/BASSA-Crew-and-Passenger-exposure-to-organophosphates-on-aircraft..pdf
• There is still no support for those injured and still no medical protocol implemented within U.K. Accident & Emergency Departments to enable medical professionals to help those who have been exposed to toxic chemicals onboard aircraft and the majority of GP’s are still unaware of this type of poisoning.
• No epidemiological studies of air crew complaining of ill health following exposure have been undertaken.
• Both passengers and airline crew have been injured. There are thousands (if not tens of thousands) worldwide living with the long-term health effects of exposure to fumes onboard aircraft and many deaths have occurred. Yet the CAA (Aviation Health Unit), Airlines and U.K. Government have made no effort to find out exactly how this has happened or the mechanisms of injury. In fact, they continue to deny any connection to the contaminated air onboard aircraft and state that the air is safe.
• They also use the term ‘nocebo effect’ - (psychological manifestation) as an alternative explanation for the long-term injuries caused, in order to absolve themselves, airlines and the U.K. Government from accountability.
Pages 11 &12 - 3rd Report -
House of Lords Science and Technology Committee Update
2008:
‘Recommendation 5.17
We recommend that the AHWG-sponsored research to identify the substances produced during a fume event be completed urgently. It should be followed up by an epidemiological study on pilots to ascertain the incidence and prevalence of ill health in air crew and any association there might be with exposure to the chemicals identified in the AHWG-sponsored study, paying particular attention to the synergistic effect of these chemicals.
Government response
We agree that the AHWG-sponsored research to identify the substances produced during a fume event should be completed urgently.’
https://publications.parliament.uk/pa/ld200708/ldselect/ldsctech/105/105.pdf
Unfortunately, substances produced during a fume event were not identified during the Air Sampling study as no fume events occurred. There has not been an epidemiological study and the synergistic effects remain unknown. No attempt has been made by the UK Government or the CAA since to undertake any of this research, instead they are depending on EASA to give them this information from their ongoing industry funded research.
Anyone would think they don’t want to know and certainly don’t want airline employees or the travelling public to know either.
This is what Professor Jeremy Ramsden, formerly of Cranfield University said about the Research carried out for the UK Department for Transport on 3rd November 2011 in an interview with David Learmount for FlightGlobal:
"Unfortunately," said Ramsden, "the final conclusion of the report is the statement: 'With respect to the conditions of flight that were experienced during the study, there was no evidence for target pollutants occurring in the cabin at levels exceeding available health and safety standards and guidelines.'
"The first phrase underlines the fact that the study failed to achieve measurement of a 'fume event', even though that was one of its principal objectives. Even for 'normal flying conditions' the purported conclusion is irrelevant because no standards are available for some of the most problematical substances. Nevertheless, despite the fact that this 'conclusion' is neither sound nor justified by the actual work carried out, it has been carelessly and uncritically quoted, including by the UK Minister for Transport Theresa Villiers, and widely used to infer that there is no safety and health problem."
‘In the meantime, effective treatment of crew and passengers who have suffered neurological damage might now be practical. "Highly encouragingly, successful biochemical treatments are being developed and are already available," said Ramsden. But treatment can only be provided if the patients are informed of contamination events, because, as Ramsden points out, misdiagnosis is frequent.
Ramsden pointed out that the Boeing 787 will be free of this problem because it does not use engine bleed air for cabin ventilation and pressurisation. For most aircraft types this is not the case, and Ramsden remarked: "The mandatory inclusion of a health warning on air tickets, as on cigarette packets, would seem to be the alternative in the face of technical inaction."’
https://www.flightglobal.com/news/articles/cranfield-professor-proposes-action-over-toxic-cabin-364287/
‘Sir Stephen Hillier, Chair of the Civil Aviation Authority, said:
At the Civil Aviation Authority, we work tirelessly on our mission to achieve improvements in aviation and aerospace for consumers and the public.
We welcome the opportunity this review presents to highlight the dedication, skill and continuous learning culture of our organisation, whilst identifying any areas for improvement.
It will help ensure that we continue to be a diverse, innovative and future-focused regulator, dedicated to improving aviation safety, security and consumer interests and enabling a thriving aerospace sector.
We look forward to working in an open, transparent and collaborative way with government to support this review.
The review forms part of a wider programme looking at public bodies across government, announced in April this year.
It comes at a crucial time for the aviation industry as it continues its strong recovery from the pandemic and will also run in parallel, but entirely separate to, the International Civil Aviation Organisation safety audit due to take place.’
You can let the UK Government know your thoughts on the CAA Chair’s perception that they are a ‘diverse, innovative and future-focused regulator, dedicated to improving aviation safety, security and consumer interests’ in respect of the contaminated air in aircraft which has caused devastation to many individuals and families.
We feel they need to address the situation of contaminated air in aircraft before they can consider being ‘future focused’ and if they were serious on being ‘dedicated to improving aviation safety’ this would have already been dealt with.
Thank you so much for your continued support.
https://www.gov.uk/government/consultations/the-effectiveness-and-efficiency-of-the-civil-aviation-authority-caa/the-effectiveness-and-efficiency-of-the-civil-aviation-authority-caa?fbclid=IwAR0t9cIlospkdyzx271UUwFkypdbMmD4VQOkEiiCTiO0lxhyzNp3liH4l9Q
For further information please visit:
https://www.unfiltered.vip/science.html?fbclid=IwAR2_XlO4iVU8uveni2T1aPY2u4ogwYJ5eicXP4M3gv_LcecxW9COIj8nCTE