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Definition of Safety ©
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10th April 2008
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by Susan Michaelis
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While aviation safety ought to be based upon an
aircraft’s ability to meet the regulations, it is clear that the
aviation industry’s definition of air safety is very different. British
Aerospace advised the Australian Senate Inquiry looking at contaminated
air in 2000 that of its 350 BAe 146 aircraft operating in 27 countries
with 52 airlines:
The BAe 146 has never suffered a passenger fatality
or a fatal accident due to technical failure in more than 4.5 million
hours of operation. [52]
When questioned by Senator O’Brien of the Australian
Senate Inquiry committee looking into these matters, British Aerospace
very clearly stated that the measure of an aircraft’s safety record was
measured in terms of the aircraft having, ‘not had a fatality due to a
technical problem, and that is the criterion.’ Senator O’Brien clearly
stated that he was keen to draw out that airlines use the term that its
aircraft is ‘safe’ by ‘getting the passengers from here to here, point A
to point B, without tragedies or disasters.’ This is clearly supported
by the BAe acknowledgement that the definition of aircraft safety
records was based upon the lack of aircraft accidents causing fatalities
due to a technical fault. [17] This view of when an aircraft is deemed
safe completely without any doubt, ignores many issues that occur before
a fatal accident for ‘technical reasons’ occurs, including cabin air
contamination. The fact that an aircraft could crash based on non
technical reasons such as pilot error, perhaps due to contaminated air,
do not even fall into the aviation industry definition of ‘safety.’ This
is an extremely worrying situation that needs urgent review.
Numerous in flight incidents are showing the serious
flight safety issues linked to contaminated air exposure. In this
chapter we will refer a lot to the British Aerospace BAe 146 as an
example as it has been linked frequently to the contaminated air issue.
However, contaminated air events have occurred on nearly all commercial
aircraft types with some types having significantly higher number of
events such as the Boeing 757, Airbus A320 and MD80. This is essentially
because contaminated air as acknowledged previously is a function of
bleed air system design and all engines will leak. [14][38] Had
contaminated air not had a health part of the debate with massive
potential financial implications to the airline industry it may be that
the issue would have been addressed by now.
Kolver and Malmo Incidents
Despite years and years of contaminated air exposure
events and extensive documented history showing such oil leaks were
occurring since the BAe 146 entered airline service in 1983 (see
appendices and other data in this manual), adequate steps were not taken
to address the problem. Two well reported major flight safety events
occurred on the BAe 146 that should have logically and finally forced
the airline industry to act but they regrettably adopted a business as
usual attitude. The first occurred in Australia on 10 July 1997 and
became known in the trade as the ‘Kolver Incident’, [24] a mere 20 years
after the 1977 paper by Dr Weir. [22] The second occurred on 14 November
1999 in Sweden and became known as the ‘Malmo Incident’ in which fumes
were smelt over 3 sectors. [59] In both these incidents contaminated air
affected at least 2 pilots and in the later case the cabin crew as well.
These incidents are discussed more in Chapter 8 & 9. As in all
contaminated air events emergency oxygen was available for the pilots to
use to enable them to land the aircraft in an emergency and,
theoretically, significantly decrease the immediate risk to the aircraft
and its occupants. However, emergency oxygen was only used by the pilots
in 1 of these four sectors and not immediately contaminated air was
suspected in any case. We say in theory because having failed to tell
pilots and crews for years that exposure to contaminated air was a
health or flight safety concern, most crews like the crews on these
incidents simply ignored contaminated air as it had become a normal part
of the job. The airline industry, however, started to see the writing on
the wall for an accident because crews were becoming incapacitated
during contaminated air events despite emergency oxygen being available
to the pilots to potentially stop this. This placed the aviation
industry in an awkward position, how to minimise the risk of losing an
aircraft but without admitting to the crews and passengers of the full
health and safety risks and taking costly steps like with TCAS to do
something.
What forced the airline industry to finally take some
action was the ‘Australian Senate Inquiry’, [60] which will be reviewed
in greater detail in Chapter 18. The Inquiry concluded in October 2000
that contaminated air on the British Aerospace BAe 146 was not just a
flight safety issue but also that crews were getting sick. It also found
that unlike the industry statements that this was not an air safety
issue, the aviation regulations clearly showed that it was a safety
issue by virtue of the fact that there are regulations which, ‘require
pilots to be in a suitable state of health for flying an aircraft and
therefore acknowledges the regulatory link between crew health and air
safety’. [60] The inquiry was an embarrassment to the airline industry
as it showed clearly what was going on and the way the airline industry
and in particular British Aerospace had been unsuccessful in dealing
with contaminated air issues for almost 20 years and longer in general.
Seeing without doubt what was coming from Australia,
the UK Government, in an effort to protect the British Aviation
industry, decided to get its pending inquiry into ‘Air Travel and
Health’ to also supposedly investigate the contaminated air issue. The
task was given to the Select Committee on Science and Technology and it
is now referred to as the ‘House of Lords Inquiry.’ [61] The House of
Lords Inquiry which we take a good look at in Chapter 18 started taking
‘Oral Evidence’ on 2nd May 2000 and was ordered to be printed on 15
November 2000. As will clearly be shown later in the manual, the House
of Lords Inquiry in no way adequately undertook a thorough review of the
contaminated air issue. The House of Lords Inquiry certainly went to
great effort to conclude the complete opposite view to what the
significantly more detailed Australian Senate Inquiry concluded in
relationship to contaminated air; in that there was nothing to be
worried about. It would appear that the Government and any interested
parties had, through the Lords, achieved their objective for the
aviation industry as a whole, of business as usual. This is not
surprising given that aviation is one third of UK exports.
Another major contaminated air event occurred on 5
November 2000. This particular event occurred in British airspace on a
UK registered BAe 146 and was most likely one of the reasons, along with
the strong conclusions of the recently completed Australian Senate
Inquiry, that the UK initial BAe 146 certifying Regulatory Authority,
the CAA finally took some action. This was known as the ‘Birmingham
G-JEAK’ incident in November 2000. [62] As this serious incident
involving both pilots was over British airspace it would appear that the
UK Air Accidents Investigation Branch (AAIB) and the UK Civil Aviation
Authority finally had to act. They had to act especially as the
manufacturer of the aircraft was a British based company in the way of
British Aerospace and the number of BAe 146 incidents was increasing.
The G-JEAK incident is discussed in Chapter 10. It had been the UK Civil
Aviation Authority which had issued the BAe 146 its original Certificate
of Airworthiness in 1983. Their response as outlined below may have a UK
theme and refer to a UK jet aircraft in the guise of the BAe 146 but the
arguments and debate apply globally and to all aircraft manufacturers,
whether they be Boeing, Airbus or Embraer in the context of contaminated
air. This is because the aviation industry is very much a global
business which has to date had a global denial of contaminated air
publicly.
Aviation activities come under the remit of aviation
regulators. The biggest regulator in the world by a long way is the US
Federal Aviation Administration (FAA). After the FAA, the UK Civil
Aviation Authority (until the birth of the European Aviation Safety
Agency (EASA)), used to be one of the main aviation regulators. Most
national regulators have looked to the US FAA or to regulators like the
CAA, to provide guidance when needed, and in 2000 guidance was being
called for on contaminated air events. The reason why many smaller
regulators look to the FAA, CAA or others is also because they have far
larger resources and expertise than regulators in many countries. The US
FAA’s budget for Fiscal Year 2005 was $13.6 billion. [63] Compare that
to the total resourcing to be received by the Australian Civil Aviation
Safety Authority in 2004-05 of AU$114.7m (approximately US$ 86 million),
[64] and it can be seen why aviation regulations drawn up by the FAA
called the US Federal Aviation Regulations or ‘FARS’ are adopted by most
nations rather than reinvent the wheel. However, the European Union did
just this by introducing via the Joint Aviation Authorities (JAA), its
own regulations, the Joint Airworthiness Regulations (JARs), which were
in any case very similar to the US FARs.
Flight Safety Aspects of Contaminated Air
References
14. Civil Aviation Safety Authority (1999-2000) Hansard
Evidence by CASA to the Australian Senate inquiry into air safety
(1999–2000) BAe 146 cabin air quality. Parliament of Australia,
Canberra.
17. British Aerospace (2000) Hansard Evidence by
British Aerospace to the Australian Senate inquiry into air safety
(1999–2000) BAe 146 cabin air quality. Parliament of Australia,
Canberra.
22. Montgomery MR, Wier GT, Zieve FJ, Anders MW (1977)
Human intoxication following inhalation exposure to synthetic jet
lubricating oil. Clinical Toxicology 11:423–426.
24. ATSB (1999) Occurrence brief 199702276, BAe 146, VH
NJF, Fumes in cabin.
38. BAe (2000) BAe 146 Manufacturer’s Operations
Manual: Notice to Aircrew, Operational Notice: No OP 16 And 43 (Issue
1). British Aerospace Systems, Hatfield.
52. British Aerospace (1999) submission by British
Aerospace to the Australian Senate inquiry into air safety (1999- 2000)
BAe 146 cabin air quality. Parliament of Australia, Canberra.
59. SHK (1999) Report RL 2001:41e: Incident onboard
aircraft SE-DRE during flight between Stockholm and Malmö, M County,
Sweden, on 12 November 1999. Swedish Statens Haverkommission (Swedish
Board of Accident Investigation), Stockholm.
60. Senate of Australia (2000) Air Safety and Cabin Air
Quality in the BAe 146 Aircraft. Senate Rural and Regional Affairs and
Transport References Committee, Final report. Parliament of Australia,
Canberra.
61. House of Lords, Select Committee on Science &
Technology Report. Air Travel & Health, 1999-2000.
62. DOT AAIB (2004) Aircraft accident report no 1/2004
(EW/C2000/11/4) BAe 146 G-JEAK, 1/2004. UK Department of Transport,
Aircraft Air Accidents Investigation Branch, London.
63. Available at:
http://www.ainonline.com/issues/01_05/01_05_faabudget_10.html.
64. Available at:
http://www.dotars.gov.au/dept/budget/0405/d1.aspx.