Contaminated Aircraft Air and CAA Safety
Source: Aviation Contaminated Air Reference Manual
CAA View of its Safety Responsibilities is Wrong © 10th April 2008 by Susan Michaelis Clearly the CAA’s view of what it is responsible for or what is deemed a safety matter is incorrect. This can be seen in several ways. This incorrect interpretation must be reviewed as the CAA is incorrectly advising many events are not safety related.
In 2003, the CAA advised that it classified contaminated air event impact on crews as shown below under "CAA Classification of Contaminated Air Event Impact"
The CAA clearly views extraordinarily that a pilot experiencing headaches, nausea, eye, nose and throat irritation while operating the aircraft can experience such adverse effects with no degradation of efficiency whatsoever.
CAA Classification of Contaminated Air Event Impact [92][93]
Incapacitation – Unable to perform any duties
Partial Incapacitation – Able to perform duties but with great difficultyNOTE: PRIMARY SAFETY FOCUS IS ON EVENTS FALLING INTO ABOVE
Impairment – Able to perform duties with some difficulty and/or minor mistakes made
Partial impairment – Able to perform duties with little difficulty but with reduced efficiencyNOTE: SAFETY FOCUS IS CONCENTRATED ON EVENTS FALLING INTO ABOVE
Feeling unwell but no impairment – (e.g. headaches, nausea)
Irritation but no impairment – (e.g. eyes, nose, throat)This is at complete odds with common sense, as well as the Australian Civil Aviation Safety Authority regulations which clearly state:
CAR 6.16A - (1) Holder of a medical certificate; impaired efficiency due illness - The holder of a medical certificate must not do an act authorised by the flight crew licence… to which the certificate relates while his or her ability to do the act efficiently is, or is likely to be, impaired to any extent by an illness or injury, no matter how minor.
CAO 48.0. 1.4 Flight time limitations - A flight crew member shall not fly, and an operator shall not require that person to fly if either the flight crew member is suffering from, or considering the circumstances of the particular flight to be undertaken, is likely to suffer from, fatigue or illness which may effect judgment or performance to the extent that safety may be impaired.
CAR 256 (2) Intoxicated persons not to act as pilots etc. or be carried on aircraft - A person acting as a member of the operating crew of an aircraft ... shall not, while so acting... be in a state in which, by reason of his/her having consumed, used or absorbed any alcoholic liquor, drug, pharmaceutical or medicinal preparation or other substance, his/her capacity so to act is impaired.
Dr David Newman, an Australian and holder of a Diploma of Aviation Medicine from the Royal College of Physicians, London, is a former chief instructor at the Australian RAAF Institute of Aviation Medicine and a consultant in aviation medicine to CASA. Dr Newman clearly states that no level of adverse effects is acceptable when he stated:
‘It makes good sense to only fly when you are fully fit… The common cold, like most other illnesses, makes you feel fatigued and generally unwell. Even a simple headache can be a distraction, and if it is a migraine headache it can be incapacitating. Attempting to deal with in-flight problems (aircraft emergency, deteriorating weather) while suffering from a headache is likely to be a hindrance at the very least, and may well make the headache worse.’ [94]
Clearly a headache, feeling of fatigue or generally feeling unwell from an outside source or aircraft contaminated air is advised as unacceptable.
In 2006, the UK Independent Pilots Association (IPA) advised the Chairman of the CAA, Sir Roy McNulty that it was surprised that the CAA decided to, ‘pass off many events as ‘low level.’ An interesting conclusion given that aircraft do not have detection systems for contaminated air or any form of contaminated air measuring systems.’ [95]
The IPA also stated:
‘The CAA is negligent in claiming such events are ‘low level’ or ‘not safety related’ and not worthy of their attention.’ [95]
Sir Roy McNulty of the CAA swiftly replied. His reply included the following three comments: [96]
‘We do not agree with your views, nor with your contention that there are serious flight safety issues… this is simply not true.’
‘The CAA safety focus is on contamination events that may be associated with engine oil where the pilots experienced symptoms that may have impaired their performance… The matter of assessing reports on subjective and inconclusive comment is, of course challenging and certainly not as simple as supposed within the recent debate. Nevertheless, the inclusion within the database of ‘lesser events’ would not have advanced the airworthiness and operational actions that continue to be undertaken. Nor do such reports provide the evidence base of the cause and effect that is necessary to deliver understanding of the nature and scope of any health threat.’
‘Symptoms that might adversely impact on the safe conduct of any flight, irrespective of their cause, would be a primary focus for our Safety Regulation Group.’
The CAA has stood by its view that that there is no evidence of under reporting and that the current reporting system appeared to be satisfactory. [88] When questioned by the IPA in 2006 about the apparent CAA continued inadequate actions regarding contaminated air events, the CAA responded by stating that these views were expressed by those, ‘demonstrating a substantial lack of understanding and appreciation of the strong safety culture that exists within the UK aviation community and how that commitment underpins UK’s excellent safety record.’ [96]
These views are supported by the UK Government and CAA additional statements including:
‘Since all UK aircrew take aviation safety very seriously, there is no reason to believe that they would deliberately under report occurrences involving impairment.’ [97]
‘The pilot community is highly professional and respected body and each individual has both a personal interest and an operational ‘duty of care’ to achieve the safe operation of their aircraft and the well being of everyone on board.’ [96]
Flight Safety Aspects of Contaminated Air
Reporting Contaminated Air Events with Samples of Known Events
FODCOM (Flight Operations Department Communication) number 17/2000
FODCOM (Flight Operations Department Communication) number 14/2001 and 21/2002
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References
88. CAA: Tom Hamilton, SRG: Minutes of the AHWG meeting 27 October 2004. Available at: http://www.dft.gov.uk/stellent/groups/dft_aviation/documents/page/dft_aviation_612241.hcsp.
92. CAA presentation by S. James, SRG BRE Cabin Air Conference September 2003. Flight deck occurrences from MORs.
93. Letter from Lord Davies of Oldham to Lord Tyler, 30 March 2006. Available at www.aopis.org.
94. Dr. David Newman. Fit to fly? CASA Flight Safety Australia, November-December 1999.
95. Independent Pilots Association (IPA) letter to CAA Chairman, Sir Roy McNulty. 12 May 2006. Available at www.aopis.org.
96. CAA Chairman’s letter to Independent Pilots Association (IPA). June 2006.
97. Countess of Mar. Question in the UK House of Lords. Question number: HL 1779 October 2005.
