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Exposure to Contaminated Air on Aircraft and Pilot Health

 
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PostPosted: Mon Aug 25, 2008 3:07 am    Post subject: Exposure to Contaminated Air on Aircraft and Pilot Health Reply with quote

CRITIQUE OF THE UK COMMITTEE ON TOXICITY
REPORT ON EXPOSURE TO OIL CONTAMINATED AIR
ON COMMERCIAL AIRCAFT AND PILOT ILL HEALTH

Captain Susan Michaelis: GCAQE researcher
Professor Chris Winder: Professor of Applied Toxicology, UNSW
Professor (Emiterius) Malcolm Hooper: Medicinal Chemistry: University of Sunderland
Dr Andrew Harper: Occupational and Public Health Physician, Perth, Australia

Report prepared for: Christopher Witkowski: AFA-CWA

May 2008

Correspondence to: susan@susanmichaelis.com

INTRODUCTION AND SUMMARY

On 21 September 2007, the UK Committee on Toxicity of Chemicals in Food, Consumer
Products, and the Environment (COT) issued a report titled: “Statement of the review of
the cabin air environment, ill health in aircraft crews, and the possible relationship
between smoke/fume events in aircraft” (COT, 2007).

What follows is a review of the COT report, with a brief description of the inaccuracies
and the facts. The global nature of the airline industry means that the negative
implications of the COT report may influence crewmembers around the world, so it is
important that any errors and misstatements in the report be corrected on the record. It
should also be noted that, despite its imperfections, the COT committee estimates that
smoke/fume events are reported by pilots on one in every 100 flights (this would translate
into 289 events on the US fleet daily), notes that oil should be prevented from
contaminating the air supply, and calls for a wide-scale sampling survey. Crewmember
organizations must be also be aware of these facts.

BACKGROUND

In 2000, a UK House of Lords committee issued a report on commercial air travel and
health. The report reviewed elements such as radiation, cabin pressure, ventilation, and
“cabin atmosphere contamination” (HOL, 2000). On the subject of oil contamination of
the air supply, the report repeatedly noted assurances from Boeing, Airbus, and Rolls
Royce that ambient levels of contaminants in the cabin and flight deck are well below
levels associated with ill health. The report presented the information provided by
industry partners as fact, despite the obvious conflicts-of-interest. For an official report, it
was surprisingly full of errors.

Four years later, the British Airline Pilots’ Association BALPA (Labor union representing 8.000 pilots at airlines in the United Kingdom) formally outlined its
concerns about oil contaminated air supply on commercial aircraft to the UK Department
for Transport (DfT), asking for an investigation into reports of compromised aviation
safety and crew ill health following exposure to oil fumes in the flight deck. BALPA had
collected more than 800 incident reports from its members over a 21 year period (with the majority reported over a six year period) and had amassed references and incident
reports from around the world. In response, the DfT instructed the COT to conduct the
investigation.

The COT initiated its investigation in 2005. Specifically, COT was tasked with reviewing
the issue of ill health in aircraft crews and the possible relationship to smoke/fume events
in aircraft. Throughout the process, pilots raised concerns about the transparency and
fairness of the process: for example, “public meetings” were not public and requests from
crewmembers with expertise on the subject to present data at the meetings were largely
denied. The COT progress reports published as annexes between mid 2006 and July 2007
were full of errors and misleading statements.

In September 2007, the COT issued its long-awaited report (COT, 2007). The committee
concluded that it had insufficient information to conclude whether a causal association
exists between cabin air exposures and ill health among flight crew (Para. 51). The COT
dismissed the available data as “anecdotal and descriptive” (Para. 51), claiming that the
data do not meet the standard of an epidemiologic study, without acknowledging that it
has not been possible to conduct a large-scale epidemiologic study because of a lack of
funding and an unwillingness on the part of airlines to participate. The COT report
dismissed the documentation from physicians, industry partners, occupational health
specialists, engineers, and crewmembers that support a causal association between
exposure and illness, suggesting that 100% proof is required before it can protect public
safety and occupational health.

Like the annexes that preceded it, the final COT report was full of errors and misleading
statements on the toxins of concern, the available sampling data, the extent and nature of
underreporting, the reliability of available incident reports, and the symptoms reported by
airline pilots. Many of the errors in the COT report could have been corrected had the
committee made more of an effort to contact more individuals with relevant expertise but
without financial ties to the aviation industry. For example, COT claimed to have
contacted academics and physicians who presented relevant data at a conference hosted
by BALPA on air safety and cabin air quality [International Aero Industry Conference “Contaminated Air Protection: Air Safety and Cabin Air Quality”
Held at Imperial College London, 20-21 April 2005. Sponsored by BALPA, the Pall Corporation,
Sofrance,and AOPIS. Proceedings published by the School of Safety Science, University of New South
Wales, Australia.
], but reported that it had received no
response (Para. 13). However, seven of those academics and physicians were not
contacted and the three experts who participated in the BALPA conference and did
contact the COT were ignored. Despite the errors, the COT did call for the prevention
(Para. 28 ) and study (Para. 69) of incidents of oil contaminated supply air. What follows
is a detailed assessment of the report, including the conclusions and recommendations.

DETAILED CRITIQUE OF REPORT

1) Toxins of concern

As background, US manufacturers of aircraft engine oils all confirm that their products
contain 1-5% tricresylphosphates (TCPs), used largely for their anti-wear properties
(Exxon-Mobil, 2008; BP, 2005). There are ten different forms of TCPs – each is
comprised of the same molecules, but they are connected together slightly differently.
These structural differences are important because they can influence toxicity. Six of the TCP “isomers” contain “ortho” chemical bonds. Of these, “tri-ortho cresyl phosphate”
(TOCP) has historically been identified as the most toxic TCP isomer, likely because of
its highly publicized involvement in some epidemics of tainted cooking oil and bootleg
alcohol in the early 20th century that caused widespread paralysis and peripheral nerve
damage (Morgan, 1978). However, it has long been recognized that TOCP is not the most
toxic TCP isomer. In fact, the other five ortho isomers are characterized as up to ten times
more toxic than TOCP (Hanhela, 2005; Mackerer, 1999; Henschler, 1958). Most
published toxicity studies for aviation engine oils are conducted by oil manufacturers
with a financial stake in the outcome and are designed with test animals either drinking
the oil or absorbing it through their skin. Then, objective measures of damage to the
peripheral nervous system such as gait problems, weakness, tingling, numbness, and
tremors, are assessed (Craig, 1999; Weiner, 1999; Daughtrey, 1996). However, inhalation
is the primary route of exposure to engine oil in the aircraft cabin and flight deck, and the
primary symptoms that crew report indicate damage to the central nervous system such as
headache, impaired concentration, impaired memory, difficulty multi-tasking, and slowed
mental functioning (AAIB, 2007; Singh, 2005; Michaelis, 2003; Cox, 2002; Coxon,
2002; Winder, 2002; SHK, 2001; PCA, 2000; van Netten, 1998; Rayman, 1983;
Montgomery, 1977). Exposure to TCPs in engine oils may explain these symptoms
because they have been observed after low-level or repeated exposure to other
organophosphates (Abou-Donia, 2003; Abou-Donia, 2005; Jamal,2002).
Likely, TCPs are not acting in isolation. The inhalation toxicities of aviation engine oils
and of each of the ten TCP isomers – including the four “meta” and ”para” isomers of
TCP that dominate commercial oil formulations - still need to be tested.

The COT report describes “an overemphasis on the potential involvement of
organophosphorus compounds on the ill health of airline pilots…that drew attention away
from other potential causes” (Para. 68 ). Tricresyl phosphate additives are known to be
present in engine oils and many crewmembers are reporting ill health consistent with
exposure to such toxins. However, we are not aware of any investigation that claims
TCPs are the only chemical toxin responsible for the reported symptoms. Many reports
raise concerns about TCPs in the context of other exposures including the many other
component of oil fumes (Winder, 2006; Bobb, 2003; TOX/2006/39, Annex 11; van
Netten, 2000), the potential presence of carbon monoxide (CO) (Winder, 2006, Bobb,
2003; van Netten, 2000), in addition to the reduced pressure environment and the
potential presence of other toxins such as insecticides, exhaust fumes, disinfectants,
ozone, and deicing fluids (Murawski, 2005).

The COT noted uncertainty that exposures to CO may explain or contribute to
neuropsychological deficits reported by crewmembers (Para. 60). Certainly, CO
generation is temperature dependent and if the temperature in an oil-contaminated
engine/APU is not high enough then carbon monoxide may not be present. However, CO
was identified when oils were heated under test conditions intended to simulate the
aircraft engine (van Netten, 2000). Unpublished CO data sampling collected by
commercial pilots on BAe146 aircraft identified CO on 81% of 345 flight segments, with
39% recording above 9 ppm and a peak value of 72 ppm (GCAQE, 2004). Neurological
symptoms are commonly associated with exposure to CO, of course varying with the
exposure level. When CO is present, however, the effect of exposure will clearly be
magnified in a reduced oxygen environment. We dispute the COT claim that the reduced
oxygen pressure at 8000 feet would not modify the potential effects of carbon monoxide”
(Para. 60), based on the opinion of their “independent expert”, the long-time, former
Medical Director of British Airways (TOX/2007/20, Annex 3). Breathing air with 50 ppm CO at a cabin altitude of 6,000 feet has been defined as physiologically equivalent to
a cabin altitude of 12,000 feet (USAF, 1992), a condition that would easily require a pilot
to have donned his or her oxygen mask. Similarly, breathing air with 150 ppm CO at a
cabin altitude of 8,000 feet has been defined as effectively raising the cabin altitude to
19,000 feet (McFarland, 1971). Elevated physical activity (relevant to cabin staff),
cardiopulmonary disease, advanced age, and being a smoker can magnify this effect. For
example, a recent study predicted that a “substantial proportion” of passengers with
normal pulmonary health over the age of 65 will have arterial oxygenation below the
threshold at which supplemental oxygen is recommended even at an 8000 feet cabin
altitude (Muhm, 2004). In addition, smoking 1.5 packs per day can raise a person’s
carboxyhemoglobin to 10%, and the elevated carboxyhemoglobin does not disappear
immediately when the cigarette is extinguished; rather it drops off at a rate of about 50%
every four hours (USAH, 2000). This altitude effect has not been tested for other airborne
contaminants or for mixtures of contaminants, although crewmembers will never be
exposed to CO in isolation.

Finally, the COT noted exposure to “potential irritants” during a fume event (Para. 28 )
but appeared to ignore the evidence on exposure to neurotoxins (TCPs and
triphenylphosphates), sensitizers (N-phenyl-L-naphthylamine, PAN), and asphyxiants
(carbon monoxide), with no mention of the potential impact of exposure to the mixture of
these and other chemicals in a reduced pressure environment. This, despite the fact that
neurological symptoms have been reported by crewmembers over the past thirty years


(AAIB, 2007; Singh, 2005; Michaelis, 2003; Cox, 2002; Coxon, 2002; Winder et al.,
2002; SHK, 2001; PCA, 2000; van Netten, 1998; Rayman, 1983; Montgomery, 1977)
and pyrolysis studies have confirmed the presence of these toxins when commercial oils
are heated (van Netten, 2000; Marshman, 2001; Fox, 2001). Even the Material Safety
Data Sheet for these engine oils acknowledge the TCP content and the fact that “toxic
fumes may be evolved on burning or exposure to heat” (BP, 2001).

2) Available sampling data

In its report, the COT stated that TCPs had only been identified on one military aircraft
and that there were no sampling data from commercial aircraft (Para. 7(b)). However,
there are four published reports identifying TCPs in the passenger cabin (CAA, 2004;
Honeywell, 2000a; Honeywell, 2000b; PCA, 2000) and at least two published
investigations on military aircraft (Hanhela, 2005; Kelso, 1988). In addition, a Canadian
toxicologist had notified COT members of TCP wipe sampling data collected on
commercial aircraft from 2005-2006 (van Netten, 2006) but the COT apparently chose to
disregard this report. Also, tributylphosphates have been detected on commercial aircraft
both before (Fox, 1997) and after (Muir, 2008) the COT report was published.

The COT report did acknowledge oil pyrolysis studies conducted by Shell, Honeywell,
the Society of Automotive Engineers, and an engine manufacturer (TOX/2006/39,
Annexes 10, 11, 12) but incorrectly stated that the “ortho isomer of TCP had not been
identified” (Para 29). First, there are six ortho isomers, not one. Second, a review of the
Honeywell data (the only pyrolysis study that was available on the COT website, so the
only one we can comment on) confirmed that five of the six ortho isomers were present
(TOX/2006/39, Annex 11). TCPs (including ortho isomers) were also identified in the
flight decks of military aircraft (Hanhela, 2005). Further, in 1999, there was a confirmed
incident of oil supply contamination on a commercial flight during which the captain was
incapacitated (ACARM, 2007a; SHK, 2001). Honeywell conducted air quality tests on the air supplied from the defective engine mounted on a test rig (Honeywell, 2000a) and a
new engine installed on the aircraft in the incident (Honeywell, 2000b). The COT states
that the “ortho isomer of tricresyl phosphate was not detected” in the latter test (Para. 34)
but again, there are six ortho isomers of TCP, not one, and in both tests, TCP isomers
were identified, along with triphenyl phosphate and a “hydrocarbon matrix…representing
a broad mix of very heavy tar like coeluting compounds” (TOX/2006/39, Annex 11).
Finally, when aviation engine oils were heated under conditions intended to simulate an
operating aircraft engine, five of ten TCP isomers were identified (van Netten, 2000), so
at least one and as many as all five would have been ortho isomers.

3) Extent of underreporting

The COT noted a total of 770 incident reports from BALPA members collected during a
21 year period (1985-2006), with most being reported after 1999 (Para. 47). The report
compared these reports to Mandatory Occurrence Reports (MORs) reported to the UK
Civil Aviation Authority (CAA) from 2001-2006. The COT concluded that it was not
possible to estimate the extent of underreporting, but that “objective monitoring of
exposure and health would be a priority for the future” (Para. 49).

The COT failed to note that crews are not required to report to BALPA.

The COT report claims that pilots do not have to record contaminated air events in the
tech log/pilot log book, so “this system may not record all events” (Para. 44). In fact,
pilots are required to report all defects/mechanical irregularities noted during flight, but
the regulations are not being met. It is true, however, that events are underreported in the
tech log/pilot log book, such that this source will not capture all events.

The COT reports that UK pilots do not have to file an “Aviation Safety Report” (ASR)
with their airline following a fume event, but that if they do, the airline may forward the
ASR to the UK Civil Aviation Authority (CAA) as a “Mandatory Occurrence Report” if
the airline or the pilot deems it serious enough, adding that “cabin fume events are most
likely not reach the threshold for a MOR” (Para. 45). However, according to the CAA,
“smoke, toxic, or noxious fumes” as well as “use of emergency oxygen” are all reportable
occurrences per the MOR system, and the CAA requires the use of emergency oxygen
during a fume event (FODCOMS 21/2002, 14/2001, 17/2000).

The COT estimated that pilots report smoke/fume events on 1% of flights and that
maintenance staff confirm fume events on 0.05% of flights (Para. 69). Both estimates are
based on events at three UK airlines, with the engineering investigations only including
confirmed ASR reports. The estimates must be interpreted through the lens of an aviation
culture that sees smoke/fumes as a “nuisance” (BAe Systems, 2001a) and expects
transient exposures during engine acceleration, deceleration, or warm up (BAe Systems,
2001b); an industry that has acknowledged widespread and documented underreporting
to both airlines and regulators (ACARM 2007b; FAA, 2006; Singh, 2004; Rayman,
1983). Even so, applying these estimates to the US fleet translates into a daily average of
289 events identified by pilots and 14 events confirmed by maintenance staff.The
problems of maintenance staf failing to identify fume events is well documented
(ACARM 2007).


4) Reliability of available incident reports

COT reported that BALPA was unable to distinguish between reports generated by odors
of oil in the air supply system and galley/toilet smells. However, in its submission,
BALPA made it clear that only smoke/fume events were included in its database and that
reports of toilet/galley smells were excluded (TOX/2006/39, Annex 2, Para. 6). It is
irresponsible to disregard reports of oil fumes that may threaten occupant health and
flight safety as “galley/toilet smells.” Numerous industry sources have explicitly
associated odors with oil leaking into the air supply through thermally degraded seals or
other defective air supply system components (Ansett, 2000; Ansett, 1998; National Jet,
1998; Rolls Royce, 1990), as have regulators (AAIB, 2004; CAA, 2004), technical
associations (SAE, 2007), researchers (Hanhela, 2005; Montgomery, 1977) and airlines
(Murawski, 2008). Clearly, pyrolyzed oil is generating oil odors in the cabin and flight
deck. However, crewmembers should not have to rely on their noses, and proper sensing
equipment should be installed.

5) Assessment of symptoms reported by pilots

COT reviewed the symptoms reported to the BALPA database, airlines ASR reports, and
the CAA’s MOR scheme (2001-2006). Committee members concluded that most of the
reported symptoms were non-specific, acute in nature, and “common in healthy
individuals” (Para. 56). The COT failed to note that incident reports are completed at the
time of the event and do not require follow up, such that chronic symptoms would not be
identified. Also, the “common in healthy individuals” observation appears at odds with
the fact that in 32% of the smoke/fume event reports submitted to BALPA, crews noted
some form of impairment, and in 9% of events, both pilots reported impairment.

Regarding the investigation into neuropsychological deficits reported by a sample of
pilots, the COT reported that, while the evidence of neuropsychological impairment
among pilots “was not consistent , “the potential for cognitive deficits needs further
consideration” (Para. 67). However, the expert that submitted the pilot’s health data noted
that “the pattern of deficits observed in each pilot are similar and consistent” and
“resembles those found in the literature on exposure to organophosphates and solvents”
(Mackenzie Ross, 2006). Another neuropsychological investigation of airline pilots
reporting fume events reported similar results (Coxon, 2002).

6) Comment on COT recommendation for future research

Despite its claims that there is insufficient evidence to support a causal relationship
between exposure to oil contaminated air and pilot ill health, the COT concluded that the
it would be prudent to prevent exposure to oil contaminated air (Para. 28 ), presumably
based on the precautionary principle, and noted that that since “an association is
plausible…consideration should be given to further research” (Para. 74) Specifically, the
committee called for monitoring on 10,000 to 15,000 flight segments to characterize the
nature and concentration of individual airborne chemical contaminants both under
“normal” conditions and during fume events (Para. 69).

We fully support a large scale sampling study, but emphasize that it must be conducted
by researchers without any financial ties to the aviation industry who inspire the trust and
confidence of qualified crewmember representatives. Also, we are concerned that the study proposed by the COT almost seems to have been designed to minimize the chance
of identifying any problems:

• We recommend against the proposed collection of time-weighted average (TWA)
exposure sampling data collected over the duration of a flight (TOX/2006/39,
Annex 15, Para. 37). Specifically, fume events are generally considered to be
transient so peak and short-term exposure data are the endpoints of interest, not
longer-term TWA data that will dilute any findings.

• The proposed SPME technology will not capture particulates.

• The COT proposed CO as one indicator of a fume event (Para. 72). We caution
that CO not be used as an indicator of a bleed event alone because formation of
CO is temperature-dependent and there may be oil contamination in the air supply
without the oil being heated to the temperatures necessary to form CO.

• Any sampling results must be carefully interpreted in the content of possible
synergistic effects, repeated exposures (especially for crewmembers), shift/flight
durations beyond typical eight hour industrial exposure profiles, reduced cabin
pressure, and not simply compared to ground-based industrial standards that do
not apply to aviation (Singh, 2004; Rayman, 2002).

• We recommend against the COT relying on ASR reports to accompany flight-
long sampling data (Para. 76). We acknowledge that the ASR system is familiar
to pilots (Para. 76), but it is underused for fume events and it is not intended as a
health surveillance tool.

CONCLUSION

This critique of the 2007 COT review on the suggested relationship between pilot ill
health and exposure to oil fumes found many errors and misleading statements, as
described. We call on UK regulators and researchers who may rely on the COT findings
to reconsider the facts as outlined here and to proceed with a carefully designed sampling
strategy that is honestly intended to assess the health impact of exposure to oil fumes.

POSTSCRIPT

Three months after the publication of the COT report, the UK House of Lords published a
follow up to their 2000 report (HOL, 2007). The following month, researchers
commissioned by the DfT published its results of inflight air sampling (Muir, 2008).
These reports will be described separately.

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