Select Committee on Science and Technology Written Evidence

Memorandum by the British Airline Pilots Association (BALPA)'s Occupational Health & Safety Group


  The BALPA Occupational Health & Safety Group is a specialist focus group within the Association, whose remit is to deliver Health & Safety guidance and improvements for members, to train and support its Health & Safety Representatives, and to represent the occupational health & safety interests of its pilot and flight engineer members. This currently represents some 10,000 flight crew members in the UK.

  The BALPA Occupational Health & Safety Group consists of current operational pilots who have received training in accordance with accredited standards, including some holding post-graduate level qualifications in Occupational Health & Safety Management and membership of the Institute of Occupational Safety & Health (IOSH) Aviation Specialist Group Committee. The Group meets regularly with Airlines and Regulators—both the Civil Aviation Authority and Health & Safety Executive—in a variety of forums.


  The identification, management and communication of health risks in air travel are of paramount importance and have are in significant need of further funding and a renewed stakeholder commitment, if the industry is to demonstrate that it regularly achieves what could be deemed best practice. It is very much our belief that such funding and investment must also provide for varied research projects into the various aspects of air travel on a cross-industry basis which includes all stakeholders and that a new culture of openness and sharing of health information is needed to provide that which an increasingly interested public expects.

  We agree with the Committee's comments in Para 1.8 that health has been "woefully neglected", and in particular we wish to record our concerns regarding the trends in increasing risk and pressure suffered by flight crews due to lengthening duty periods as a result of increasing delays, allied to ever reducing rest periods between flight sequences in airline efficiency drives, whilst still attempting to maintain the highest of standards in ever more densely crowded skies. There is a need for a review of the fundamental applications of crew fatigue and stress management standards being applied to flight crew—for too long the perception that pilots are able to cope with all forms of adversity has been an accepted industry norm—and this culture needs to change. It is a culture which promotes acceptance of excesses of stress, and re-enforces a lack of fatigue reporting through concerns over job-security.

  Quite rightly over the last half-century, the aviation industry has focused its efforts on the primary provision of flight-safety, but this now needs to be augmented with a new determination to govern and protect the health and safety of the individual crew members who have provided this given.

  BALPA Occupational Health & Safety Group fully supports the recommendation of Para 1.9 and we endorse the view that the Government actively promote both the health of crews and passengers, as a specific goal in the immediate future.

  We also recognise the inertia referred to in Para 1.10 of the safety focused regulatory structures and recommends that the widespread knowledge available through bodies such as IOSH be fully utilised and integrated into new health & safety related management structures which now apply to aviation. The funding levels of the HSE and CAA SRG by Government are something which we believe needs urgent attention, with a significant injection of investment into each—to be ring-fenced specifically for health related issues.


  With regard to Para 1.11—the European Working Time Directive in 2006, was the instrument responsible for the extension of UK Health & Safety Legislation (HASAWA 1974 etc.) to mobile transport workers, and until the implementation of this Directive under the Civil Aviation Working Time Regulations, flight crew had no recourse to Health & Safety legislation. In response to this, BALPA established its Occupational Health & Safety Group in November 2005, to provide both a service to its members and a focus point for engagement with other parties with an interest in the subject, including the relevant governmental and regulatory bodies, employers and fellow Trade Unions. The Group meets on a monthly basis establishing policy, setting goals, monitoring trends and to supply training.

  BALPA now has qualified H&S Representatives across a broad spread of UK airlines. The training of new volunteer reps and the ongoing professional development of existing Reps and members continues apace. However, the release of pilot H&S Representative volunteers to complete their training and to carry out their activities by some airlines—is a problematic issue. Some airlines still refuse release for these activities.

  Our belief is that this is partly due to resistance on the part of some airlines to accept that H&S legislation be applied equally to pilots as it is to ground based workers. Indeed, we find that we are often frustrated by the disapplication of certain specific legislation to flight decks—for example the Display Screen Regulations. The whole is far from satisfactory at present, leading to both delays and difficulties in the application of health and safety standards enjoyed by ground based staff.


  We support and are pleased to see that the Committee accept that DVT is an issue which is not solely confined to air travel. We believe that the additional risks in air travel only augment the overall risk of a DVT development in a minor manner and that the Department of Health, CAA and AOA should provide clearer, more uniform advice covering all forms of travel.

  With regard to the taking of health providing exercise on aircraft, we wish to record that the necessary locking of the flight deck door system post the 9/11 events, has led to a culture of pilots being stuck in a confined area with little opportunity to stretch and move the legs for significant periods of time. This may have longer term health implications.


  BALPA's Occupational Health & Safety Group see no sensible reason for not adopting the JAA requirement for a fresh air only supply to the flight deck, and to this extent are at odds with the recommendation of the Committee. The pilots are the two singularly most expensive pieces of flight safety equipment on board and we believe that this status deserves recognition and that includes the provision of a fresh air supply. There may be other security related issues which further re-enforce this opinion. We do not concern ourselves with the view in some circles that this would imply that re—circulated cabin air is intrinsically bad, but add that scientific evidence suggests that on the whole cabin air is normally of acceptable quality—with occasional acute exceptions.

  The Committee is no doubt aware that BALPA along with DfT and several other key industry stakeholders are undertaking joint research into cabin air quality to establish further scientific facts.


  We believe that the EU smoking ban in confined spaces from July 2007 be applied to all aircraft cabins operating within the boundaries of UK territorial airspace. We fully support no smoking legislation.


  BALPA Occupational Health & Safety Group fully endorses the Committees recommendation regarding air filtration, and we urge all airlines to adopt a positive and pro-active stance towards HEPA filtration and accept that any improvements in filtration are cost-effective in terms of crew and passenger health.


  BALPA continues to press for further flight deck noise research and for airlines to be responsible for providing adequate hearing protection for flight crew—both whilst in the aircraft and whilst exposed to noise hazards when carrying out external duties on the ground. Noise levels at the ear should be controllable to levels as defined under the Control of Noise at Work Regulations 2005. Noise induced hearing loss is both permanent and prevalent in the industry yet protection is easily affordable. Sadly, we note that few UK airlines provide legally adequate levels of information, instruction and training along with personal protection equipment for pilots to be able to protect their hearing—which can lead to a loss of flying licence and hence career due to health failings.

  Whilst the causes of in-flight noise may be costly to rectify, the cost of suitable protection is reasonable and we continue to press all UK airlines to put into place adequate noise control programs for flight crew including the provision of suitable training.


  With regard to stress our principle concern is to record the increasing levels of work-related stress felt by our members, with empirical evidence suggesting that rates of increase in stress are rising year on year. In our unique role the committee should appreciate that our stress is augmented by constant jet-lag and fatigue and that the industry poorly supports the health issues surrounding this situation.

  The Occupational Health Group at BALPA would like to see a review of flight crew scheduling and rest limitations to introduce systems which support more suitable rest breaks between flights and thus help to reduce chronic fatigue prevalence towards the latter stages of many long-haul flights. Additionally, we recognise that increasingly hectic short-haul work patterns for crews add to fatigue levels in a very stressful environment, and ask that this Committee recognise the need for research and serious review of planned rest patterns. Fatigue is cumulative, but our rostering systems assume that the tiredness counter in each pilot is reset to zero on the first day of each month and take no account of the previous months experiences. This is a potential flight safety hazard which needs a fresh approach.

  More effort has to be placed through regulators into re-aligning crew rest periods with a proper regard to fatigue of crews during subsequent flights. We support more research in this area.


  This report, has quite surprisingly, made no reference to the effects of cosmic radiation exposure of flight crews. Whilst much research has been conducted we feel that more is required. Indeed to this extent we have developed a methodology for an epidemiological study into flight crew schedules and exposure on various types of long-haul aircraft. Our concern is that the latest generation of ultra-long haul aircraft are able to climb shortly after take-off to high cruise altitudes and remain at high altitudes for considerably longer than older aircraft types on whose performance much data is based.

  This allied to a trend towards increasing annual flying hours amongst long-haul crews is of concern to us. We wish to see the DfT to sponsor a major new research effort into this field.

June 2007

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