Is S.1626’s Cabin Air Mandate Justified?

Cabin Air Safety Act of 2017 faa
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Cabin Air Safety Act of 2017

A Top FAA Safety Issue?

Referenced article: Cabin Air Safety Act aimed at cleaning the air in the air

The answers to the Cabin Air Quality issue are not clear. There is episodic information indicating that that it is a problem, like these:

  • January, 2017, seven flight attendants were taken to the hospital after a fume event on an American Airlines flight that landed in Orlando. According to news reports, that Airbus A330 had experienced two previous fume events before that.
  • Last week, a JetBlue plane on its way to Florida from California had to land instead in Oklahoma City due to an unknown odor that was coming from the cockpit. Ambulances met the plane and medics gave oxygen to some of the passengers who were having trouble breathing.

[Both of these examples are drawn from the linked article.]

  • Quote from a 2013 academic study: “There has been an increase in reported incidents of in-flight smoke/fume events since 1999, with a small number of crew members reporting adverse health effects which they associate with the events.”
  • And many, many more.

Then there are reports by the FAA, EASA and others, which mostly conclude that there are no quantifiable standards by which to regulate this problem:

  • EASA, an agency with a history of strong consumer protection, issued the following startling conclusion:

“A causal link between exposure to cabin/cockpit air contaminants and reported health symptoms is unlikely.”

A review of the US regulatory and Congressional controversy may help put the EASA statement in its proper context.

Cabin air quality has been a topic of confusion and concern in the aviation industry for years. Specifically, Congress, in 1984, directed research into cabin air quality, including investigation of health risks among individuals exposed to toxic fumes during flight. The results of the research were not clear.

“Common across the RFI [FAA solicited information about this subject] responses was a reference to the lack of contaminant standards for detection of cabin air contaminants. Common standards would facilitate further commercial development and implementation of advanced detection and cleaning technologies. As shown by the search summary, the occurrence of oil or hydraulic based contamination of bleed air is extremely low. In formulating the annual aviation safety research portfolio, the FAA evaluates the relative risk of aviation safety hazards and the potential for safety improvement. The FAA will continue to consider cabin safety risk and sponsor research in this area appropriate to the risk level.”

“While previous studies suggest minimal (if any) adverse health effects from cabin air exposure since the ban on smoking went into effect, we intend to continue to monitor the development of data on cabin air contamination to further ensure the health of the flying public.”

“Quantification of the potential health risks associated with exposure to bleed-air contaminants in cabin air is not possible without broad identification and measurement of the representative hazardous constituents of bleed air during contaminated air events. Such broad identification and measurement does not exist.”

faa air cabin safety studies

Unfortunately, while there are a lot of serious concerns, science has neither defined how to measure the problem, nor what a possible remedy may be.

Largely at the urging of Allied Pilots Association, the International Union of Teamsters, Association of Flight Attendants-CWA and the Association of Professional Flight Attendants (APFA), the International Association of Machinists and Aerospace Workers and others, Senator Richard Blumenthal (D-CT) along with Senators Diane Feinstein (D-CA) and Edward Markey (D-MA) have introduced the Cabin Air Safety Act. According to Runway Girl, the bill was included in the Senate version of the FAA Reauthorization bill.

Cabin Air Safety Act faa congress

Here are the primary requirements of S. 1626:

A. Training:

(1) Sources and types of smoke and fumes on board aircraft.

(2) Odor and visual descriptors to allow an individual to recognize the presence of oil and hydraulic fluid fumes and other potentially hazardous fumes, such as fumes relating to hydraulic fluid, engine exhaust, ground service vehicle exhaust, fuel, de-icing fluid, and ozone.

(3) The potential for acute or chronic impairment to an individual relating to such fumes.

(4) Procedures for recognizing and responding to smoke and fumes on board aircraft.

(5) An overview of the system for reporting incidents of smoke or fumes on board aircraft established under section 4(a)(2).

(6) Requirements relating to reporting incidents of smoke and fumes on board aircraft to the Federal Aviation Administration under sections 4 and 6(b).

B. Reporting: requires FAA to develop form and create a reporting system within 180 days of enactment.

C. Public Availability of Report: requires FAA to make the reports available on a website.

D. Investigations: would require FAA to investigate every report filed. Also mandates that both the airline management and the union participate in the process.

E. Bleed Air Monitoring Equipment: within 180 days of enactment, the FAA shall issue regulations prescribing that all airlines:

to install and operate, by not later than one year after the regulations are published in the Federal Register, a carbon monoxide detector on each bleed air stream in locations on the aircraft that include the cockpit, the cabin, crew rest areas, and each crew galley of each aircraft operated by the air carrier

(1) to continuously monitor carbon monoxide levels in the aircraft air supply system when the aircraft is in flight; and

(2) to alert the pilot and flight attendants in the event that carbon monoxide exceeds limits set forth in the national primary ambient air quality standards under section 50.8 of title 40, Code of Federal Regulations (or any corresponding similar regulation or ruling), adjusted for application at altitude.

(b) Requirement For A Pilot To Report An Alarm.—The regulations prescribed under subsection (a) shall require a pilot to submit a form through the system for reporting incidents of smoke or fumes on board aircraft established under section 4(a)(2) if the alarm in a carbon monoxide detector activates during flight.

(c) Inclusion Of Information Relating To Carbon Monoxide Detectors In Aircraft Manuals.—Not later than one year after the date of the enactment of this Act, the Administrator of the Federal Aviation Administration shall prescribe regulations requiring an aircraft manufacturer that manufactures aircraft for commercial air carriers to include procedures for responding to alarms from carbon monoxide detectors during normal and nonstandard operations in the flight operator’s manual for each such aircraft produced by the manufacturer.

(d) Continuing Research To Develop Sensors And Techniques To Monitor Bleed Air Quality.—The Federal Aviation Administration shall continue to research, study, and identify emerging technologies suitable to provide reliable warning of bleed air contamination, including through investigation and research into specific sensors, methods, and operational techniques to prevent fume events.

(e) Rule Of CONSTRUCTION.—Nothing in this section may be construed to imply that an investigation under section 5 is not necessary or that crew members and passengers have not been exposed to fumes if the alarm in a carbon monoxide detector installed on an aircraft is not activated.

Perhaps the Senators have greater knowledge than what the FAA and EASA have published. To comply with many of S. 1626, the FAA will have to complete complex research in less than 180 days. The recent previous studies have found that the metrics for measuring the air quality. Both the FAA and EASA have found that the magnitude of air quality is not significant, but the Senators have determined that fixing the air quality must be addressed within 180 days. Even the Centers for Disease Control and Prevention/The National Institute for Occupational Safety and Health (NIOSH) has found:

What is not known

We don’t know what causes most health problems that could be linked to cabin air. If you are exposed to a potential cabin air hazard and have health problems, it may not be possible to tell if it was caused by your work conditions or if it was caused by something else.

We don’t know what levels of potential hazards in cabin air are safe for every person.

A 2002 lengthy (236 pages) research study by the National Academies of Sciences, Engineering and Medicine, supported by an incredibly prestigious list of academicians in every conceivable relevant subject matter, determined:

Findings

The primary air-quality characteristics evaluated by the committee are summarized in Table S-1, which presents information on potential health effects, frequency of occurrence, and quality of the available data. The committee ranked the characteristics as of low, moderate, or high concern, on the basis of the likelihood of exposure and the potential severity of their effect. For example, hydraulic fluids or engine lubricating oils were ranked as of moderate concern because the potential severity of their effects is high but the likelihood of exposure to them at high concentrations is believed to be low. An important point to note is that the ability to evaluate a characteristic is limited in most cases because of a lack of data on exposure or health effects.

Other similar studies:

[There are many more studies on BOTH sides of the issue.]

Also, the FAA has established Fire and Cabin Safety Research Group, which includes the globe’s leading CAA’s and that group is studying cabin air quality jointly. All of these organizations share research information and all have set high priorities for addressing cabin air quality.

faa Fire and Cabin Safety Research Group

Further, a Center of Excellence was established at Auburn; called the Airliner Cabin Environment Research (ACER),this institute is in the process of studying Ozone in Passenger Cabins.

The Constitution makes it clear that the Congress’ role is to authorize programs and S. 1626 is an example of such legislation. In setting 180 day mandates for several sections of the bill. By so doing the Senators are setting priorities. To comply with this deadline, other pressing safety projects are being demeaned in comparison to cabin air quality.

The professional, scientific evidence is not conclusive that immediate actions can be initiated. The world’s CAA are already hard at work in studying this issue. The FAA has studied this issue recently and has an on-going research projects. As stated here before, this is an issue for which the FAA needs to determine the right answer.

Questions:

  • Does S.1626 merit delaying other FAA safety initiatives?
  • Or is the Congress so sure that the elements of this bill justify its elevation to the top of the FAA list?

 


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4 Comments on "Is S.1626’s Cabin Air Mandate Justified?"

  1. Richard M Isbell | August 14, 2017 at 1:05 pm | Reply

    well, at least the 787 would be exempt as it it doesn’t use bleed air for pressurization.

  2. Sandy Murdock | August 14, 2017 at 1:10 pm | Reply

    Mr. Isbell– excellent point. Thank you

  3. it has been a hard fact that the air on aircrafts is most likely contaminated and poisoned with oil fumes !

  4. Sandy Murdock | October 7, 2017 at 2:26 pm | Reply

    Karolin, thanks for your opinion. I hope that you read the scientific studies mentioned in the article. Those experts seem to disagree with your “hard facts”.

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