GCAQE response to ANEC - May 2021
Stephen Russell
Secretary-General
ANEC
Rue d’Arlon 80
B-1040
Brussels
Belgium
11 May 2021
Dear Secretary-General Russell,
We have read your letter dated 18 March 2021 that you sent to CEN regarding the prEN 17436 cabin
air quality draft standard that is currently out for a second public inquiry.
On behalf of the Global Cabin Air Quality Executive (GCAQE), I wish to express our strong opposition to the ANEC position that you have highlighted in the above letter and additionally in an email that you have sent out on Friday 7 May to your network.
We believe ANEC is not providing accurate information to the consumer organisations within Europe
on this subject. We understand that ANEC is calling for the use of threshold limits, clear pass/fail criteria on a wider subset of individual substances, which in your opinion would enable the requirements to be verifiable.
While ANEC clearly has expertise in relevant areas, we do not believe your competency extends to the aircraft cabin air environment. We have worked with independent scientists over several decades and it is very clear that your position if applied, would be neither protective or helpful to aircrew or passengers. We have indeed mentioned this to you and your team on several previous occasions.
We also note your belief that EASA will present the missing scientific data in the future. However, the initial EU funded EASA FACTS cabin air quality project which lasted for 3 years (2017-2020) was not completed with no final report published. The GCAQE and numerous experts advised EASA and DG MOVE in 2016 that the wrong questions were being asked and raised this with the EU Ombudsman’s office. Despite this, a second EU funded (1.5 million euro) study has recently been initiated and it appears that again they are not asking the right questions.
We do not believe that ANEC has taken into account the unique environment of the aircraft cabin and what has actually been documented over many many years. A few points to note include:
• The use of exposure and threshold limits or pass/fail criteria cannot be applied to the aircraft cabin environment.[1] This has been repeatedly been addressed in the scientific literature. Many substances do not have such threshold limits, including one of the main substances in the engine oils. The reliance on individual substance thresholds will “do absolutely nothing to address health problems that aircrew and frequent flyers suffer from.” [2] We have reviewed the available cabin air monitoring data and in not one case have the individual substances breached the individual thresholds, where they actually exist. Despite this we see impairment, incapacitation and ill health occurring globally. [3]
• Based on our research, supported by the pattern seen over many decades, exposure to cabin air contamination is not about acute exposure events to individual substances. The cabin environment is primarily about repeat background exposure to a low-level complex mixture, along with less frequent acute events. This has clearly been identified in our various papers.
• The previous EN 4618 and prEN 4666 standards were withdrawn in around 2013, for precisely the reasons that OELs and similar thresholds were not suitable for this exact environment. It would therefore appear that ANEC is trying to defend the case to use threshold limits, when they were clearly rejected 8 years ago, for the same reasons they were rejected by TC436 again this time around.
While you may do good work elsewhere, on this topic ANEC has not taken the correct or appropriate approach. You may like to review the attached methodology document that the GCAQE prepared and provided to TC 436 back in 2015. This clearly showed what should be done with regard to cabin air contamination. However as stated above, the EASA approach has not and will not provide the answers required to protect workers and consumers.
We note however, that you are extremely critical of the UK based consumer representative Frank
Brehany. In fact, Mr Brehany has been exceedingly active on this topic, has taken the correct approach to actually help protect consumers, being the travelling public and has the complete support of the GCAQE and we believe many others working on this standard.
It is very concerning that ANEC appears to have failed to listen to the people who work in and on
aircraft and others who have worked on this issue for decades in some cases. The GCAQE believes
that ANEC should listen to the people in the room, the people who work on aircraft and independent
medical experts and scientists as well as the aviation industry. You had the opportunity to be in the
room and to engage on this subject, once listening to all points of view. However, instead ANEC has
by your own admission, stepped back from taking an active role and now attacked the standard and
in our opinion thereby acting in a detrimental way to those who travel and work on aircraft.
We hope that ANEC will reflect and listen to the wider and long-established views on the direction of
this standard. Following that reflection, we would ask that ANEC urgently places the welfare of
consumers and workers who travel or work in aircraft, ahead of the regrettable established and well entrenched position we are seeing from ANEC.
Yours sincerely,
Dr. Susan Michaelis
Head of Research
Global Cabin Air Quality Executive
References
1. Watterson A, Michaelis S. Use of exposure standards in aviation. In: (2019) 2017
International Aircraft Cabin Air Conference. Journal of Health and Pollution: December 2019, Vol. 9,
No. 24, pp. S1-S142. https://doi.org/10.5281/zenodo.3605144 (2019).
2. Howard C, Johnson DW, Morton J, et al. Is a cumulative exposure to a background aerosol of
nanoparticles part of the causal mechanism of aerotoxic syndrome ? Nanomedicine Nanosci
Res 2018; 139: 1–8.
3. Michaelis S, Burdon J, Howard C. Aerotoxic Syndrome : A new occupational disease ? Public
Heal Panor 2017; 3: 198–211.
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London,
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Tel; +44 7880554551
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