Submitted by EurECCA
June 09, 2015
As informed and active stakeholders on cabin air quality issues, the EurECCA is submitting these comments on the proposed work organization and task groups that the CEN TC (Technical Committee) 436 Chairman circulated to members after the plenary meeting on April 20, 2015 in Brussels. Specifically, we propose an addition to the work organization structure (intended to establish some agreed-upon basic principles to guide the Standard development) and some changes to the task groups (intended to ensure that the Standard defines and ranks means to prevent exposure to chemical agents, according to a specific structure).
We generally agree with the structure of the working methodology proposed at the first meeting of TC 436 on April 20, 2015:
- Step 1 Establish a bibliography
- Step 2 Gather all available and relevant publications
- Step 3 Summarize the rationale
- Step 4 Provide formalized inputs to the relevant draft standard chapter responsible
However, given the diversity of the Stakeholders in this process, and the fact that the Standard is intended to address the needs of workers and a diverse population of consumers in a unique, enclosed, and safety-sensitive environment, we strongly recommend that members of TC 436 collectively first discuss and agree upon some basic principles to guide and support the drafting of this Standard. These principles should be grounded in relevant EU laws and regulations and should include:
- the precautionary principle;
- chemical exposure hazard assessment;
- risk assessment;
- means to determine whether there is evidence of a causal relationship between exposure and ill effects; and
- strategies to prevent exposure to chemical agents.
The current list of task groups proposed by the Chairman at the plenary meeting only covers one aspect of health and safety strategy; namely, defining and enforcing exposure limits for specific chemicals, and identifying suitable measurement methods for those chemicals. However, the Scope section of Form A states that the standard “will, in particular, focus on the presence of airborne chemical agents that may affect safety of operation, [and] in addition to health and comfort.” Thus, the task of defining control measures to prevent exposure to chemical agents/mixtures falls within the Scope.
Measures to prevent exposure to chemical agents in the aircraft air supply must be defined, classified, and ranked according to the classic occupational hygiene “hierarchy of controls.” This strategy is already required of EU employers according to Article 6 of Directive 89/391/EEC, according to the following structure:1
- The most effective option is to either eliminate the exposure hazard or substitute a hazardous compound for a less hazardous compound;
- The next best option, if the exposure hazard cannot be eliminated, is to apply engineering control measures intended to mitigate the chemical agent exposure hazard by addressing the exposure at the source;
- If engineering control measures are not sufficient, then administrative measures are useful to help to control/monitor the exposure;
- And, as a last resort when exposure cannot be adequately controlled by other means, personal protective measures, including the use of personal protective equipment (PPE), are instituted. Where PPE is given to workers, they must be trained in its use.
As a foundation to all of the task groups:
Identify and summarize EU legislation relevant to worker and consumer protection from exposure to chemical agents, including occupational hygiene control hierarchy, comparative hazard assessment, risk assessment, causation assessment, and the precautionary principle. Discuss and agree upon basic principles that will serve as the foundation for the work undertaken by all of the task groups.
Amend the task groups as follows:
- Combine “sensors” with “sampling and measurement methods” and renumber as Task Group 2;
- Insert “Industrial hygiene hierarchy of controls” (exposure prevention measures, as described above) and number as Task Group 3;
- Expand the current TG2 title (“thresholds”) to “early warning thresholds” and add a reference to developing procedures for workers to respond to said thresholds, all as a means to use chemical monitoring data as an early warning system for pilots and maintenance workers (Task Group 4); and
- Rename the current TG4 as “worker training/education,” add “incident reporting,” and renumber as TG5.
Thus, the proposed task group list is:
TG1 : Identify suitable chemical agent marker compounds;
TG2 : Identify suitable onboard sensors/sampling methods;
TG3 : Define, classify, and rank exposure control measures according to the occupational hygiene “hierarchy of controls”; (Note that some administrative controls [worker training/education, incident reporting, and chemical sensors/operating procedures] are addressed in separate TGs.)
TG4 : Define the early warning thresholds/procedures by which information from onboard chemical sensors would be applied/used as an early warning system for pilots and maintenance workers; and
TG5 : Worker training/education, including incident reporting system.
Justification for the proposed amendments to the task groups:
1. Combine “sensors” with “sampling and measurement methods” and renumber as Task Group 2;
This proposed amendment is self-explanatory.
2. Insert “Industrial hygiene hierarchy of controls” (exposure prevention measures, as described in Article 6 of Directive 89/391/EEC) and number as Task Group 3;
In accordance with European legislation on exposure to chemical at work, we recommend the creation of a task group to discuss and draft recommendations for exposure control measures, according to the classic occupational hygiene “hierarchy of controls.”
The European Chemical Agents Directive 98/24/EG (CAD)2 is the 14th special directive in the implementation of the framework directive 89/391/EEC3 on the introduction of measures to encourage improvements in the safety and health of workers at work. The CAD lays down minimum requirements for the protection of workers from risks to their safety and health arising, or likely to arise, from the effects of chemical agents that are present at the workplace or as a result of any work activity involving chemical agents. The employer must take the necessary preventive measures set out in Article 6 of Directive 89/391/EEC, and risks must be either eliminated or reduced to a minimum according to the hierarchy of prevention measures4 which starts with eliminating/substituting the hazards, and is followed by engineering design control measures, then administrative control measures, and ends with individual protection measures, including personal protective equipment (PPE).
Some exposure control/risk reduction measures for chemical agents in aircraft cabin air are already available and feasible, while and others require additional study. Note that, because a CEN standard cannot interfere with commercial competition, the task group would not propose language that would either require or promote specific technologies. Rather, a given technology would prove its supremacy by its rank in the preventative hierarchy.
3. Expand the current TG2 title (“thresholds”) to “early warning thresholds” and add a reference to developing procedures for workers to respond to said thresholds, all as a means to use chemical monitoring data as an early warning system for pilots and maintenance workers (Task Group 4); and
It is not possible for the TC to define “safe” exposure limits/thresholds. Rather, thresholds may be proposed in the context of an early warning system and would, thus, need to be accompanied by recommended actions/procedures for pilots and maintenance workers.
4. Rename the current TG4 as “worker training/education,” add “incident reporting,” and renumber as TG5.
“Worker training” should also include education. For example, providing workers with some basic education to enable them to better recognize and respond to the presence of certain types of onboard fumes is a simple and appropriate administrative control measure. Also, an incident reporting system is a tool to help to identify the nature of the chemical agents based on workers’ reports of nature of odour, whether smoke/haze, location in aircraft, apparent source, phase of flight, etc. It would enable more effective troubleshooting of reported issues and would help to identify/address trends. Thus, it is consistent with the Scope of TC 436. If an incident reporting system is recommended, then workers must be trained to use it.
In closing, EurECCA is convinced that prefacing our standard-setting task with a thoughtful review of some agreed-upon aspects of relevant EU worker and consumer protection laws, including exposure prevention strategies, will ultimately streamline the process.
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