The FDX MEC Environmental Standards Committee is Open for Business
Now that the CBA is behind us, we ask for your attention on something more important than our pay and benefits – our health, safety and long-term quality of life. Potential longstanding adverse environmental threats and issues in our pilot workplace—our cockpits, cabins, lavatories, galleys and crew rest areas are a major concern that must be addressed.
According to the FedEx Code of Business Conduct and Ethics, safety is our highest priority and FedEx is committed to providing a safe and healthy workplace. Under this Code, employees are responsible for reporting unsafe work conditions so that FedEx can take corrective actions. Pilots, however, are mostly unaware of hidden health and safety threats in their work environment, and therefore cannot report them.
Workplace environmental threats and issues extend beyond us to the wellbeing of our families who covet our quality time and depend on our careers for their financial security. For the sake of our health and wellbeing, as well as the wellbeing of our families, we all share the duty to engage with work environment issues.
The FDX MEC Environmental Standards Committee
In May of this year, the FDX MEC established the Environmental Standards Committee (ESC) for the purpose of fostering acceptable hygiene, health and environmental safety standards in our workplace.
The mission of the ESC is to research, document, report on and positively impact cleanliness, sanitation and health and safety related environmental threats and issues that exist in our pilot work environment.
What are the issues?
Thanks to the FedEx Aircraft Cleaning Project, the surface environment of our workplace is cleaner. But regrettably, below the surface environmental health and safety issues remain a matter of significant concern. The ESC is currently focused on these health and safety threats:
1. Air quality in our cockpits and cabins.
2. Crew oxygen mask cleanliness. Of particular concern is the frequency of cleaning behind the microphone where you cannot see or sanitize.
3. Potable water tank servicing. Improper servicing can lead to harmful bacteria.
4. Toxic insecticides sprayed onboard aircraft without safety precautions or health warnings being disseminated to ramp workers or flight crews using the product.
5. Ozone converters – do we have them and are they properly maintained?
6. Lack of soap and water for washing hands after we touch many dirty things and use toilets.
Each of these issues will be explored on in detail in upcoming ESC newsletters because you have the right to know and the obligation to report infractions.
Is FedEx ALPA going this alone?
No. Working through our FDX ALPA leadership, the ESC petitioned ALPA National for support. As it turns out, ALPA National, through their Air Safety Organization, was already in the process of elevating their occupational health program to higher levels within our government for the benefit of all ALPA pilots. ALPA National congratulated our FDX ALPA groundbreaking efforts and pledged full support of our ongoing ESC program.
Additionally, the ESC has formed collaborative working relationships with influential subject matter expert (SME) organizations and individuals who possess a wealth of knowledge and understanding of the issues we face. Having these assets in place as we perform ESC work will add efficiency, depth and credibility to our work.
ESC Principles and Strategy
Principles forming our strategy:
1. Pilots have the right to know if they are working in an unhealthy environment.
2. FedEx makes all employees responsible for reporting unhealthy or unsafe conditions. Since pilots are generally unaware of below the surface health and safety threats, the MEC has tasked the ESC to inform and educate pilots so that adverse conditions can be properly reported.
3. Given that safety is FedEx’s highest priority, and that FedEx is committed to providing a safe and healthy workplace, it is assumed that unhealthy or unsafe work environment conditions will be cured, or at least mitigated.
Our strategy is to:
1. Inform and educate the FedEx crew force on work environment hygiene, health and safety threats we face every day at work. This will be accomplished through a series of newsletters with this newsletter being the first. Future newsletters will drill down into specific issues and provide documentation, reports and data to support the need for change.
2. Continue our attempts to establish a channel of communications and a collaborative working relationship with Flight Ops management and appropriate FedEx departments including Flight Safety, Tech Ops (Maintenance) and Aircraft Engineering. With substantial work environment information, including data collected at FedEx over the past three years, the ESC feels we can contribute significantly to much needed change. We continue to offer our time, knowledge and SMEs to investigate and resolve longstanding pilot work environment issues.
3. Continue working with the ALPA National Air Safety Organization to build long-term strategy that will improve pilot work environment health and safety conditions for all airline pilots.
4. Continue building working relationships with SME organizations and individuals who will lend strength and credibility to our efforts.
URGENT: Harvard Airline Pilot Health Survey and Study
There are only a few studies about airline pilots which have examined the broad health effects of occupational exposures apart from disease-specific morbidity and mortality studies. Researchers at the Harvard T.H. Chan School of Public Health are currently recruiting airline pilots to take an anonymous survey about work and health. This study is designed to characterize the health and well-being of pilots and relate these conditions to environmental and personal exposures. This is a web-based, anonymous survey that for the first time polls pilots around the world directly. The Harvard survey website states, “We tailored the survey to address issues that are of primary concern to pilots, and hope you will join us in this first of its kind assessment of pilot health.”
The ESC is asking you to spend 15 minutes to take the Harvard Airline Pilot Health Survey before Dec. 31. Information gained will benefit every airline pilot in the world and will contribute significantly to much needed environmental improvements at FedEx. This is an urgent matter and we need your participation.
Take the Harvard Airline Pilot Health Survey: http://www.pilothealthstudy.org/
The study will remain open until December 31, 2015. After taking the survey, be sure to click on the RESEARCH tab on the website for a collection of information and technical documents regarding pilot work environment threats.
This first ESC newsletter sets the stage for much more information to follow. Future newsletters will address specific hygiene, health and safety issues and threats we face in our work environment. The next newsletter will address contaminated air. For a read-ahead, go to www.gcaqe.org and download the Contaminated Air Overview brochure on the home page.
It is time for FedEx to improve or adapt policies, procedures and standards that respect the health, safety, dignity and quality of life of every FedEx pilot, every day they fly. Equally important, it is time for every FedEx pilot to become informed and educated on work environment issues that potentially threaten our long-term health, quality of life and the financial security of our families. Once informed, we must all work to change adverse work environment conditions. Like many things in our profession, we will continue to live with the standards we continue to accept.
We invite all feedback from the crew force. If you have a question, a story, an opinion or a work environment issue you think should be addressed, please forward your comments to: FedExESC@ALPA.org
Potential progress regarding cleaning up our work environment
On Thursday, March 31, our MEC met with FedEx senior leaders to present and discuss issues that
have been raised by the Environmental Standards Committee (ESC).
Attending the meeting for FedEx:
- John Maxwell, Senior Counsel, Regulatory Affairs
- Cynthia Chandler-Snell, Senior Counsel, Regulatory Affairs
- Capt. Tim Leonard, VP Flight Operations
- Ed Lyons, VP Flight Safety
- Capt. Rob Fisher, SCP
- Capt. Tim Murphy, MD Flight Safety
- Capt. Kim Koryat, Flight Safety Projects
- Tim Hersberger, Corporate Safety Advisor, Safety Programs
- David Church, Aircraft Engineering
- Tech Ops Rep (name not recorded)
Attending from ALPA:
- Capt. Chuck Dyer, MEC Chairman
- Capt. John Cardaci, MEC Vice Chairman
- Russ Sklenka, MEC Executive VP
- Mr. Terry McTigue, FDX ALPA Attorney
- Capt. Bob Avery, ESC Chairman
Capt. Chuck Dyer began the meeting by presenting the background on past aircraft cleaning and environmental standards efforts. I delivered a 35-minute PowerPoint presentation, which presented a considerable amount of information new to FedEx.
These issues were presented with supporting data, documentation and photos:
- Contaminated air and toxic particulate matter in our ventilation systems that has accumulated over decades due to the lack of HEPA filters and air systems that are never cleaned.
- Potable water tanks improperly serviced causing serious water contamination.
- Crew oxygen masks only cleaned internally once every six years allowing dried mucus, pathogens and other foreign mater to accumulate behind the microphone (in the regulator area) where pilots cannot see or clean.
- Toilets improperly serviced and maintained causing foul odor, unpleasant and unsanitary conditions.
- Lack of soap and water for basic hand washing while aboard aircraft.
- Use of insecticides with no adequate health warnings for ramp personnel dispensing the product or pilots exposed to the product.
- Ozone converters (issues to be discussed later)
We made the reasons for our MEC’s concerns clear:
- The health and wellness of 4,000+ FedEx pilots who are exposed to unhealthy conditions every day they work.
- The wellbeing of pilot families who depend on their spouse’s career for financial security and quality of life.
- The safety of our airline.
- The finances and reputation of our Company.
We proposed simple, obvious and inexpensive remedies for most of the issues. Most remedies would only require maintenance in accordance with standard airline industry practices, existing FedEx policies and procedures, aircraft manufacturer’s recommendations and basic cleaning and hygienic practices recommended by aviation agencies and government health and safety organizations such as: ICAO, OSHA, NIOSH, FDA, CDC, Dept. of Health and the World Health Organization. Simply put, we are asking for the same cleaning and hygienic policies, procedures and standards that are taken for granted by every other FedEx employee, every day they work.
After the presentation, the group spent one hour in a lively exchange that only stopped when the time that we had allotted was consumed. It was apparent from the beginning of the discussion that FedEx participants took the briefing seriously. During the discussion, FedEx attendees presented a number of thoughtful questions and comments. In the end, FedEx leaders asked the ESC for more data in order to better understand the depth of the issues, and promised follow-up meetings to discuss a way forward. In parting comments, they made it clear that FedEx intended to revisit all issues while considering new evidence presented, with pilot health and airline safety being a top priority. Of particular note was the genuine concern and rapid response by FedEx Express Vice President of Flight Operations Tim Leonard. He made it clear that his door is open to continue discussing the issues and that issues presented would be seriously reviewed at all levels.
ALPA’s proposal to FedEx for moving forward remains unchanged:
- Open a channel of communications so the ESC can communicate information and data with the appropriate FedEx departments and managers.
- Form and support a collaborative investigation committee, to include the ALPA ESC, that will research environmental threats in a meaningful way.
- Receive FedEx’s commitment that any health and safety threats identified will be eliminated, or at least mitigated, to the maximum extent possible.
- Establish and support an ongoing Aircraft Cleaning Program and Environmental Standards Program co-lead by the customers – the pilots.
- Through innovative change, make FedEx an industry leader in safeguarding the health and wellness of our pilots.
Follow-on meetings have already been set to review data and discuss a way forward. It is clear that FedEx leaders are concerned with existing conditions and will explore viable solutions. However, the only acceptable way to resolve the threats and issues is to work in a collaborative trust but verify environment.
Overall, ALPA attendees viewed this meeting as pivotal and a major positive step in advancing environmental issues. Judging from the concerned questions and comments from FedEx leaders, we departed the meeting optimistic that FedEx will do the right thing.
Keep in mind that prior to 2013, environmental threats had never been formally surfaced and aircraft cleaning barely existed. Thanks to Mr. Greg Hall (former SVP Tech Ops) an entire new aircraft cleaning program was built at a cost of tens of millions of dollars based on pilot input. Today, the aircraft cleaning program is working and the visible areas of our work environment are much cleaner – probably among the cleanest in the airline industry. By the way, if you see see Mr. Hall, you owe him a huge debt of gratitude and a big “thank you”.
Like many things in our career, we live forever with the standards we accept today. FedEx environmental policies and procedures will set the hygiene and health standards we live with every day we work for the remainder of our career. Please pay close attention as this scenario unfolds. Let our managers and leaders know how you feel about a clean and healthy workplace. If it is perceived we do not care, it is unlikely meaningful change will occur.
About the FDX ALPA Environmental Standards Committee
The ESC was established to foster acceptable hygiene and health environmental standards in our workplace. The ESC mission is to research, document, report on and positively impact cleanliness, sanitation and health related environmental threats that exist onboard the aircraft we fly. We will work in a diligent, responsible and professional manner with a sharp focus on our reason to exist – guarding the health of every FedEx pilot, every day they work.
We invite all feedback from the crew force. If you have a question, a story, an opinion or a work environment issue you think should be addressed, please forward your comments to: FedExESC@ALPA.org
Update on Company discussions, recap of issues, and a way forward
Interest in Environmental Standards Committee (ESC) issues remains high. After ESC newsletter #2, these questions and concerns continue to be raised by the crew force:
- How did a scenario developed where ALPA is appealing to FedEx to resolve known health and safety issues in our workplace?
- By far most requested: Pilots want more information on specific health and safety issues mentioned in past correspondence.
- Who is responsible for guarding our health at work?
- What is the logical path forward? Is FedEx serious about addressing these issues?
- This newsletter addresses these concerns and questions. Future newsletters will discuss details of health and safety issues and what we can do to help ourselves.
- How did this scenario develop?
To put the current situation in perspective, here is a recap of how we got to where we are today.
Health and safety concerns on board our aircraft were first brought to the attention of Flight Ops leaders in March 2013. In October 2014, a letter was delivered to FDX Flight Ops management outlining specific threats and issues.
Upon receiving the Oct. 2014 letter, FedEx Regulatory Affairs (Legal) assembled a team of specialists and directed an investigation of issues outlined in the letter.
One year later (Oct. 5, 2015), FDX Regulatory Affairs sent a letter to our MEC Chairman stating that an investigation had been conducted and that FedEx procedures were appropriate, met manufacturer’s recommendations, complied with or exceed all applicable regulatory requirements and provided for the health and safety of pilots. No other details about the investigation were disclosed.
The ESC disagreed with the conclusions of the Oct. 2015 Regulatory Affairs letter based on substantial data and evidence, including laboratory testing, that was not reviewed by the investigation team. Because the large discrepancy between the Regulatory Affairs conclusion and ESC data, evidence and information, the ESC petitioned ALPA leadership to request a meeting with FedEx Legal and Flight Ops leaders for the purpose of presenting the ESC information.
After consultation with FDX management, that meeting occurred on March 31 of this year. The ESC presented the data and evidence to FedEx Legal, Flight Safety, FDX Maintenance and Aircraft Engineering and Flight Ops senior leaders. This briefing was reported to the crew force in ESC newsletter #2. After the ESC presentation, FedEx leaders agreed to accept and examine ESC information, revisit all issues and continue to meet with ALPA.
Following the March 31 briefing, the ESC forwarded more supporting data and evidence to FedEx Regulatory Affairs and Flight Ops senior leadership. We have since been told that FedEx Flight Ops and Legal leaders will meet to discuss how to proceed, then will be back in contact with ALPA. We optimistically anticipate follow-on meetings with FedEx and the opportunity to participate in achieving solutions to the issues presented.
More details on health and safety issues in focus:
Following is a summary of issues that have been presented to FedEx Legal and Flight Ops senior leadership.
- Contaminated Air: Our ventilated air is contaminated with toxic substances, according to laboratory testing. Contaminants found so far are known causes of respiratory and neurological illnesses. We cannot say the contaminants are causing illness in anyone—only a doctor can, but we can say that the contaminants tested are toxic.This situation is worsened due to the removal of HEPA filters from all FedEx aircraft (except the B-777, in which HEPA filters are integral to the air system and cannot be removed) and ventilation systems that have never been routinely cleaned at FedEx, as aircraft manufacturers say should be done. These shortfalls allow a black ultra-fine graphite-like material and other particulate matter to accumulate throughout the ventilation system. Laboratory testing of this particulate matter taken from a FedEx MD11 revealed the presence of black carbon and fiberglass. Both are toxic and both can have serious short and long term ill health effects, especially in the respiratory system. Fiberglass has been called “the new asbestos.”An example of particulate matter clogging our air systems can be seen in this photo looking inside the cockpit ceiling main air supply vent in one MD11 and this photo looking into the same vent from another angle. Another photo (taken in 2013 before the Aircraft Cleaning Program started) shows the same material in the cockpit door vents where it accumulates as air passes through. The matter is not this thick in MD11 door vents today because the vents are frequently cleaned under the Aircraft Cleaning Program. But the matter builds again after cleaning indicating it is ever-present in the ventilation system. This particulate matter is present in many of our aircraft across our fleets.Ever wonder why you can take a shower, put on a clean white uniform shirt, then end the flying day with a gray ring around your shirt collar? Natural oil and perspiration from your body keep your neck and collar moist and sticky. Constantly moving your head causes frequent contact between your neck and collar, trapping the graphitelike material suspended in the air on your collar to create the stain. You may also notice gray soap suds when you wash your hands in your hotel room after a day’s work. What you are seeing on your collar, on your hands and in the vents and doors is the ultra-fine material that coats everything in the cockpit and is constantly present in the air we breathe.Fume Events are another type of air contamination. When dozens of pilots were asked if they had heard the term, “fume event,” all said no. When they were asked if they have ever smelled the pungent dirty socks, stale gym locker, or moldy cheese smell, all said yes—a number of times. This type of odor created during a fume event is a primary indicator that toxic substances are being released into the ventilation system.According to multiple documents, including those published by the FAA, ICAO and reputable technical sources, fume events emitting these types of odors are typically caused by engine oil or hydraulic fluid leaking into the pneumatic system, then becoming pyrolyzed (thermally decomposed) when exposed to extreme heat from within the pneumatic system. When this happens, chemical synthetic oil additives such as tricresyl phosphate (TCP) or tributyl phosphate (TBP) are released. Both chemicals are toxic and both can do short and long term health damage to the respiratory system. TCP is a known neurotoxin.
Air samples and particulate mater wipe samples taken by the ESC from several MD11 aircraft were sent to the University of British Columbia, School of Population and Public Health, Faculty of Medicine for testing. Results confirmed the presence of TCP and TBP. The report states, “The data presented here show that there are bleed air contamination problems within the aircraft monitored. Flight crew members are exposed to this through the inhalation of the air as well as through dermal exposure…It should be emphasized that the agents identified in this report are not only toxic by themselves, but are also indicators of many other agents that are produced due to the pyrolysis of bleed air contaminants.”
Fume events producing the odors described above are typically the result of mechanical irregularities or failures—such as over servicing oil systems and weak or 3 failed engine oil seals allowing oil to enter the pneumatic system where it becomes pyrolyzed. Fume events happen in all commercial airliners except the B-787 Dreamliner where cabin air is supplied by electric compressors, not from the engine via the pneumatic system. No airline can prevent fume events caused by pneumatic system design issues. However, important steps should be taken to mitigate health risks and train pilots and maintenance on this threat.
Most pilots consider a “dirty sock” odor fume event an unpleasant nuisance and are oblivious to the potentially serious medical effects of this type of contaminated air exposure. Pilots should be aware that adverse health side effects or illness following a fume event could be a result of the event. Ill health effects can occur quickly or can take up to 24-48 hours before becoming obvious. If ill health due to a fume event is suspected, proper medical attention should be considered.
This document, Management of Exposure to Aircraft Bleed-Air Contaminants Among Airline Workers, funded by the FAA and written by a group of medical professionals, is an excellent discussion on exposure to pyrolyzed engine oils and hydraulic fluids. The report discusses health effects associated with exposure, symptoms, evaluation of health effects and treatment and reporting.
Pilots have been reminded through recent Flight Ops hot-topic communications that FARs require an AML write-up for every mechanical irregularity or failure. Given that fume events are the result of mechanical irregularities or failures, to not write up a fume event is a willful violation of FARs.
Since fume events are a threat to health and safety, a flight safety report is required (FOM 2.15 Mandatory Reports, indications of smoke, fumes, fire or odor). Filing an ASAP report rather than a FSR should be considered since the FAA will automatically be notified of the event through the ASAP program.
FedEx should train pilots to recognize and understand the events so they can be properly reported. Maintenance should be trained to understand the cause of the events so appropriate fixes can be implemented. ICAO Circular 344, Guidelines on Education, Training and Reporting Practices related to Fume Events provides guidance to airlines on reporting, as well as education and training of flight crews and AMTs to enable them to prevent, recognize and respond to the presence of fumes, particularly aircraft air supply system-sourced engine or auxiliary power (APU) oil or hydraulic fluid fumes.
Fume events and contaminated air largely go unreported at FedEx due to our pilot’s lack of basic knowledge surrounding this issue. This is something we can correct beginning immediately. It is important that you use the term “Fume Event” in the AML and FSR or ASAP report.
This document, Contaminated Air Overview (GCAQE), provides a good description of how fume events are created.
This paper, A counterpoint to key misperceptions about exposure to aviation engine oil and hydraulic fluid fumes (Judith Anderson) systematically reviews the most commonly encountered misperceptions regarding crew health and flight safety hazards of breathing ventilation air contaminated with either engine oil or hydraulic fluid fumes on commercial and military aircraft.
This paper, Contaminated Aircraft Cabin Air (Dr. Susan Michaelis) gives a broad overview of the subject, covering all salient aspects including the technical history, a discussion of the compounds involved in the contamination, the frequency of occurrence, a survey of attempts to measure the contamination, safety considerations, health considerations, and possible technical solutions to the problem of contamination.
- Potable water: Potable water tanks are not properly serviced causing foreign substances to grow inside the tanks. A bold face warning on page 2 of Tech Ops work card 38-010-00-01 states, “If the potable water system is not drained at a minimum of one time each three days, the growth of bacteria can occur. If bacteria growth continues and you drink the water, illness can occur.” According to Tech Ops sources, potable water tanks on MD11 and B-777 aircraft have never been drained on a scheduled basis. According to mechanics who have serviced the potable water systems during heavy checks (occurring approximately once every 1–2 years), the tank interior walls are frequently coated with a green slimy substance and have a brown sludge floating on the water’s surface. Until this issue is resolved, the ESC recommends not drinking coffee from the aircraft’s coffee maker. The green metal coffee jugs are routinely washed in a commercial dishwasher in MEM.
- Crew Oxygen masks: Oxygen masks are only cleaned and sterilized once every six years when masks are sent to a third-party vendor for major overhaul. This six-year overhaul cycle complies with mechanical requirements and regulations but the time cycle does not consider potentially serious hygienic issues. Over the six-year period, our masks accumulate a buildup of dried mucus, food crumbs and other foreign substances behind the microphone in the regulator and hose attachment area where you cannot see or clean with a Sani Com. According to our mask servicing vendor, these foreign substances are commonly found in FedEx masks during the six-year overhaul.OSHA standards do not allow one employee to wear an oxygen mask after another employee until the mask is cleaned and sanitized. Unfortunately, flight crews are not protected by OSHA. In our cockpits, if a mask was used an average of fifteen times per month and you are at the end of the six-year cycle, more than one-thousand people before you have worn the mask and deposited whatever pathogens, mucus, food or other particulate matter they gave up while breathing into the mask.Recently, three pilots informed the ESC they contracted serious illness after wearing a crew oxygen mask, including a heavy acne-like breakout on their face in the exact print of their mask, staphylococcus (staph infection) that required antibiotics and doctor’s care, and an inverted papilloma, a very serious condition that required surgery and using three months on sick leave. If you have experienced an adverse reaction to wearing the crew oxygen masks, please send your story to the ESC. The more data we have, the more effective we can be.Many airlines send their mask in for annual cleaning and inspection which significantly reduces the build-up of pathogens and undesirable foreign substances. Besides better controlling the build-up of foreign substances, the annual cleaning and inspection would reduce FedEx’s overall cost of maintaining masks, according to our mask vendor.
- Use of toxic insecticides: Toxic insecticides are dispensed on board aircraft with no safety training or warnings for ground crews dispensing the product or flight crews exposed to the product after it is dispensed. The Material Safety Data Sheet (MSDS) for the insecticide sprayed on our upper cargo decks states the material can cause respiratory irritation and further lung damage. The MSDS states a number of cautions and warnings for handling and dispensing the product—but ramp personnel and pilots are completely unaware of these cautions and warnings. The chemical manufacturer has additional warnings and cautions, such as a seven-minute wait period from the time the chemical is sprayed until the aircraft air system is turned on.
- Ozone converters: Ozone converters may not be installed on some of our long-range aircraft. Ozone exposure creates serious respiratory health concerns, especially on longhaul flights and flights operating at higher latitudes. We are standing by to hear from FedEx which aircraft have ozone converters and which do not.
- Toilets: When you board the aircraft, look at the Aircraft Lavatory Service Record (LSR) found in a grey multi-pocket pouch on the inside or outside wall of the toilet. You will find a date and record indicating when the toilet was serviced (blue water change). The blue water manufacturer has stated the fluid should be changed once every 24 hours, given our low volume use. After 24 hours, the chemical begins to break down and foul odors develop due to the buildup of e coli from solid waste and ammonia from urine. Maintenance’s standards call for changing blue water every three days. In reality, toilets sometimes go well past the three days. You can see the last blue water change on the LSR.Unlike ground-based toilets, aircraft toilets waste does not go away when flushed, but continues to stir in a small pot of fluid. In the case of an Airbus or B-777, the pot of water is only about 2.5 gallons. It does not take long for human waste on a hot ramp to become unbearable and unsanitary.
The ESC recommends that captains check the LSR immediately upon boarding the aircraft. If the toilet stinks, or if the toilet has not been serviced in an acceptable amount of time (you be the judge), one radio call to maintenance will normally result in a lavatory servicing cart in less than 15 minutes (at a FedEx hub airport). If you cannot get a blue water change due to your remote location, make an AML entry so servicing will occur at the next possible opportunity.
We wince at toilet odor when we board the aircraft, complain to each other, and then work our shift within a few feet of a malodorous toilet. Remember, this unpleasant condition can often be eliminated with one quick radio call. If we won’t take the time to call for a service or write up a malodorous toilet, we are getting what we have accepted.
- Lack of soap and water for hand washing: 75 percent of our aircraft do not have soap and water for hand washing. We spend our workday touching many dirty things, then use the toilet, then eat our catering with our bare hands—without having the ability to wash our hands with soap and water. No other FedEx employee is expected to accept these conditions because these conditions are not allowed under OSHA rules. Hand sanitizer was never intended to replace soap and water and will not remove grease, grime and other particulate matter. OSHA does not allow this substitution and the FDA highly discourages it.
It is unlikely FedEx will put potable water back in 75% of our airplanes, but hand soap could be supplied to all aircraft and bottle water can be used for washing hands. The existing unacceptable hygienic condition can be quickly cured by adding a soap holder and bottle of soap to all aircraft without potable water. Hand sanitizer should be kept for those who see a need for it. This simple and inexpensive fix would completely eliminate this serious hygienic issue.
Inexpensive solutions are readily available for most of the issues presented. Most would be eliminated if FedEx would comply with standard airline industry practices, adopt hygienic and health standards granted to every U.S. industrial worker by law (OSHA) or, in the case of potable water, simply comply with existing Tech Ops published procedures.
Future newsletters will discuss more details and supporting data and evidence on each of these matters.
Who is responsible for guarding our health at work?
First, consider the fact that health and safety are indivisible in our world of operating complex aircraft around world, around the clock.
Many pilots ask why OSHA is not involved. Ironically, OSHA protects pilots everywhere on FedEx property except on board the aircraft they are operating. OSHA has jurisdiction over flight attendants but not pilots on board commercial airliners. If FedEx pilots were protected by OSHA, issues and threats we are discussing could not exist. Under current circumstances, we can only depend on FedEx leadership to provide occupational health and safety standards guaranteed by law to every other worker in America and taken for granted by every FedEx employee, every day they work.
Our demanding profession is complicated by a number of unavoidable health and safety threats such as inverted circadian rhythm cycles, fatigue, radiation, hazardous cargo and others. Any risk that can be avoided should be avoided. To reduce our exposure, we are asking FedEx to to eliminate, or at least mitigate to the maximum extent possible, the manageable health and safety threats we face daily. We believe the following FedEx policies concerning health and safety, created and handed down by FedEx executive leadership, support our request:
- The FedEx Express (USA) Personnel Policy and Procedure Manual (The People’s Manual), Section 8-1, Corporate Safety, states that FedEx Express is dedicated to the principle that its employees are its most important asset. Therefore, one of the primary concerns in the performance of all work is the safety and health of all employees. Guidelines in this paragraph state: All levels of management are responsible for providing and maintaining a safe and healthy work environment.
- The FedEx Code of Business Conduct and Ethics, Health Safety and Environment chapter, states that FedEx is committed to providing a safe and healthy workplace and that all employees are responsible for reporting unsafe or unhealthy conditions. Managers are responsible for addressing unsafe or unhealthy conditions.
- A commitment from Mr. Dave Bronczek, CEO of FedEx Express, is stated in a Safety Policy Letter posted on five-foot billboards at the entry to MEM Flight Ops, IND Flight Ops and other places around our system. Mr. Bronczek’s letter discusses our “Safety Above All” culture and the FedEx pledge to improve employee satisfaction and loyalty by ensuring a safe working environment. The letter charges every employee with the responsibility for maintaining a safe and healthy workplace and affirms FedEx’s commitment to resolve unsafe or unhealthy conditions quickly. Mr. Bronczek states, “We will provide the necessary financial and human resources for the implementation of this safety policy.”
Given this guidance, we are confident our Flight Ops leaders will actively engage with a program to eliminate manageable health and safety threats in our work environment.
What is the logical path forward?
With concurrence of our MEC leadership, the ESC proposed a new investigation of environmental conditions on board FedEx aircraft be conducted in an open and collaborative environment that would include the ESC and consider all data and evidence available. This ALPA proposal, delivered to Flight Ops leadership and Regulatory Affairs in April, would focus on protecting the health of FedEx pilots and the safety of our airline while being mindful of corporate objectives, limitations and conditions that are not controlled by FedEx.
Cleaning up the immediate health and safety threats and issues is the priority. After that, we need a long-term sustainable program to maintain acceptable health and hygiene standards on board our aircraft. In our profession, cleanliness, hygiene, health and safety are inseparable. Based on this certainty, the ESC proposal further recommended that aircraft cleaning and occupational health and safety initiatives be organized and administered by a single workgroup. We believe the workgroup should be co-lead by Tech Ops, as the service provider or overseer of third-party aircraft cleaning vendors, and Flight Ops as the quality assurance arm representing the customer. Through Insite (formerly the POR system), every pilot would be encouraged to actively participate in this innovative program affecting their health and quality of life on a daily basis.
This concept has already been proven effective. When the FedEx Aircraft Cleaning Program (ACP) was initiated in early 2013, Flight Ops leader’s communications encouraged pilots to participate in the ACP through the POR system—and they did. PORs immediately jumped from 2-3 per month to over 100 per month. This gave Tech Ops the information they needed to effectively attack the problems and Flight Ops real-time feedback of actual conditions and resolutions. When circumstances called for more attention or an innovative solution, the joint Tech Ops/Flight Ops ACP team engaged and resolved many issues. The co-lead ACP team was innovative, successful and game changing with regards to hygienic conditions on board our aircraft. Then, for unknown reasons, Fight Ops participation in the ACP was completely eliminated and the entire program was returned to Tech Ops. Removing the customer from the process put us back on a course that created the need for the ACP in the first place.
Based on sound management principles and past proven success, the ESC firmly believes that combining aircraft cleaning and environmental issues under a permanent project, co-lead by Tech Ops and Flight Ops, is the most logical and sustainable approach to resolving issues that have plagued our crew force for decades and remain unresolved today.
In summary, ALPA’s proposal to FedEx for moving forward remains unchanged:
- Open a channel of communications so the ESC can communicate information and data with the appropriate FedEx managers and departments. (This was accomplished with our March 31 briefing.)
- Form and support a collaborative investigation committee, to include the ALPA ESC, that will research environmental threats in a meaningful way.
- Receive FedEx’s commitment that any health and safety threats identified will be eliminated, or at least mitigated, to the maximum extent possible.
- Establish and support an ongoing Aircraft Cleaning Program and Environmental Standards Program co-lead by the customers – the pilots.
Is FedEx serious about addressing these issues?
Since our March 31 presentation, Flight Ops leadership and Legal opened the door by agreeing to accept and review ESC data and supporting evidence, and to continue discussions. Since then, all communications have been positive and encouraging and we continue to believe our Flight Ops leaders will act in the best interest of the crew force. We are optimistically waiting for the next step.
As highly trained and skilled professionals held to the highest standards and shouldering large responsibilities for property, life and assets of our company, we deserve the dignity of a clean and healthy work environment. As line pilots, we will live every workday of our careers on board FedEx aircraft. For many, that means thirty or more years. It is in everyone’s self-interest, not to mention the interest of our families who depend on our health and career for their financial security and wellbeing, to get involved and stay involved with this project. More information on how to do this is forthcoming.
We invite all feedback from the crew force. If you have a question, a story, an opinion or a work environment issue you think should be addressed, please forward your comments to FedExESC@ALPA.org or call the ESC chairman anytime.
About the FDX ALPA Environmental Standards Committee (ESC) The ESC was established to foster acceptable hygiene and health environmental standards in our pilot workplace. The ESC mission is to research, document, report on and positively impact health, safety and hygiene related environmental threats and issues that exist on board the aircraft we fly. We will work in a diligent, responsible and professional manner with a sharp focus on our reason to exist – guarding the health of every FedEx pilot, every day they work.
The response to ESC newsletter #3 was overwhelming. Many pilots are concerned, to say the least. We should be because this issue is more important than our money. This is our personal health and the financial security of our families who depend on our careers for their wellbeing.
Many have asked—what do we do now? This newsletter is about helping ourselves. Some information is repeated from ESC newsletter #3, but I believe it’s worth repeating.
First, some background info that creates the major point of this newsletter. When the FedEx Aircraft Cleaning Program (ACP) was established in mid-2013, Flight Ops leaders put out communications to the crew force asking for PORs on aircraft cleanliness issues and promising that pilot input was vital to the success of the program. They were right. Aircraft cleanliness PORs increased 15-fold from the January—March 2013 period to the July—September period that same year—a groundswell that took everyone by surprise. With PORs describing specific issues on specific aircraft, Tech Ops was able to focus resources where they were needed. Flight Ops, as co-leader of the ACP team at that time, was able to monitor issues and engage if issues were not properly addressed. When innovation was required, the ACP team was usually able to come up with a solution. Under this system, much was accomplished in a highly effective manner. Hard data in the form of PORs and other supporting research won the day.
Unfortunately, this highly successful system was later abandoned when pilots—the customers, were removed from the ACP team. This setback put pilots back in the same situation that created the need for the ACP in the first place. Based on sound management principles and past proven success, the ESC firmly believes that combining aircraft cleaning and environmental issues under a permanent project co-lead by Tech Ops and Flight Ops is the most logical, effective, and sustainable approach to resolving issues that have plagued our crew force for decades.
The point of this background info and the lesson to be relearned: Changes do not happen at FedEx without thorough documentation and hard data to back the need for change. That’s not criticism, but acknowledgement of a sound business practice. Documentation and data are required to drive change on the issues the ESC has engaged. No data = no problem = no change.
Insite (formerly POR)
Many ask: “Does the Company pay attention to pilot-generated reports and will anything be done?” Whether you’re an optimist (they can only fix what we report) or a pessimist (why bother—nobody is listening), Insite is vital. I happen to be an optimist based on my former work with the FedEx ACP. But assume nobody is listening and discrepancies are not resolved. In this case, Insite tickets are just as important because they build a database of unresolved issues that can later be used to create change through other channels. Optimist or pessimist—Insite tickets and a history of data are vital to changing hygienic and health conditions in our work environment.
What should we report?
This is a starter list. More to follow in future newsletters.
Why are FedEx toilets so malodorous when passenger airliners are not?
In order to present the argument on how we help, this newsletter will focus on a specific issue near and dear to our hearts—aircraft toilets. The following was learned while working with the manufacturer of our toilet blue water and from other sources. This information provides details on toilet mechanics to help understand how issues are created. Next are examples suggesting how you can help eliminate filthy and malodorous toilets. Examples should be applied across the board to all other hygiene and health issues in our work environment. WARNING: This is more than you wanted to know about aircraft toilets.
The main components of a liquid flush toilet are the seat, shroud, toilet bowl, tank top, flush system and waste tank. Here is a technical diagram if you want a visual. The small waste tank is attached to and sets immediately below the toilet bowl, just behind the flapper valve. (The B-777 has a vacuum toilet, which is different than the rest of our fleets.) The normal blue water charge for an Airbus and B-777 is about 2.5 gallons of blue water. Other aircraft hold slightly more.
Unlike ground-based toilets, aircraft toilet waste does not go away when flushed; rather, it continues to stir in the small waste tank partially filled with chemically charged blue water. Chemicals engineered to kill bacteria and other pathogens and eliminate foul odor work well when blue water is fresh but begin to break down and become ineffective when human waste is introduced, or over time even without human waste.
Besides being used several times per day by flight crews and jumpseaters, it was documented by the FedEx ACP team that our toilets are used by ramp personnel when they are working in and around the aircraft (even though they are instructed not use aircraft toilets). A considerable amount of human waste can accumulate in the small waste tank and blue water can rapidly become ineffective after several days without servicing.
Aircraft toilet tanks are the breeding ground for E. coli and fecal coliform. These and other bacteria can cause infections and sickness and have a foul smell. Organic growth and tar-like buildup is created by solid waste in the toilet tank and organic and inorganic buildup in the pump, pipes, valves and waste tank walls. Organic growth is also created outside the toilet—on the seat, shroud and floor (bad aim/low manifold pressure) and all other surfaces where blue water aerosol settles after a toilet flush. Mineral scaling is created by urine. Urine generates ammonia, which is foul smelling and corrosive. As waste buildup and organic growth increase, bacteria and other pathogens multiply and foul odors increase.
When an aircraft toilet is flushed, whatever matter is suspended in the blue water can become airborne via aerosol created by the flush. When this happens, you can inhale the particulate matter, and particulate matter is left behind on all surfaces where the aerosol settles and evaporates. The good news is that if the blue water is fresh and active, pathogens have been killed and particulate matter carried in the blue water will not likely threaten your health. If the blue water has been in the tank for days, and chemicals are breaking down, all bets are off.
After 24 hours and when human waste is deposited, blue water begins to chemically break down and becomes less effective in killing bacteria, other pathogens, and odor, according to the manufacturer. When breakdown occurs, E. coli and fecal coliform from solid waste and ammonia created from urine are able to multiply. Bacteria thrive in warm, wet conditions. In warm weather, and especially when unserviced toilets are buttoned up for layover on a hot ramp, bacteria can grow rampant and malodorous conditions can become unbearable. Besides being disgustingly unpleasant, these conditions are unhealthy, unsanitary, and can cause illness, according to the World Health Organization.
The only way to prevent or eliminate pathogens and malodors in aircraft toilets is to eliminate the source. Source elimination is accomplished through three distinctly different procedures—cleaning, sanitizing, and odor control. All three are vital to the lavatory housekeeping process. Cleaning means complete removal of dirt and waste using physical means and appropriate detergent. Sanitizing is the elimination or reduction of the number of microorganisms to a safe level. Odors are controlled through cleaning and sanitization and with fragrances in the blue water.
The following three procedures are industry-standard practices for cleaning, sanitizing, and odor elimination in airliner lavatories.
First, toilets must be “soaked,” meaning deep cleaned, by filling and soaking the toilet tank, pipes, valves, and pump with a special chemical for 6–12 hours. Soaking removes all organic growth, tarlike buildup, and scaling and eliminates odor. The procedure, normally accomplished every 60–90 days at other airlines, allows blue water to remain chemically effective longer. Every passenger airline in the world soaks aircraft toilets on a regular basis. FedEx Tech Ops established soaking procedures in 2015 after the need was identified by the FedEx ACP team. Before 2015, toilets had never been soaked at FedEx. The new FedEx procedure is now scheduled during aircraft heavy check, which is approximately once per year. Once per year is a big improvement over never, but still falls far short of industry-standards. And, the new FedEx toilet soaking procedure is not mandatory during heavy check. Some FedEx aircraft toilets have yet to be soaked after the toilet soaking procedure has existed for 1.5 years.
Second, blue water should be changed as often as necessary, depending on the volume of toilet use and other factors, such as warm weather. Passenger carriers with high volume use service toilets after every flight. For FedEx’s low-volume use, the chemical manufacturer recommends a blue water change once every 24 hours for reasons previously mentioned. FedEx Tech Ops’ standard for changing blue water is once every three days. In reality, toilets sometimes go un-serviced for days more. The three-day policy, which is contrary to the manufacturer recommendations, exists to save money. Not providing toilet servicing from an airport vendor at an outstation is also a money saving policy. The cost of blue water for one toilet, if supplied from FedEx inventory, is about $12. The cost if supplied by a vendor at an outstation is about $40.
Finally, toilet seats, shrouds, countertops, walls and the floor must be routinely cleaned and sanitized on an appropriate schedule. Passenger carriers clean and sanitize toilet interiors after every flight. We don’t need this frequency at FedEx, but it is obvious we need a frequency higher than we currently have.
FedEx offices are cleaned once per day and office toilets are cleaned and sanitized twice per day. It seems apparent that current FedEx aircraft toilet cleaning and sanitization procedures are inadequate and are the main cause of the foul and unsanitary toilet issues on many of our aircraft.
We all recognize and accept the obvious differences between our work environment and the typical office environment. But dirt, grime, bacteria, other pathogens and disgusting malodor should not be a difference we are expected to accept. Sacrificing employees’ personal hygiene by eliminating the most basic of cleanliness and sanitization practices for the sake of saving money is not tolerated in any other FedEx work environment, and it should not be happening in ours.
Here are two real-world examples with suggested ways to handle unacceptable toilet situations:
Toilet servicing: The Lavatory Service Record (LSR) is located in a multi-pocket grey pouch on the inside or outside wall of the toilet. You will find a date indicating when the toilet was serviced. The LSR only reports blue water change, not cleaning and disinfecting of toilet shroud and seat or LAV interior.
This Lavatory Service Record (LSxR) is from one of my recent flights. The lavatory had not been serviced for four days (16–19 May) and later had not been serviced for six days (20–25 May) preceding my flight. It was rancid. I called for a lavatory service immediately upon entering the cockpit. A service cart appeared under our aircraft in less than 15 minutes. I took a photo of the LSR with my FPR to document the dates, then later submitted the photo with an Insite ticket to document the unacceptable amount of time between toilet servicing.
Toilet mechanical failure: When you check the LSR upon boarding the aircraft, flush the toilet to make sure it’s working properly. At the very top of the toilet bowl, under the plastic shroud, there is a flush nozzle ring designed to distribute blue water 360 degrees to rinse human waste out of the bowl. When the flush nozzle ring is clogged or broken and blue water only flows over a portion of the bowl, human waste is not being removed from the unrinsed portion of the bowl. Besides being disgusting and unsanitary, this is a mechanical failure that requires an AML write-up. Not documenting all aircraft mechanical failures was a recent Flight Ops hot topic driven by the FAA. Most importantly, Maintenance can only fix what we report as broken.
This was my AML entry for a recent flush ring issue:
Flush ring in toilet is clogged or broken. Blue water only rinses less than half the toilet bowl when toilet flushed. Human waste cannot be rinsed from toilet bowl. Toilet has foul smell. Flush ring needs to be fixed.
Here was the AML resolution sign-off one hour after the above AML entry was received by Maintenance:
LAV serviced by vendor. Pressure adequate to properly flush. OK for service at this time.
According to the AML resolution, the broken flush ring was fixed with a blue water change. Upon receiving the AML resolution by e-mail, I submitted the original AML write-up and the AML resolution on an Insite ticket with this complaint:
Please see the attached AML write-up and sign-off resolution. The toilet flush ring was clogged or broken. The resolution was a blue water toilet service. This cannot fix the problem. That means the flush ring is likely still broken. I would like to open this original broken flush ring AML write-up. I believe someone needs to check the toilet to see if it works. The blue water must rinse 100% of the toilet bowl when the toilet is flushed. If it rinses less than 50%, as was the case with this toilet, human waste is never rinsed off of the unrinsed off of 50% of the toilet bowl. Besides being disgusting, this is unsanitary and unhealthy. Thank you for looking into this matter.
On June 21, this AML resolution was sent to me:
Removed and replaced LAV flush ring in Ref to MD-10 AMM 38-31-01-2. LAV flush checks normal. A/C OK for service.
One small victory for the team!
If we will simply take the time to document the issues, then follow up on resolutions, we can make a huge dent in fixing what’s wrong with hygienic and health issues in our work environment. We must be proactive and help ourselves. Look out for your crew and the next crew by timely and accurate AML reporting of dirty, un-serviced, malodorous or broken toilets. Guaranteed: If it’s not reported, it will not be fixed. Submit an Insite ticket because no data=no problem=no change. If we are unwilling to document reoccurring failures, we will never be able to resolve the issues. If reporting does not work, we need the situation well documented so other alternate channels can be engaged.
More about hand soap
We see signs in FedEx hallways telling us how important it is for our own health and the health of others to frequently wash our hands with soap and water. Yet soap and water was removed from 75 percent of our aircraft to cut costs. Hand washing is even more important for pilots who do not have the luxury of using toilets that are cleaned, sanitized and serviced daily, and who are exposed to toxic particulate matter (described in newsletter #3) on everything they touch in their work environment.
Hand sanitizers are no substitute for soap and water, according to this article by Purdue University. According to the Purdue article, “In terms of the regulations regarding food services, the Food and Drug Administration says hand sanitizers may be used as a supplement but not as a substitute for hand washing.” Also, see this article from the Minnesota Department of Health explaining why hand sanitizers cannot be used in a food service area (which we have) or this article from the Center of Disease Control and Prevention (CDC) explaining why hand sanitizers may not be effective on dirty or greasy hands or might not remove harmful chemicals (such as toxic particulate matter in our work environment).
Our office (the cockpit), our toilet, and our food are confined to an area the size of a modest walk-in closet. Our hands become coated with toxic particulate matter ever-present in our work environment. We use malodorous aircraft toilets that are not frequently cleaned and sanitized and may not have been serviced for days. Then, we are forced to eat our catering with our bare hands without the opportunity to first wash with soap and water. How can this inconceivable scenario be justified by anyone and how can it possibly be allowed it to continue?
Because non-pilots are protected by OSHA, this cannot happen to any other employee group at FedEx, or any other company in America for that matter. It should not be happening to us.
Besides the lack of soap and water on non-potable water aircraft, hand sanitizer is frequently stocked on potable water aircraft and soap is not, even though Tech Ops standards call for potable water aircraft to be supplied with liquid hand soap. This shortfall was identified in early 2013 by the FedEx Aircraft Cleaning Program and continues to exist today. For whatever reason, the team stocking the lavatories continue to make this mistake. It is not uncommon for long international flights to block out with no hand soap onboard.
The solution to these issues—proposed by the FedEx Aircraft Cleaning Program team in early 2013, is simple, logical and inexpensive. Today, every aircraft has a black rubber base attached to the lavatory shelf near the wash basin. On all aircraft, either hand soap or hand sanitizer is screwed into the base (but often the wrong one for the aircraft configuration). By simply adding a second base, and then instructing the lavatory restocking team to put one each of liquid hand soap and hand sanitizer in every lavatory, pilots always have what they need and can chose which to use. Adding one base to each aircraft and the problem is solved. If FedEx will not recharge the potable water systems and give us the most basic of industry standard hygienic considerations, we can use bottle water.
More on oxygen masks
How we help ourselves
As suggested in ESC newsletter #3: Captains should check the lavatory upon boarding the aircraft. First officers should do it as a backup when preflighting the cabin. The following recommended checks will take less than 20 seconds:
If you missed the important discussion on fume events and contaminated air, please read ESC newsletter #3. This is a reminder that fume events require an AML entry because they are caused by mechanical irregularities or failures. A flight safety report is also required per FOM 2.15 (but consider an ASAP report to make sure the FAA has the data required for their congressionally mandated database). Fume events and air contamination are serious, health threatening issues. Documentation is critical for all the reasons previously mentioned.
Recently, I exchanged an email and phone call from a female B-777 first officer. She complained that every time she slept in the B777 crew rest module, she gets a headache, watering nose (she describes as sniveling mess) accompanied by coughing and congestion. She said on more than one occasion the captain accused her of flying while sick and she needed to explain it only happens after being in the crew rest bunk. She says this pop-up illness subsides a few hours after leaving the bunk, then completely disappears within 24 hours. She asked me for any help in understanding what is going on. Other pilots have made similar complaints regarding the B-777 crew rest bunk.
Following my conversations with the first officer, I flew (jumpseat) on three B-777 aircraft and inspected the bunk area. On all three aircraft, I found the same situation that I suspect could be causing her symptoms. The main air exhaust vent in the bunk area is heavily coated with the fine dusty material. You can see the vent located under the bottom bunk in this photo and a close-up of the vent in this photo. Samples swabbed out of the vent with q-tips are shown here. What ever is in this dusty material cannot be good for anyone with allergies or respiratory sensitivities while sleeping in the crew rest bunk.
You would never see an air vent in this condition on a passenger airliner. This is probably something that can be corrected with basic housekeeping procedures. These photos and story were sent to Flight Ops senior management and we are waiting for feedback.
How did we get here and how do we get out?
I believe NASA gave us the answer after investigating the Challenger Space Shuttle disaster. NASA explained a root cause—the normalization of deviance, defined as “the gradual process through which unacceptable practice or standards become acceptable. As the deviant behavior is repeated without catastrophic results, it becomes the social norm for the organization.” If you have never seen this NASA presentation on the subject, it’s fascinating and well worth your time.
Pilots face hygiene issues and health threats every day at work that none of us—pilots or managers—would ever expose our family to. Health and safety threats and issues in our workplace could never exist in any FedEx office environment, thanks to OSHA, and should not exist for us, based on health and safety policy promises by FedEx executive leadership. Not only do these unacceptable conditions exist, we have come to accept them.
We can only reverse previously accepted social norms with pilot participation. The ESC, even with 100 percent backing of our MEC, cannot effectively fight this battle alone. We need your help beginning with first steps presented in this newsletter. If pilots will not participate we send one of two messages: Either nothing is wrong or we don’t care. Both messages will produce the same results. If it’s not important to you, it will not be important to management.
Our ALPA goal
On March 31, the ESC delivered a detailed briefing to FedEx senior leaders, including FedEx Legal. The briefing and issues of concern were reported in ESC newsletter #2. Next, the ESC appealed to Flight Ops management to put pilots back in the loop so we gain back some control of the environment we will spend our entire careers in. Here is the recap of the ESC proposal presented to FedEx leaders:
FedEx pilots do not have OSHA to guard basic hygiene and health rights guaranteed by federal law to every other industry employee in America. We can only depend on FedEx senior leaders to provide an acceptable work environment. The MEC continues to anticipate Flight Ops management’s favorable reaction to resolving hygiene, health and safety issues in our work environment.
The ESC continues to receive e-mails, texts and phone calls from pilots relaying individual stories about illnesses they suspect are or were related to contaminated air or wearing the oxygen mask. According to credible technical, medical and research data, there is good reason to be suspicious. The next ESC newsletter will provide information on adverse health conditions reportedly caused by contaminated air in the airline industry. Additionally, we will offer information from medical, technical, and scientific subject-matter experts on suggested actions if you suspect you are experiencing ill health effects due to air contamination.
The ESC is coordinating with a well respected medical research establishment to create a FedEx pilot health survey. It is widely known that adverse health effects caused by air contamination, oxygen mask use, and other environmental factors are grossly underreported in the airline industry because pilots are generally unaware. Our goal is to obtain a realistic database on how frequently pilots experience fume events or suspect adverse health reactions due to bio threats in our work environment. With data, change is possible.
Pilot feedback is critical to the success of this effort. Firsthand reports are a huge benefit for building our database. If you have a story, an opinion, a question, or a work environment issue you think should be addressed, please forward your comments to FedEx-ESC@alpa.org or call Bob Avery anytime.
About the FDX ALPA Environmental Standards Committee (ESC)
The ESC was established to foster acceptable hygiene and health environmental standards in our pilot workplace. The ESC mission is to research, document, report on, and positively impact health, safety, and hygiene related environmental threats and issues that exist on board the aircraft we fly. We will work in a diligent, responsible, and professional manner with a sharp focus on our reason to exist—guarding the health and wellness of every FedEx pilot, every day they fly.
July 25, 2016
From: Capt. Bob Avery, Environmental Standards Committee Chairman
- Use of insecticides onboard FedEx aircraft
- Insite reporting—a perfect example of what we need to do
- Update of discussions with the Company
The ESC is jumping over the next promised subject—medical and research information regarding reported adverse health conditions caused by contaminated air, to discuss the use of insecticides onboard our aircraft. This information will be coming soon.
The following incident recently happened to me and will continue to happen to others until safety procedures are created and implemented. I believe my ASAP report (following) will sufficiently explain the issue. Hopefully, this report will provide international crews useful insight and guidance for avoiding a potentially hazardous health threat in our work environment.
ASAP Report ID: 30027
Date: 18 July 2016 (Z)
FDX Flight 77, HNL-SYD
Submitted by: Capt. Bob Avery, MEM MD11
During flight preparation, just prior to closing up the aircraft for block out, a cabin smoke alert illuminated in the cockpit. Less than 30 seconds later, a pungent odor filled the cockpit. The captain went to the cabin area to investigate and found the smell to be more intense with a light fog present in the air. The captain queried the ramp agent present in the courier area and was informed that insecticide had just been sprayed on the upper cargo deck. This explained the cabin smoke alert. Because the cockpit odor was intense, the captain turned the packs off and instructed the other two crew members to deplane. After 15 minutes the smell was still present in the courier area but had dissipated in the cockpit. The crew resumed normal duties.
The APU was running and all three packs were on when the ramp crew sprayed the insecticide in the cargo areas. The crew presumed the strong odor in the cockpit and jumpseat area occurred when the aircraft ventilation system circulated the insecticide sprayed in the upper cargo deck. The crew was not notified when the upper cargo deck was sprayed, which is normal, given there are no procedures for crew notification.
The ramp agent on board our aircraft informed the captain this incident was not uncommon and another crew had recently evacuated the aircraft because a fog and pungent smell filled the cockpit and cabin after insecticide was sprayed.
Within 30 minutes of the crew’s exposure to the insecticide spray, the captain experienced a tightening of the throat and sneezing. The relief flight officer experienced irritated nostrils. The first officer did not experience symptoms.
The insecticide spray used in FedEx aircraft cargo compartments for all HNL-SYD flights is Callington 1-Shot (Callington is the manufacturer). Besides Honolulu and Sydney, disinsection is also required for Columbia, New Zealand, Penang and Curacao, according to the FOM.
The attached 1-Shot material safety data sheet (MSDS) warns of potential health hazards associated with the product. Two chemicals in 1-Shot, d-phenothrin and permethrin, are toxic and potentially hazardous to human health, according to OSHA and the World Health Organization (WHO). Permethrin is the most toxic of the two chemicals. Both d-phenothrin and permethrin are listed as probably carcinogens by the International Agency for the Research of Cancer.
Attached documents disallow spraying of permethrin insecticides when human contact is at risk, except when specified protective measures are used. Permethrin products should never be inhaled, according to medical and technical documents, including those attached. The attached 1-Shot MSDS warns to avoid personal contact with the product and advises that protective clothing and equipment, including a respirator, should be used by personnel dispensing the product when risk of inhalation or dermal exposure exists. The 1-Shot MSDS contains a number of other warnings.
The attached WHO document, Recommendations on the Disinsecting of Aircraft, states, “The flight deck should be treated at a suitable time prior to the expected occupancy of the flight crew, the door of this compartment then being closed and kept closed, except when being opened momentarily to permit the passage of the crew members, until the ‘blocks-away’ (pre-flight) treatment and the take-off of the aircraft are completed.” This blocks-away procedure is not accomplished on the HNL ramp. Only the pre-flight treatment is accomplished—and with the crew onboard.
According to the attached WHO document, the aircraft ventilation system must be closed during pre-flight spraying, and for a period of not less than five minutes following dispensing of sprays containing permethrin.” Section 5.1 of the attached document, Schedule of Aircraft Disinsection Procedures for Flights into Australia and New Zealand, states the same minimum 5-minute warning. According to the manufacturer of 1-Shot, the ventilation system should be off for 10 minutes following spraying of this product. This time warning exists because 1-Shot is heavier than air and is designed to settle onto surfaces in undisturbed air. Settling onto surfaces mitigates the risk of inhalation when the aircraft ventilation system is turned on after spraying. If the product is drawn into a packs-on air system, the spray circulates to all areas, including the cockpit.
The WHO has describe disinsection as a procedure that would not cause risk to human health “if carried out with the recommended precautions,” according to the attached Airline Cabin Environmental Research (ACER) document. This document states that adverse health effects have been reported by flight crews and that urine tests conducted on flight crews where disinsection was performed showed significantly higher levels of associated toxic chemicals after disinsection flights. Additionally, the document states, “The risks to crewmembers and the flying public associated with exposure to pyrethroids (permethrin) at the levels (stated within the document) need to be reviewed.” (ACER is funded through an FAA Cooperative Agreement entitled “National Air Transportation Center of Excellence for Research in the Intermodal Transport Environment”).
Over the past year, I have communicated my concerns on this subject to appropriate FedEx managers in MEM and HNL. HNL personnel I have spoken with say they have never been given training, advised of warnings or received procedural information for spraying insecticides onboard aircraft, except where to discharge the cans. This was confirmed again on July 18, the day of this incident. Additionally, pilots have never been given safety information regarding aircraft disinsection procedures.
The fact that ramp and flight crews have never received safety information is concerning. It is especially concerning for ramp crews because the same people are exposed to this safety threat every day over a period of years. Publishing readily available safety procedures and warnings would mitigate risks associated with aircraft disinsection, thus protect the health and safety of FedEx personnel—an action that seems necessary given commitments within our FedEx Safety Management System.
In the interest of health and safety for flight and ground crews, I recommend that FedEx Flight Safety and/or Ground Safety prepare and deliver information on the use of insecticides onboard our aircraft.
Note: I am aware of Callington 1-Shot dispensing recommendations and health and safety warnings regarding aircraft disinsection due to my former work with the FedEx Aircraft Cleaning Program and current work with the ALPA Environmental Standards Committee (ESC). Information I have obtained comes from government sources, technical and medical sources, speaking directly with Callington (the manufacturer) representatives, and a number of conversations with HNL ramp managers and ramp crew members.
(End of ASAP report)
To arm you with information on your next disinsection flight, here is a photo of Callington 1-Shot Aircraft Insecticide used by FedEx to spray all cargo holds, including the top deck. 1-Shot is always in this red can.
This is a photo of Callington Pre-Spray, used by FedEx to disinsect the aircraft cockpit and courier area. The Callington Pre-Spray Technical Data Sheet states, “A preflight spray must be applied to the flight deck, all toilet areas (including upper deck where applicable), lockers and crew rest areas before crew and passengers board.” At FedEx, Pre-Spray is dispensed when crew members are onboard. Pre-Spray is always in this green can.
Here is an August 2016 news article about the U.S. Air Force disinsecting cargo aircraft to fight the Zika virus. The Staff Sergeant in the photo is spraying 1-Shot—the same product used by FedEx, according to the story. Note that he is equipped with the proper protection, as specified in the 1-Shot MSDS—gloves, coveralls and a respirator. The article states, “After spraying, the aircraft are sealed for 20 minutes, then ventilated before crew can enter without respirators. The Air Force is diligent about following all safety procedures, according to this article.
Here is a photo of a FedEx ramp crewmember spraying 1-Shot in the upper deck of a FedEx aircraft. Not only is the ramp crew member wearing a t-shirt and shorts and using no safety equipment, he is standing in the middle of the fog created by the three cans he is discharging. This is especially concerning because HNL ramp personnel spray these products every day over a period of years. Additionally, the spray is not being distributed through the length of the cargo compartment, as attached documents specify should be done.
In no way is the ALPA ESC attempting to create or modify any FedEx procedure with this newsletter. That said, we recommend pilots consider these steps to guard your own health and safety on disinsection flights:
- Make a request to the ramp manager and load team to notify the crew before insecticides are sprayed and when spraying is complete on the upper cargo deck.
- Before spraying commences, make sure the packs are off and the cockpit door is closed, and remains closed, for at least 10 minutes after disinsection is complete.
- If spraying of insecticide results in a strong odor in the cockpit, consider deplaning until the odor dissipates.
Even this precaution may fall short of published procedures, but it’s a start.
Given the numerous safety procedures and warning in the attached documents, the ESC believes this is a serious matter that should be addressed immediately. The cost of implementing changes is very low for FedEx while benefits for flight and ramp crew members are very high.
If you are directly exposed to insecticides during an aircraft disinsection event, the ESC strongly recommends submitting an ASAP report. Besides notifying FedEx Flight Safety and the FAA of unsafe operations (a FOM 2.15 requirement), the ASAP will serve as a record of exposure in the event you suffer medical consequences from the spray.
Insite reporting – a perfect example of what we need to do
During cabin preflight, a pilot on a recent MEM-NRT flight opened the paper towel dispenser door in the lavatory during his search for hand soap. He found these paper towels, which were covered with grease and dirt—apparently from the person’s hands who installed the towels in the holder. The pilot asked these valid questions: Who thinks it’s okay to handle clean paper towels with such filthy hands? Did this same person also handle the coffee pot or touch the galley with the same filthy hands? The seats? The bedding materials? Did he stock the ice chest? Did this person connect and operate the toilet servicing cart before all the above? These and more cross contamination questions come to mind regarding proper training for personnel servicing our lavatories, ice chests and catering. (By the way, the pilot reported there was no hand soap on the airplane.)
The pilot submitted an Insite report with the photo, which is exactly what we must do if we expect to achieve reasonable hygienic and cleanliness standards. Management cannot fix what they don’t know about.
Remember: No data = no problem = no change.
Many thanks to this pilot and all pilots who have taken the time to file Insite reports for environmental standards issues. Every report takes us one step closer to acceptable hygienic conditions in our work environment. The more reports filed, the faster we will get there. If you have not read the Insite report discussion in ESC newsletter #4 (What we can do to help ourselves), please do so.
Update of discussions with the Company
FDX ALPA leadership recently received word that FedEx will conduct air testing on our aircraft. It is encouraging to report that the ALPA ESC has been invited to participate in this testing, with consultation from the industrial hygienist who serves as our subject matter expert.
We need your feedback
If you have a story, question or comment on aircraft disinsection or any other work environment issue, please send it to FedEx-ESC@alpa.org or call/text ESC Chairman Bob Avery. We continue to receive a lot of valuable information from pilots who are engaged. This recent proactivity has been a tremendous help in supporting our efforts. We cannot do this alone.
About the FDX ALPA Environmental Standards Committee (ESC)
The ESC was established to foster acceptable hygiene and health environmental standards in our pilot workplace. The ESC mission is to research, document, report on and positively impact health, safety and hygiene related environmental threats and issues that exist on board the aircraft we fly. We will work in a diligent, responsible and professional manner with a sharp focus on our reason to exist—guarding the health and wellness of every FedEx pilot, every day they fly.
August 18, 2016
From: Capt. Bob Avery, Environmental Standards Committee Chairman
Newsletter #6: More on use of insecticides onboard FedEx aircraft
Since releasing newsletter #5 (25 July 2016)—Use of insecticides onboard FedEx Aircraft, the ESC has received a number of inquiries and stories from pilots regarding aircraft disinsection. Pilots are asking the difference between the red spray cans used by ramp crews in cargo areas and the green spray cans given to pilots for spraying the courier/galley area. Some are asking, “What are the procedures?” This newsletter addresses new questions and concerns and expands on previous information concerning FedEx aircraft disinsection procedures.
If you have not done so, read ESC newsletter #5 first so this new information will be better understood.
Aircraft disinsection basics
Aircraft disinsection involves specific government mandated procedures incorporating the latest recommendations and practices of recognized bodies, such as the World Health Organization (WHO) and the International Civil Aviation Organization (ICAO).
All information in this newsletter refers to FedEx disinsection flights originating from Honolulu and destined for Sydney or Auckland. FedEx disinsection flights to other countries routinely occur, but any differences in procedures are not discussed in this newsletter.
From all information available, it seems apparent that handling, dispensing and being exposed to limited amounts of approved insecticides are reasonably safe, as long as established procedures and safety warnings are adhered to. Conversely, it seems apparent that misusing the product, using improper application procedures, or ignoring published safety warnings could create unnecessary health and safety risks for personnel dispensing or exposed to the active chemicals.
Most aircraft disinsection aerosols use one or both of two chemical active ingredients—permethrin (2%) and d-phenothrin (2%), depending on the treatment to be accomplished. Both chemicals can be toxic to humans if misused or if safety warnings are not observed. Permethrin and d-phenothrin are currently recommended by the World Health Organization for aircraft disinsection and meet ICAO guidance. Insecticides used by FedEx in HNL use one or both of these active ingredients, depending on where the insecticide is sprayed.
The Australian government document Schedule of Aircraft Disinsection Procedures for Flights into Australia and New Zealand lists options available to airline operators to meet Australian and New Zealand cabin and cargo hold disinsection requirements. FedEx uses the Pre-Embarkation Disinsection (PED) option—spraying of the internal surfaces of an aircraft at the last overseas port. This treatment is designed to last for the duration of a single flight sector. PED spraying is to be carried out using permethrin in the cockpit and courier/galley area, before passengers and flight crew board the aircraft. Both permethrin and d-phenothrin are required in all cargo holds when PED procedures are used.
FedEx uses Callington Pre-Spray and 1-Shot for aircraft disinsection (Callington is the manufacturer). Each insecticide is designed for a specific purpose and carries its own procedures, risks and safety warnings.
1-Shot in the red can is a residual insecticide containing both permethrin and d-phenothrin as active ingredients. 1-Shot is designed for disinsection of all cargo holds (including the upper cargo deck) after loading is complete and just prior to block-out.
Pre-Spray in the green can is a residual insecticide containing permethrin as the active ingredient. Ramp agents give Pre-Spray to FedEx flight crews before departure for spraying the cockpit and courier/galley area after doors are closed and before landing.
Callington Pre-Spray for cockpit, courier/galley area treatment
Disinsection must be accomplished in the cockpit, cabin area, and all cargo holds on every Australia or New Zealand bound flight, according to the Australian government.
Callington Pre-Spray is designed for pre-embarkation disinsection, but not the way the task is being accomplished at FedEx. HNL ramp agents give one can of Pre-Spray to pilots before closing the aircraft. Pilots have been given varying verbal instructions, such as: spray the product after closing the cabin door, or spray the product at top of descent, or spray sometime before landing—then have the empty can accessible for the Australian Agriculture inspector at block-in as proof of spraying. There are no FedEx published procedures for dispersing Pre-Spray.
Section 3.2 and 4.1 of Schedule of Aircraft Disinsection Procedures for Flights into Australia and New Zealand state that pre-embarkation spraying (with active ingredient permethrin) must be conducted in the absence of passengers. This includes the flight crew, according to the WHO and the manufacturer. Procedures also state that during disinsection, and for a period of five minutes after the completion of the spray, the aircraft’s air-conditioning (packs) must be off. (Note: Callington, the manufacturer of Pre-Spray, recommends that the air system be off for 10 minutes.)
The Callington Technical Data Sheet and the Material Safety Data Sheet (MSDS) for Pre-Spray list a number of risks, warnings and health concerns including: avoid all personal contact including inhalation and, preflight spray must be applied to the flight deck, all toilet areas, lockers and crew rest areas before crew and passengers board. Pilots operating disinfection flights should take a few minutes to read these two documents for their own protection.
According to the Australian Department of Agriculture, 10 grams of residual insecticide (such as Pre-Spray) should be sprayed per 1,000 cubic feet of space to be disinsected in aircraft cabin areas when using pre-embarkation procedures.
Concern: There are no published procedures, risks or warnings for in-flight disinsection by flight crews.
Concern: According to the manufacturer, Pre-Spray should not be used when crewmembers are onboard, but should be used in accordance with WHO, ICAO and Australian Department of Agriculture disinsection guidance, which instruct use in the absence of passengers or flight crew.
Concern: According the the manufacturer (Callington), FedEx is using the wrong product for inflight spraying by pilots. Pre-Spray, the product being used, carries a number of safety warnings including to avoid all personal contact, including inhalation, and that spraying must be done before the flight crew board.
Concern: According to the Australian Department of Agriculture, and the manufacturer, the amount of Pre-Spray needed for the courier/galley area of the MD-11 is approximately 10 grams. However, this amount is based on using the proper procedures, which include spraying in the absence of passengers and crew. The Pre-Spray canister given to pilots for spraying inflight contains 100 grams of insecticide. It appears that flight crews are overdosing themselves by 10 times with an insecticide not designed for inflight use and carrying the warnings mentioned above.
Callington 1-Shot for cargo hold disinsection
The following is a partial list of pre-flight cargo hold disinsection procedures from section 5.1 and 5.3 of Schedule of Aircraft Disinsection Procedures for Flights into Australia and New Zealand. 1-Shot is used for this procedure at FedEx.
Note: Section 3.9 of this document states: Any area within a freighter that carries cargo is classified as a hold and should meet the hold disinsection requirements as specified in section 5 (of the above-mentioned document); this includes the main cargo deck.
- Spraying must be completed using 2% permethrin and 2% d-phenothrin as the active ingredients. (FedEx uses 3 cans of 1-Shot on the upper cargo deck which is consistent with Australian government requirements.)
- Advise the crew that hold spraying is about to commence. Aerosols can set off the smoke alarms, so it is vital that the crew are fully aware prior to any disinsection taking place. (There is no FedEx procedure to notify crews)
- During disinsection and for a period of five minutes after completion of the spray, the aircraft’s air conditioning must remain off. (Callington, the manufacturer of 1-Shot recommends that the air system be off for 10 minutes.)
Callington Technical Data Sheet and the Material Safety Data Sheet (MSDS) for 1-Shot used for spraying cargo holds contain important procedures, risks and safety warnings. Pilots operating disinsection flights should take a few minutes to read these two documents for their own protection.
Concern: There are no published procedures for ramp crews who spray 1-Shot or pilots who are exposed to 1-Shot during disinsection procedures. From information gathered, pilots are frequently exposed to inhalation of the insecticide when it is sprayed with the APU and packs on.
Because adverse health effects caused by toxic substances in these sprays can be cumulative, the issue is concerning for pilots who frequently operate disinsection flights.
Reports completed by flight crews (outside of FedEx) have suggested the possibility of the onset of symptoms in passengers and crewmembers as a consequence of pyrethroid application. The reported symptoms varied from metallic taste; slight and nonspecific irritation of eyes, throat, and upper respiratory tract; and, in some cases, skin, to severe respiratory symptoms such as dyspnea, cough, and even asthma. In other cases, headache and allergic reactions were reported (World Health Organization 2013).
When people get permethrin on their skin, they may have irritation or tingling, burning and itching at that spot. If permethrin gets in the eyes, it can cause redness, pain, or burning. People who have inhaled permethrin have had irritation in the nose and lungs, difficulty breathing, headaches, dizziness, nausea, and vomiting (National Pesticide Information Center).
When d-phenothrin gets on the skin, it can cause skin sensations like tingling, itching, burning, or numbness at that spot. D-phenothrin can also be mildly irritating to skin and eyes. Reported symptoms from inhaling d-phenothrin are rare, but can include nausea, vomiting, throat irritation, headaches, and dizziness (National Pesticide Information Center).
If you are directly exposed to insecticides during an aircraft disinsection event, the ESC strongly recommends submitting a detailed ASAP report. Besides notifying FedEx Flight Safety of unsafe operations (a FOM 2.15 requirement), the ASAP report will serve as a record of exposure in the event you suffer adverse medical consequences from the spray. If you experience adverse health consequences that last longer than the flight, the ESC recommends that you seek medical attention as soon as possible.
Important repeat from ESC newsletter #5
In no way is the ALPA ESC attempting to create or modify any FedEx procedure. That said, we recommend pilots consider these steps to guard your own health and safety on disinsection flights:
- Early in the predeparture process, make a request to the ramp manager and load team leader to notify the flight crew before cargo area disinsection begins and when spraying is complete.
- Before cargo hold spraying commences, make sure the packs are off and the cockpit door is closed, and remains closed, for at least 10 minutes after the procedure is complete.
- If spraying of insecticide in cargo holds results in a strong odor in the cockpit, consider deplaning until the odor dissipates.
- If the ramp agent gives the flight crew Pre-Spray in the green can for inflight disinsection, question the procedure and ask for a disinsectant designed to be sprayed in flight. (Callington makes a product called “Top Of Descent” for inflight spraying prior to arrival.)
Other FedEx aircraft disinsection around the world
FedEx disinsection occurs on ramps other than HNL. It is assumed other procedures are similar to Australia and New Zealand procedures because most countries following WHO and ICAO recommendations. Until procedures, cautions and warnings are published at FedEx, it would behoove pilots to pay close attention when operating any disinsection flight. This means reading the references listed in this newsletter and raising a red flag if proper procedures are not followed. In the end, it’s your health at risk.
Insite—ASAP—AML (with photos, when able)
We cannot do this alone. The voice of the crew force is required.
Remember: No data = no problem = no change.
We need your feedback
If you have a story, question or comment on aircraft disinsection or any other work environment issue, please send it to FedEx-ESC@ALPA.org or call/text ESC chairman Bob Avery. We continue to receive great questions and valuable information from pilots who are engaged. This helps the process immensely. Recent proactivity has been a tremendous help in supporting ESC efforts.
About the FDX ALPA Environmental Standards Committee (ESC)
The ESC was established to foster acceptable hygiene and health environmental standards in our pilot workplace. The ESC mission is to research, document, report on, and positively impact health-, safety-, and hygiene-related environmental threats and issues that exist onboard our aircraft. We will work in a diligent, responsible, and professional manner with a sharp focus on our reason to exist—guarding the health and wellness of every FedEx pilot, every day they fly.
Review ESC newsletter #1 (introduction of ALPA ESC Committee)
Review ESC newsletter #2 (report on March 31 ALPA briefing to FedEx)
Review ESC newsletter #3 (discussion of environmental issues and threats)
Review ESC newsletter #4 (helping ourselves)
Review ESC newsletter #5 (use of insecticides onboard FedEx aircraft)
References for information provided in this newsletter:
Schedule of Aircraft Disinsection Procedures for Flights into Australia and New Zealand
(version 4.0) Australian Dept. of Agriculture and Water Resources
Australian Dept. of Agriculture and Water Resource aircraft disinsection website
Analysis and Implications of Aircraft Disinsectants (C. van Netten)
ACER Quantifying Exposure to Pesticides on Commercial Aircraft (Feb 2012)
Aircraft Disinsection Insecticides (World Health Organization 2013)
National Pesticide Information Center – Permethrin Fact Sheet
National Pesticide Information Center – d-Phenothrin Fact Sheet
We will live forever with the standards we accept today. Fly safe and fly healthy,
Capt. Bob Avery