An Analysis of Cabin Ozone Regulations

Main Article Content

Taylor Pottinger
Cheryl Lynn Marcham

Abstract

Exposure to elevated levels of ozone have been reported to be associated with complaints of discomfort such as dry mouth, eye irritation and dryness, nasal irritation coughing, and headaches.  The Federal Aviation Administration (FAA) established regulatory requirements in 1980 to limit cabin ozone levels to no more than 0.25 parts per million (ppm) at any time or 0.1 ppm averaged over a 3-hour interval for any flight over four hours in length.  The FAA also published an Advisory Circular (AC), AC 120-38, to provide guidance to air carriers on how to comply with these then new ozone regulations. Methods of compliance include the use of catalytic converters, or ozone filters, designed to remove ozone, utilizing statistical methods to prove that ozone concentrations will not exceed limits for the carrier’s route structure and flight planning to avoid areas of reported high concentrations of ozone. The calculations used to determine cabin ozone concentration from manufacturer’s filter efficiency data and ozone levels are to be based on published ozonesonde data found in the AC 120-38 or an equivalent data set. 

Unfortunately, the published ozonesonde data in the AC 120-38 are outdated and the AC does not point to any other data source that is acceptable to the FAA to conduct the required statistical analysis. In addition, once compliance is shown, no follow-up measurements are required to ensure that ozone levels remain below these required levels.  Actual ozone concentrations have been measured in the aircraft by several researchers that exceed these regulatory levels. Finally, FAA ozone regulations and AC 120-38 do not address cumulative effects of ozone exposure to crewmembers over multiple flights and do not offer any protection against ozone exposure for crewmembers on non-passenger carrying flights. A revision of federal regulations to afford protection to all crewmembers, account for cumulative effects, and updated compliance methods that rely on current ozonesonde data and periodic ozone monitoring should be accomplished to ensure crewmembers are not subjected to ozone levels that could potentially result in serious health concerns.

Article Details

Section
Literature Reviews
Author Biographies

Taylor Pottinger, Embry-Riddle Aeronautical University

Ms. Pottinger currently works as a flight follower for Hillwood Airways, a Part 121 Supplemental airline, based out of the Fort Worth Alliance airport, and is also working towards her Master of Science degree in Occupational Safety Management from Embry-Riddle Aeronautical University.Ms. Pottinger was hired by Hillwood Airways while they were still undergoing Part 121 airline certification with the Federal Aviation Administration (FAA). She participated in the FAA’s proving and validation tests, commonly referred to as “table tops†and “proving runsâ€, and was a valued member of Hillwood Airway’s airline certification team.

Prior to her career at Hillwood Airways, Taylor obtained her Bachelor of Science degree in Air Traffic Management from LeTourneau University in 2016. During her time at LeTourneau, she tutored students in various aviation courses and worked as a Lab Assistant in Tower, Radar and Advanced Air Traffic Control labs. During her college years she also obtained her private pilot license and aircraft dispatcher license.

Ms. Pottinger became interested in ozone regulations and the adverse health effects associated with ozone after comparing federal aviation regulations to what she was learning in her safety courses from Embry-Riddle. From her research she determined that current aviation ozone regulations need to be adjusted to reflect current knowledge of how ozone can adversely affect the human body.

Cheryl Lynn Marcham, Embry-Riddle Aeronautical University

Cheryl L. (Cheri) Marcham, PhD, CSP, CIH, CHMM, FAIHA is an Assistant Professor and Program Chair for the Master of Science in Occupational Safety Management in the College of Aeronautics Worldwide Online Campus for Embry-Riddle Aeronautical University.  She was previously the Environmental Health and Safety Officer for a major university for over 25 years.  She holds a B.S. in Biology from Arizona State University, and an M.S. and Ph.D. from the University of Oklahoma Health Sciences Center Department of Occupational and Environmental Health.

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