Protection from Ionizing Radiation – Position paper

Entry posted on Friday, May 31st, 2019 at 10:54 pm by admin

The airline pilot operates in an environment with exposure to circadian dysrhythmia, chronic fatigue, reduced atmospheric pressure, mild hypoxia, low humidity, and exposure to sound, vibration, radiation (both ionizing and non-ionizing), and electromagnetic fields. These occupational exposures present physiological challenges to their long-term health.
In particular, exposure to ionizing radiation and its carcinogenic/mutagenic potential has received considerable attention. Whereas annual exposures for ground-based radiation workers have been successfully reduced, airline flight crew exposures remain at levels substantially above those of other radiation-exposed workers and are increasing with modern flight operations.

NOTE
While this Position Paper is specific to ionizing radiation, exposure to non-ionizing radiation such as UV-A rays as well as high-energy visible light are increasingly suspected to have adverse health effects on skin and eyes.
This ECA Position Paper closely adheres to the IFALPA position 18POS02 while emphasizing the more comprehensive and legally binding aspects of European jurisdiction compared to UN (ICRP) recommendations.

INTRODUCTION
Despite the international recognition that cosmic radiation poses a workplace health risk to airline pilots, there is an immediate requirement for comprehensive research into all forms of radiation exposures of airline pilots. Keeping in mind the complexity of exposures in the cockpit environment, this Position Paper endeavors to provide for the protection of flight crews with respect to the potential health risks of ionizing radiation exposure.
The International Commission on Radiological Protection (ICRP) is the recognized international body that develops the principles, philosophies, and policies for radiological protection. The guidance for a generic system of radiological protection was published in ICRP Publication 103 in 2007 and specifically for aviation in ICRP Publication 132 in 2016.
Even more importantly, in 2013, the Council of the European Unionissued their current legal framework, the EU Council Directive 2013/59/EURATOM of 05 Dec 2013 (the “2013 EURATOM BSS“). These Basic Safety Standards are to be implemented into national law of the EU Member States by the end of 2018.
These documents make the cornerstones for the ECA position.

The International Federation of Air Line Pilots’ Associations (IFALPA) recommends the EURATOM BSS as an exemplary legal framework to its Member Associations across the globe.
ECA POSITION

  1. Flight crew radiation protection should be categorized as a planned exposure situation
    Where ICRP Publication 132 recommends that the exposure of aircraft crew should be treated as occupational exposure in an existing exposure situation, the European Council encourages its Member States to categorize aircrew work as a planned exposure situation, leading to a full classification as planned exposure e.g. in Germany. (EU BSS Intro (26), German StrlSchG)
    Within Europe, there is an exceptional opportunity to be a role model and categorize aircrew exposure as a planned exposure situation in national legislation. ECA recommends therefore the national authorities to follow the EURATOM proposition.
  2. Flight crew should be recognized as Category A occupationally exposed workers
    Flight crew with an effective dose of more than 1 mSv per year should be recognized as occupationally exposed to ionizing radiation. Those who are liable to receive an effective dose greater than 6 mSv per year should be classified as Category A workers. (Art. 401)
    This allows for better individual dose monitoring and closer medical check-ups. (Art. 41(1), 44(6) and 452)
  3. Optimization and dose minimization
    Initial dose reference levels for all flight crew in each fleet should be set at 6 mSv per year. Flight crew radiation exposure doses should be individually monitored and optimized to As Low As Reasonably Achievable (ALARA), even if the reference level is not exceeded.
    Reference levels should only be increased:
    • where an appropriate statistical analysis demonstrates a sound application of optimization principles and minimization techniques to reduce both the average annual effective dose and the variation in annual effective doses as increments of 1 mSv.
  4. Cumulative radiation dose assessment and recording for flight crew members
    Operators should produce individual annual dose records to which flight crew members should have regular access on a permanent basis, unless competent analysis shows that no flight crew member will be exposed to inflight radiation of 1 or more mSv per year.
    Exposures caused by energetic particle events (e.g. solar particle events) must be taken into account in dose assessments. (Art 35(3)a).
    To allow a better comparison with cancer statistics and facilitate epidemiological studies in the future, dose and medical records – obtained through applicable regulation (and thus containing de-identified data only) – should be kept until the greater of:
    1. 2013/59/EURATOM
    2. 2013/59/EURATOM