This paper examines the challenge of implementing Occupational Safety and Health Administration (OSHA) regulations in the aircraft cabin environment. It traces the history of the FAA-OSHA Memorandum of Understanding signed in 2000, the Aviation Safety and Health Team's findings, and the persistent jurisdictional gap that leaves flight attendants without standard workplace protections. The paper identifies key hazards facing cabin crews — including slips and falls, fire, poor air quality, infectious disease, and noise — and analyzes why neither the FAA nor OSHA has successfully enforced safety standards for in-flight workers. It concludes by proposing the creation of a dedicated aviation safety authority to resolve the bureaucratic impasse.
The problem of crew safety in aircraft was taken up seriously after the September 11, 2001 attacks. Before that, the protection of workers was largely a formal declaration. Intrusions into aircraft prompted a second look at crew working conditions. For many years, flight attendants have faced significant voluntary occupational health hazards, and aircraft cabins have been very dangerous workplaces. In August 2000, Jane Garvey, the Administrator of the FAA, and Charles Jeffress, the OSHA Assistant Secretary, signed a Memorandum of Understanding (MOU) that directed the FAA and OSHA to "establish a procedure for coordinating and supporting enforcement … with respect to the working conditions of employees on aircraft in operation … and for resolving jurisdictional questions" ("FAA-OSHA Jurisdiction," 2007). The matter was also taken to court by staff over failure to ensure crew safety. The suit was filed in 2005 by the AFA and sought directions for the FAA to implement healthy working conditions for cabin crew ("FAA-OSHA Jurisdiction," 2007).
The Occupational Safety and Health Administration (OSHA) and the Federal Aviation Administration (FAA) established a joint team known as the "Aviation Safety and Health Team" in the year 2000 ("FAA/OSHA: Aviation Safety and Health Team — Action Plan," 2002). The task of this team was to identify which "OSHA requirements could be applied to the working conditions of employees on aircraft in operation (other than flight deck crew) without compromising aviation safety" ("FAA/OSHA: Aviation Safety and Health Team — Action Plan," 2002). The team produced a report identifying seven areas of concern pertaining to flight attendants. They were, however, uncertain about the applicability of OSHA regulations due to a lack of empirical data, and recommended that airline operators enter into voluntary agreements with the FAA regarding these issues. It is worth noting that OSHA has successfully implemented such programs in other industries ("FAA/OSHA: Aviation Safety and Health Team — Action Plan," 2002).
In March 2007, the FAA issued a policy authorization clearly stating that the U.S. aviation industry provides over ten million jobs and that, on account of terrorist activity and disease, there was a need to revamp existing norms — potentially requiring treasury funding. One important issue noted was the overwork of personnel resulting in inadequate rest for pilots and cabin crew. As one report observed, "The safety of the aircraft cabin is critical for both flight attendants and the traveling public. For flight attendants, the aircraft cabin is their workplace. Unfortunately, these workers are not afforded common workplace safety standards as are most other U.S. workers" ("FAA Reauthorization: Opportunity to Enhance Aviation Safety and Protect U.S. Workers," n.d.). The FAA reauthorization bill, in effect since March 4, 2007, was created with the aim of clearly establishing guidelines for cabin safety covering all issues pertaining to employee health, safety, injury, and emergency requirements ("FAA Reauthorization: Opportunity to Enhance Aviation Safety and Protect U.S. Workers," n.d.).
Cabin crews are among the highest-risk workers in any industry, and the hazards they face may also affect passengers. Accidents in flight can result from slippery floors, tripping over baggage, falling during air turbulence or on stairways, and falling from open aircraft doors. One of the greatest hazards in aircraft cabin work environments is injuries caused by tripping or falls; one study found that twenty-two percent of accidents occurred through such mishaps (United Kingdom Civil Aviation Authority, 2005).
Addressing this risk requires coordinated action from aircraft crew, maintenance teams, and manufacturers. "The design of the cabin environment, particularly flooring and fall prevention systems at exits, should reduce the potential for slips, trips, and falls occurring." While airlines are directed to provide safe installations and periodic checks to reduce risks — including accounting for seasonal climate conditions — OSHA regulations remain non-mandatory in this context. "Many States have approved OSHA plans, which may be more restrictive" (United Kingdom Civil Aviation Authority, 2005). When an accident occurs on the ground, OSHA regulations apply; however, they may not apply in a foreign country or in the air.
Other hazards include fire and inadequate firefighting equipment, both of which are commonly neglected. Fires can break out on the runway or inside the aircraft, leaving personnel to combat fire with limited means while simultaneously protecting passengers (United States Congress House, 1985). Hazards extend beyond fire to include smoke, emissions, and poor cabin air quality, which pose serious health risks. Bacteria and fungal infections are potentially present in cabins due to the vast volume of human transit (Nagda, 2000). The effects of reduced oxygen, low humidity, ozone, fumes, altitude, and infectious diseases — most notably demonstrated during the outbreak of Severe Acute Respiratory Syndrome (SARS), which spread rapidly on aircraft — together create a multidimensional set of concerns (Spengler & Wilson, 2003). Load factors in aircraft have increased and trip delays have grown more common; average trip lengths in the U.S. have grown to approximately three thousand miles. The aircraft cabin differs from a normal office in that it is pressurized, densely occupied, and exposed to a range of environmental contaminants (Committee on Air Quality in Passenger Cabins of Commercial Aircraft, Board on Environmental Studies and Toxicology, National Research Council, 2002).
OSHA regulations are not applicable to all employees in the aircraft industry. Proper vaccinations, protective equipment requirements, and exposure training are not mandated for cabin crew — though they should be. Noise-exposure testing requirements under OSHA standards should be applied to cabin staff. Sanitation hazard communication policies and guidelines should likewise apply to cabin crew, which would make flights safer and reduce injuries. The current exclusion of flight crew from these protections arguably violates OSHA anti-discrimination provisions ("FAA/OSHA Aviation Safety and Health Team: First Report," 2000).
It is further worth noting that the Occupational Safety and Health Act of 1970 does not apply where another federal agency has jurisdiction ("FAA/OSHA Aviation Safety and Health Team: First Report," 2000). Because the airline industry falls under the FAA, OSHA rules have not been applied to aircraft personnel despite the MOU between the two authorities. FAA rules do address some aspects of cabin crew affairs — including construction, maintenance, accident prevention, and duty-hour limitations — as well as "noise reduction; smoke evacuation; carbon monoxide, carbon dioxide and cabin ozone concentrations; ventilation, heating, and pressurization; first aid, emergency medical equipment, and protective gloves; and prohibition on interference with crewmembers" ("FAA/OSHA Aviation Safety and Health Team: First Report," 2000). Nevertheless, significant gaps remain.
"Jurisdictional gaps and state plan limits"
"FAA reluctance and failed regulatory attempts"
N.A. (2007, June). FAA-OSHA jurisdiction. Retrieved February 8, 2008, from http://ashsd.afacwa.org/index.cfm?zone=/unionactive/viewarticle.cfm&HomeID=1397
N.A. (n.d.). FAA reauthorization: Opportunity to enhance aviation safety and protect U.S. workers. Retrieved February 8, 2008, from
Spengler, J. D., & Wilson, D. G. (2003). Air quality in aircraft. Journal of Process Mechanical Engineering, 217(4), 323–335.
United Kingdom Civil Aviation Authority. (2005, August). Slips, trips and fall prevention on-board aircraft: General guidelines. Retrieved February 8, 2008, from
United States Congress House. (1985). Aviation safety (aircraft passenger survivability and cabin safety). U.S. Government Printing Office.
Wood, R. (2000, July). OSHA: The next battleground? Air Safety Week, 14–29.
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