SIM 05/2007/07 (Version 3)
The Civil Aviation (Access to Travel for Disabled Persons and Persons with Reduced Mobility) Regulations 2007 came into force on 26 July 2007. These provide an enforcement regime in the UK for European Regulation (EC) No.1107/2006 concerning the rights of disabled persons and persons with reduced mobility when travelling by air. The Regulations are enforced by the Civil Aviation Authority (CAA) and the Equality and Human Rights Commission (EHRC) will assist individuals to pursue civil cases.
Although HSE does not enforce this legislation, Transportation Section has worked with DfT, CAA and industry to develop the new guidance and Code of Practice to ensure that occupational health and safety issues for ground handlers and passengers are identified and addressed. Inspectors should contact the Section if they have any queries. Overall responsibility for ensuring adequate services are provided now rests with the airport authority.
The legislation applies to any disabilities including hearing and sight etc. However, this SIM is intended to address manual handling risks associated with routine transfer of incapacitated or wheelchair-using passengers to and from the aircraft. It identifies the methods and equipment that we would expect to see employed. It also identifies practices that should be avoided. Inspectors should refer to the DfT Code of Practice, as this contains a considerable amount of useful information and links to other relevant guidance and standards.
1 Assisting disabled passengers and persons with reduced mobility (PRMs) and handling heavy equipment such as wheelchairs can pose significant risks to the health and safety of both airport workers and passengers. These include the risk of back injuries, sprains and strains (MSDs) and risks of slips, trips and falls when carrying heavy or awkward loads.
2 This SIM provides advice to inspectors for assessing the measures that have been put in place to assist disabled passengers and PRMs on and off aircraft. It covers those passengers who are less mobile or require use of a wheelchair, including passengers who become incapacitated in flight, or have difficulty walking or climbing stairs.
3 The guidance applies to all routine situations, and also outlines good practice that should be followed as far as possible in non-routine or emergency situations. In the case of unforeseen medical emergencies or emergency evacuation of aircraft, contingency plans should be available, and staff should be trained in those aspects of emergency situations for which they may have responsibility.
4 Assisting disabled passengers and PRMs includes handling of passengers throughout the airport, transfer of the passenger between wheelchairs and from wheelchair to aircraft seat, assistance with luggage, checking in, travelling to departure gates, and handling and loading of equipment such as wheelchairs. All of these may present manual handling and other risks and should be part of the employers risk assessment and training procedures where necessary.
5 Inspectors may find guidance on patient lifting in the health services useful in identifying good practice in lifting and handling.
6..The new regulations place the overall duty for ensuring provision of services and assistance to disabled passengers and PRMs on the managing bodies of airports, or the airport operators. Individual airports may provide services themselves or, more likely, contract the service out to ground handling companies.
7 Inspectors should consider the following 4 general aspects of procedures for assisting disabled passengers and PRMs:
8 Risk assessment and planning should ensure that passengers are assisted and transported within the airport and terminal buildings in the safest possible way.
9 The European Regulation places duties on air carriers and tour operators to make information available to passengers about services or arrangements for disabled persons, and to obtain information on needs for assistance. A passengers' right to the full range of assistance at the airport is dependent on their providing notification of such need at least 48 hours before their flight, though airports are expected to make reasonable efforts to provide a service even if a disabled passenger is not pre-notified. Availability of relevant information is essential if handlers are to plan and provide a suitable service.
10 Consideration should be given to the safe carrying of passenger luggage as well as the transfer of the passenger themselves. If service providers are expected to assist with passengers' luggage, whether hand luggage or hold luggage, there should be suitable equipment available to do this safely. It is not acceptable for a handler to, for instance, try to push a wheelchair with one hand and carry luggage in the other.
11 Where it is necessary to transfer to or from wheelchairs, lifting aids such as hoists should be used wherever possible.
12 While wheelchair users are entitled to stay in their own wheelchair to the aircraft wherever possible, there must be safe ways of transferring the passenger onto the aircraft, and safe ways of transferring the wheelchair from the gate to the ramp. If the passenger cannot safely be transferred to a 'boarding chair' once on the aircraft, this transfer should take place within the terminal where there is more space
13 If the passenger's own wheelchair is to be loaded into the aircraft hold, safe systems of work must be in place to enable transfer of the wheelchair to the ramp and for loading into the hold to avoid manual handling risks to handlers. Carrying heavy or awkward loads up or down engineering or air bridge steps is not acceptable.
14 It is important to plan the process. There should be good organization to enable the handlers and the correct equipment to be available, to ensure the planned route is clear, and to ensure that the 'set down' area is suitable for further passenger transfer.
15 The DfT Code of Practice reminds airport operators to consider the needs of disabled persons and PRMs from the first phase of planning new buildings or refurbishing existing ones. This will be required to ensure compliance with the Disability Discrimination Act. Inspectors should consider the responsibilities of the airport operator to provide a safe place of work under the Workplace Regulations if the infrastructure imposes significant risks on users of the facilities.
16 There is specific guidance in the Code of Practice on allocation of seats and in-flight safety issues. This guidance will also be relevant to ground handlers when assisting passengers to board or disembark the aircraft.
17 There are also specific recommendations on improving accessibility to aircraft that apply to all new and refurbished aircraft. HSE will expect carriers to plan for such future improvements to reduce risks to handlers as well as passengers.
18 When planning assistance, the handlers should make an assessment of the unique characteristics of the passenger. This will involve talking to the individual to ascertain if they have any particular needs.
19 Sufficient information should be provided in advance by the passenger, airline, tour operator and airport (as relevant) to enable the handling company to provide suitable equipment and assistance. This will include specific mobility needs and information such as weight to ensure that equipment and lifting aids provided are adequate.
20 Where passengers are transferred to or from wheelchairs, additional lifting aids such as hoists, slide boards etc may be necessary. In some cases, if the passenger has a carer or companion, it may be appropriate for the carer to assist in such transfers.
21 The passenger should feel secure and should be given clear information about the transfer to the aircraft to reassure them. Conveying this information will put the passenger at ease and enable them to cooperate in ensuring the most appropriate assistance.
22 Equipment must be suitable for the task and suitably maintained. All persons using the equipment must be trained in how to use it safely including its limitations.
23 The preferred option to transfer passengers from the terminal to an aircraft is to use an air bridge, as this removes virtually all of the manual handling risks. However, if the air bridge cannot be used then a scissor-lift should be provided. This also minimizes the manual handling risks and only pushing/pulling on the wheelchair is required.
24 Only in exceptional circumstances should a passenger be transferred up or down the aircraft steps in a Boarding Chair, for instance in a medical emergency, or on very small aircraft where use of an ambulift or mechanised lifting aids is not possible. Using a chair on the stairway significantly increases the manual handling risk to the handlers. Lifting with a Boarding Chair requires two handlers.
25 BS EN 1915-1:2001 sets out the basic safety requirements for aircraft ground support equipment and BS EN 12312-14 gives specific requirements for disabled/incapacitated passenger boarding equipment.
26 There should be sufficient devices to accommodate the range of aircraft likely to be encountered. There must be systems in place both in terms of communication and storage or parking of equipment around the airport to ensure availability of suitable equipment at the required location.
27 It is not acceptable to use lifting devices that are designed to carry freight or catering supplies unless the vehicles have been specifically modified to carry disabled passengers.
28 When passengers in wheelchairs are being transported in ambulifts and airside buses both wheelchair and passenger should be secured in position. The restraint mechanisms should be regularly maintained. Further guidance and standards relevant to the carriage and transportation of wheelchairs are in Appendix 4.
29 There may be a small number of occasions when the nature of a disability makes it difficult to fit passenger restraints or to do so would cause severe distress. Handling agents should be sufficiently trained in dynamic risk assessment and disability awareness to be able to manage these situations in such as way as to reduce the risk as much as is reasonably practicable.
30 There are many different designs of boarding chairs, but they are all narrow chairs that allow access down the aisles in the plane. Powered or power assisted stair climbers should be used wherever possible and there is also new technology, such as fold away stair lifts fitted to standard passenger access steps, which reduces manual handling risks.
31 Chairs should be designed to enable one person to lift at the foot of the chair and one to lift at the shoulder of the chair. Where possible, the handles should extend to prevent the handler from stooping. Similarly, the handles at the shoulder should be positioned at a comfortable height to avoid handlers raising their elbows and shoulders.
32 Stair climbers should be designed to allow access into the aircraft aisle, to avoid the requirement for passengers to be transferred between chairs on entering the aircraft.
33 Chairs should be fitted with a braking system and secure harness to prevent inadvertent movement of the passenger, and to ensure that the passenger feels secure.
34 In terms of technical specifications, chairs should be designed such that the force required to push and turn (on a level surface) a wheelchair or boarding chair occupied by a 99th percentile weight male should not exceed the maximum force which can be exerted by a 5th percentile female. These weights are based on statistical data and calculation of such forces is extremely complex. In very simple terms, chairs should be designed so that a male at the top end of the weight/build scale can be easily pushed by a female at the lower end of the weight/build scale. Manufacturers should be able to give details of forces required to move specific chairs and specialist advice should be sought if there is any doubt about this.
35 Personal protective equipment to be worn by the handlers should include suitable safety footwear to minimize slipping and crushing injuries from the wheels of the chair. When working airside, individuals will also be required to wear ID badges, hi-visibility clothing and ear protection. To minimize interference with the handling task, ID badges and clothing should not be loose fitting.
36 All individuals involved in the transfer of disabled passengers should receive training in the specific procedures and equipment used at the airport as well as disability awareness training.
37 Comprehensive training in use of equipment, including any different types of chair in the circumstances in which they will be used and in any limitations in use, is essential. For example, some of the newer designs, particularly tri-wheels and caterpillar type chairs, require a great deal more training and user experience than 'standard' chairs.
38 Problems may arise if the handlers are unfamiliar with the equipment because the scissor-lift, or boarding chair, is of a different design to that which was used for training. It is unacceptable for untrained individuals to undertake such lifts.
39 Refresher training should be provided at regular intervals and whenever new systems or equipment are introduced.
40 Inspectors are requested to:
41 Implementation of the Regulations in terms of service provision is enforced by CAA. Passenger complaints about level of service should be addressed to the airport or airline in the first instance and it is expected that the airport authority will have local arrangements to deal with such issues. Formal complaints will be dealt with by the EHRC and CAA. HSE Inspectors should only intervene where there are specific health and safety issues which cannot be resolved at the local level.
42 Further development work on the application of the Enforcement Management Model (EMM) to health issues is continuing. It is not currently possible to handle the risks of musculoskeletal disorders rigorously within the EMM, but the following guidance is given as an interim measure.
43. Inspectors should follow the guidance in the FOD Inspection Pack on Musculoskeletal Disorders and be aware of the Health Services sector policy that the Manual Handling Assessment Tool (MAC) should not be applied to patient/ passenger lifting.
44 In 2006/07 the accident category 'Handling and Sprains' accounted for around 50% of reported over-3-day accidents in the air transport industry. Some of these injuries resulted from carrying heavy equipment or attempting to provide assistance without suitable equipment.
45 Transportation Section is aware of incidents where lifting equipment and wheelchairs have collapsed when the weight of the user exceeded the limit of the equipment. Information on passenger needs must include sufficient information to enable the handling company to adequately assess needs and provide suitable equipment.
46. The legal framework which sets the requirements for the management of risk from manual handling is laid down in the Health and Safety at Work etc Act 1974 HSWA), the Management of Health and Safety at Work Regulations 1999 (MHSWR) and the Manual Handling Operations Regulations 1992 (MHOR).
47 In particular the following should be considered:
48 The enforcement guidance below is of a generic nature. Inspectors should use their discretion when determining appropriate controls in particular situations bearing in mind what is reasonably practicable. Transportation Section should be contacted if specific guidance is required.
49 The main factors which must be examined in carrying out an ergonomic risk assessment are: the load, the task, the environment, the individual, and any other factors (e.g. PPE).
50 Most duties under health and safety legislation rest on the employer - in this case the ground handling company. However, consideration should be given to circumstances where the infrastructure or systems of work imposed by the airport or airlines impose risks to the health and safety of ground handlers.
51 Where there is evidence that there is a significant risk of injury and:
a Prohibition Notice (PN) or Deferred Prohibition Notice should be considered if supported by specialist advice. An Improvement Notice for the airline or airport may be necessary to address situations where their requirements create significant risks for handlers.
52 You should, however, be aware that the CAA has responsibility for aircraft design issues and in-flight safety. Inspectors should consult Transportation Section before taking any action which might involve such issues.
53 Inspectors should take into account the overall implications of an immediate PN, which could prevent aircraft turnround and may have serious implications for overall airport and aircraft safety. If the prohibition would, of itself, bring about other risks to health and safety that otherwise would not have existed, a deferred PN will be the preferred option, allowing, for instance, reasonable time for the repair of defective equipment for use on subsequent passenger boarding operations, without imposing additional risks in changing the system of work around an aircraft awaiting take-off.
54 Where a longer time scale is required, for instance for the acquisition of additional equipment, or improvements to infrastructure and facilities an Improvement Notice is likely to be the practical option.
55 Where inspectors find failings of management systems such as:
and there is evidence that:
an Improvement Notice should be considered. Advice or enforcement should be addressed to the party or parties best able to rectify an identified problem, i.e. airport and/or airline and/or ground handler.
56 It is important to consider who is responsible for providing and maintaining equipment such as scissor lifts or lifts/chutes at gates as this could be the airport operator, the service provider, the airline or another organization.
57 Inspectors should apply local factors based on their knowledge of the specific situation and employer.
Target for action
58 Inspectors should consider and target specific manual handling risks and underlying management failings by the employer and, if relevant, the airline or airport involved in a specific situation.
59 As always, inspectors should take action against the company in the best position to remedy the defects. In most cases, the target for action is likely to be the employer of the affected personnel. However, Transportation Section would encourage Inspectors to also pursue relevant issues from HSE guidance publication HSG209 Aircraft Turnround with the service provider's client (most probably the airline) and the duty holder in control of the premises (the airport authority). Matters relating to the assessment, control and monitoring of contractors and the control of risks to non-employees are likely to be the most pertinent in this context. Transportation Section should be consulted before any enforcement action proceeds on such matters.
60 The risk of musculoskeletal injury among ground handlers is well known in the industry and is the cause of considerable lost time and absence, and consequent cost to the employer, as well as the cost to the nation of injury and early retirements, and the pain and suffering of individuals.
61 Inspectors should also consider that enforcement action will have a positive impact on dutyholders in the industry in general.
1 At larger airports, boarding on many flights is undertaken through the use of extending passenger loading bridges or ' air bridges'. This enables passengers to access the aircraft without the need to negotiate a stairway up to the plane. However, not all gates have this facility, some smaller aircraft are incompatible with air bridges, and in some cases airlines may choose not to use the air bridge. In these cases passengers are required to embark by walking (or travelling by bus) across the ramp and ascending steps up into the aircraft.
2 A passenger and possibly their wheelchair, which may total in excess of 100kg, may have to be raised or lowered through several metres to access the aircraft. Given these facts it is clear that some form of mechanical assistance is required and training and communication are of particular importance if team handling is involved.
3 The provision of suitable equipment is the most significant factor in terms of the task design and in terms of manual handling risk to the individuals responsible for transferring passengers to and from the aircraft. The choice of equipment greatly influences the handling requirements.
4 Where air bridges are available and used the manual handling risks are significantly reduced, providing there are also facilities such as lifts or chutes to transfer wheelchairs or other equipment from the gate to the ramp for loading. In the absence of an air bridge there are a number of methods for disabled passengers to board or leave the aircraft, each employing significantly different pieces of equipment:
5 Even if air bridges or scissor-lifts are used there is likely to be a requirement to transfer the passenger to a boarding chair to access a seat once on board the aircraft. This presents significant manual handling problems. Some airlines are using hoists specifically designed for use on aircraft. These are not yet in wide use in this country and may not be suitable for all aircraft. The new regulations and Code of Practice cover longer term solutions to problems through better design of aircraft and airports. While such improvements are aspirational, HSE will expect the industry to actively seek and plan for such improvements.
6 The Civil Aviation Authority (CAA) is responsible for the regulation of aircraft registered in the UK. Inspectors may find it useful to know that CAA policy specifically restricts the allocation of seats to disabled passengers and some other categories of passengers at 'self-help' exits on the aircraft. Seats at other emergency exits may not be allocated to disabled passengers if this would impede cabin crew in carrying out their emergency duties. Disabled people should, however, be seated as close to emergency exits as the above limitations allow. Some aircraft may have seats which are modified to improve access for disabled passengers, for instance having moveable or removable arm rests.
7 The Code of Practice covers issues such as seating arrangements on board the aircraft which will also reduce risks for handlers when boarding passengers.
8 As noted in paragraph 2 the combined weight of a passenger and chair (the 'load') may well be in excess of 100kg. Combining this with the many other human variables - factors such as mobility, responsiveness, behaviour (potentially nervous or unpredictable) - presents one of the most difficult tasks for manual handling. Each lift will offer a unique set of risks and there are few factors, in terms of the load, that can be controlled by the handler.
9 Concerns have been expressed amongst handlers that the seated occupant of a boarding chair will often try to reach out and hold the nearest handrail as most of the chairs do not have arm rests and the occupant can feel insecure. Handlers should be alert to this possibility.
10 There are significant risks to handlers in transferring heavy or awkward loads such as wheelchairs from the gate to the ramp for loading.
11 Consideration should be given to handling of passenger luggage. If the handler has responsibility for assisting the passenger to or from check-in and baggage collection, suitable equipment or additional assistance may be needed.
12 As with the load, the handler has little control over the environmental conditions on the ramp. The provision of an air bridge or scissor-lift will provide the best protection from the elements for both handler and passenger, reducing the risks of slips or trips during wet or windy weather.
13 The airport operator is responsible for ensuring that the workplace and infrastructure are safe, and for the provision of equipment such as lifts and chutes for passengers and their wheelchairs where necessary.
14 The successful use of lifting aids will depend on the equipment available, the efficient maintenance of the equipment and the communication between aircraft/airline and the ground handlers, to ensure the equipment is available at the gate.
15 The use of 'air bridges' will be more common with larger, wide-bodied aircraft, therefore removing the need for ramp handling. Provision must be made for the safe transfer of wheelchairs from the air bridge to the ramp for loading into the aircraft hold, either using lifts or chutes.
16 A problem affecting the use of scissor-lifts is the interface between the lift and the aircraft entrance, due to the range of aircraft types serviced. This can be a particular problem where the aircraft has integral steps, although Ambu-lift designs are available that overcome this problem.
17 The height range of the platform on which the passenger is lifted will not be compatible with all aircraft. If the device is mounted on the back of a vehicle and the lifting platform extends over the top of the vehicle cab, the cab restricts the minimum height, and this can be a problem for small aircraft. Devices such as this will generally have a tailgate to raise the passenger from ground level.
18 For larger aircraft the maximum platform height may not reach the aircraft entrance. Therefore, there may be a need for an airport to have a range of lifting devices.
19 There are a number of companies manufacturing powered or manual carry chairs and stair climbers, some of which are specifically designed for use on aircraft steps. There are also new products becoming available such as stair lifts which can be fitted to standard passenger access steps.
20 The chairs incorporate lifting handles at head and foot which may be adjustable, single or multiple wheel assemblies or treads, passenger restraining straps, and chair folding and locking mechanisms. Design of handles, size, width and tread of wheels, type of restraints and locking mechanisms vary according to design.
21 In a recent HSL assessment of the use of stair climbers by ambulance personnel in health care services, acceptability of the chairs has been variable. Concerns which have been expressed include the following:
22 Use of any such chair will require careful assessment in relation to the exact circumstances of its use - type of aircraft steps; available space for turning or passenger transfer; stability; foreseeable use.
23 Badly maintained chairs will increase the effort required to transfer the passenger to the aircraft and will also increase the risk of injury to the passenger.
1 The Disability Discrimination Act 1995 applies to the use of booking services and airport facilities and services.
2 The Civil Aviation (Access to Air Travel for Disabled Persons and Persons with Reduced Mobility) Regulations 2007 and the EC Regulation 1107/2006 impose duties on airport operators, air carriers, their agents or tour operators in respect of the service they provide to disabled persons and PRMs. Overall responsibility for ensuring the service is provided rests with the airport managing body. The EC Regulations also consider design and refurbishment of airports and aircraft with the needs of disabled passengers in mind.
3 The DfT guidance and Code of Practice on the regulations covers handling of passengers throughout the airport, transfer of the passenger between wheelchairs and wheelchairs on board the aircraft including additional assistance which may be provided in the airport and terminal such as assisting with luggage, checking in, travelling to departure gates, etc. All of these may present manual handling risks and should be part of the employer's risk assessment and training procedures where necessary.
4 The DfT Code of Practice also gives guidance for tour operators and airlines on establishing the specific requirements of an individual passenger before they arrive at the airport, so that suitable facilities and assistance are available. This Code also takes into account standards and recommendations developed by the European Civil Aviation Conference (ECAC) and the International Civil Aviation Organization (ICAO).
5 The International Air Transport Association (IATA) Airport Handling Manual contains guidance and recommendations on the handling of PRMs, some details of which are in Appendix 3 - Further guidance on manual handling.
6 General guidance for disabled passengers can be found in Equality and Human Rights Commission web pages on Air Travel.
AHM 176 and AHM 176a give recommendations for the handling of passengers with reduced mobility (PRMs). They define a PRM as:
There are a number of categories of PRMs which are given specific codes. The codes for wheelchair users are:
There are also codes for other disabilities such as leg in cast, oxygen use, medical case, etc.
Necessary steps should be taken to ensure that the Handling Company is in a position to ensure safe handling of PRMs by ensuring that appropriate devices are made available, such as, but not limited to, wheelchairs and lifting systems.
The Handling Company shall take all necessary steps to establish and coordinate training programmes to ensure that trained staff are available. Carry up/down should only be performed by specially trained staff.
For further information on guidance in the IATA Airport Handling Manual please contact Transportation Section.
The Medicines and Healthcare Products Regulatory Agency (MHRA) produce
British Standard BS ISO 10542 'Technical systems and aids for handicapped or disabled persons. Wheelchair tiedown and occupant-restraint systems'.