ASD Response to CEN Technical Report CEN/TR 17904:2022 on Cabin Air Quality

In April 2023, the CEN (European Committee for Standardisation) Technical Committee released a technical report (CEN/TR 17904:2022) concerning cabin air quality on civil aircraft. Unlike a standard, this technical report presents recommendations rather than requirements, prompting significant concerns from various stakeholders. ASD has consistently advocated for further research before establishing standards related to cabin air quality.

ASD's opposition to the report stems from several critical points. First, the technical report lacks specificity in performance requirements or pass-fail criteria for cabin air quality, contrary to CEN internal rules. ASD argues that such criteria are essential for both standards and recommendations.

Moreover, the report's justification for its recommendations lacks supporting scientific evidence, raising concerns about the validity of its claims. ASD challenges the emphasis on the Precautionary Principle over the ALARP principle, urging a more practical approach in managing cabin air quality aligned with European Commission standards.

ASD questions the feasibility of the report's prescribed solutions, such as monitoring and additional filtration, suggesting that the lack of technical solutions may render the recommendations impractical. The report's disproportionate focus on engines and APUs as potential sources of cabin air contaminants, without sufficient scientific backing, is also contested.

Additionally, ASD highlights the absence of clear evidence linking cabin air to health issues among the billions of passengers and crews.

ASD's position underscores the importance of evidence-based standards and a collaborative approach to address cabin air quality concerns within the aviation industry.

ASD recommendations

• The withdrawal of the CEN/TR 17904:2022 report. ASD suggests that, after ongoing research, any identified need for additional guidance should lead to the development of standards with full industry engagement and EASA support.