NBAA has warned the FAA of the “specter of additional oversight and regulation of business aircraft operations” stemming from the agency’s proposal to allow Occupational Safety and Health Administration (OSHA) oversight of aircraft cabin workplace safety issues. The proposed policy, required by the FAA Modernization and Reform Act of 2012, could establish OSHA oversight of occupational safety and health requirements, such as recordkeeping, bloodborne pathogens, noise, sanitation and hazard communication, among others, for non-flight-deck crewmembers.
In the association’s written response to the FAA review, NBAA vice president for safety, security, operations and regulation Doug Carr noted that the proposed policy would apply regulatory requirements to business aviation operations without any consideration of the effects they would have on small businesses, which were not included in the cost/benefit analysis of the OSHA regulation.
For example, NBAA said, “FAA regulations do not mandate the carriage of a flight attendant in non-commercial (Part 91) or on-demand commercial (Part 135) operations for these aircraft. Unfortunately, the FAA’s proposed policy raises a number of concerns related to the application of occupational safety and health standards to operations not previously covered or even analyzed in the development of those standards.”