CAA guidance for airports on providing assistance to people with hidden disabilities

Overview

The CAA is consulting on its proposed guidance (CAP1411) for airports on the minimum compliance standards under Regulation EC1107/2006 (the PRM Regulation) in relation to providing assistance to people with hidden disabilities. Hidden disabilities include, but are not limited to, dementia, autism, learning disabilities, anxiety issues, mental health impairments and hearing loss. A significant proportion of the UK population are affected by such disabilities and conditions. According to the relevant charities, 700,000 people live with autism, 1 million have learning disabilities, 850,000 have dementia and 11 million people have some sort of hearing loss. In addition, many more friends and families of people with hidden disabilities are also affected (for autism, this is an estimated 2.8 million people). Further, recent CAA passenger research[1], suggests that many PRMs with hidden disabilities lack the confidence to travel (around 30% of PRMs have a non-physical disability which makes air travel difficult); and the CAA has been contacted by charities and individuals in regard to problems that had occurred when people with such disabilities had travelled by air.

UK airports have already provided the CAA with information on what they already do for this group of passengers. We are pleased to note that a number of airports have introduced services and enhanced existing services to better meet the needs of people with hidden disabilities. However, we consider that the extent and type of assistance offered by airports continues to vary significantly at this time, with many airports needing to improve their performance to comply with the requirements of the PRM Regulation in this regard. The CAA’s view is therefore that guidance is still needed; and from many conversations we have had with colleagues at airports, we believe that airports, in general, would welcome clarification on their obligations in this respect.

The proposed guidance will outline the CAA’s view of what UK airports need to do to comply with their obligations under the PRM Regulation. It has already been shaped to large extent by feedback from disability organisations on the varied needs of people with hidden disabilities in terms of accessing air travel. The CAA has met with a number of leading organisations representing the interests of people with hidden disabilities, including the National Autistic Society, the Alzheimer’s Society, Anxiety UK and Action for Hearing Loss, as well as attending meetings of Prime Minister’s Dementia Challenge Air Transport Task and Finish Dementia Group. In addition, we have spoken to users themselves by attending meetings of the Scottish Dementia Working Group and the Mental Health Action Group.

In addition, we have consulted our colleagues in the CAA’s Aviation Security division and the Department for Transport on the aspects of the guidance that impact on security searches. We are therefore confident that we have correctly balanced the needs of PRMs with the need to ensure security regulations are met. The CAA’s Access to air travel advisory group has also provided us with expert input.

The issue of hidden disabilities and transport is a priority one for government. In relation to aviation, we have spoken about this issue directly with Robert Goodwill, Minister of State for Transport, who I note made the issue the focus of his recent speech to the Airport Operators Association annual dinner[2].

As a result of the significant amount of consultation with both internal and external stakeholders, we have been able to ensure that the requirements within the guidance are focussed on providing practical benefit to passengers. You will note that the guidance is not unduly prescriptive. This is intentional on our part since we feel that there is significant scope for flexibility in the way airports design and implement the assistance service for this group of PRMs. However, our view is that implementation of the measures set out in the guidance should enable airports to demonstrate compliance with the applicable requirements of the PRM Regulation and will enable all UK airports to provide a consistently high standard of assistance to people with hidden disabilities.

Your views are invited

We welcome views from airports, airlines, disability organisations, passengers or any other interested parties on the issues and questions raised in this document.

In the interests of transparency, we intend to publish as much information as possible on our website.  If any of the information you provide or views you express are considered confidential please provide both confidential and non-confidential versions. The non-confidential responses will be published on our website with our report on the results of this Request for Information. In general, we will not publish information if we consider that the disclosure of such information would, or might in our opinion, significantly harm the legitimate business interests of an undertaking to which it relates, or an individual’s interests.

This consultation runs until 15 July 2016 during which time we would welcome submissions.