01/04/2026
"CC/COPIE"
Sent by Registered Mail with Acknowledgment of Receipt
Formal Notice Requesting Clarification Regarding the “AVISAN” Study
Central Works Council of Air France
45, rue de Paris
Bâtiment Pégase, 3rd floor – East & South Wings
CS 12691
95725 Roissy Charles-de-Gaulle Cedex
Copies:
Reference: No. 1A 210 118 9921 6
This open letter constitutes a formal notice and, where applicable, an institutional demand.
General Directorate of Labour (DGT)
ANSES
Labour Inspectorate
Trade Unions
Subject:
Legal status, actual purpose
Relationship with Air France’s mandatory obligations under the Labour Code
Dear Sir or Madam,
Nice, March 23, 2026
Consistent evidence now establishes the existence, within or around Air France, of a mechanism referred to as “AVISAN”, presented as aiming to identify pollutants present in cabin air and to study their potential effects on the health of flight personnel.
Even assuming that this initiative has scientific value, a fundamental legal question remains unresolved and can no longer be avoided:
Is Air France using, directly or indirectly, the AVISAN study as a substitute, a screen, or a means of disguising its legal obligations as an employer regarding occupational health, chemical risk prevention, exposure traceability, and the effective protection of employees?
If this were the case, the situation would no longer amount to mere administrative ambiguity, but to a legally unacceptable confusion, potentially constituting a serious breach of the rules governing the protection of workers’ health.
It must be stated in the clearest possible terms that no scientific study, research protocol, exploratory campaign, or academic or institutional partnership can, in law, substitute for the obligations that fall personally upon the employer under the Labour Code.
As an employer, Air France remains required to identify hazards, assess exposures, prevent risks, update the Single Occupational Risk Assessment Document (DUERP), ensure traceability of exposure situations, inform employees, and, where hazardous chemical agents may be present, carry out the inspections, analyses, measurements, and preventive measures required by applicable regulations.
These are mandatory obligations.
They are not a matter of communication, goodwill, or internal policy. They are binding on the employer with the full force of occupational health law.
This is precisely why the current situation requires immediate clarification.
The issue of cabin air contamination and its health effects is no longer a hypothetical matter or a purely theoretical debate.
It has already been the subject of two major judicial decisions.
The French Court of Cassation, in its ruling of December 19, 2012, upheld the analysis that a serious risk existed at Air France related to the quality of cabin and cockpit air. It acknowledged a significant risk of accidental pollution through the vaporization of chemical substances contained in engine oil, noting the potentially neurotoxic nature of these substances and the foreseeable harm to the health of employees and passengers. It therefore ruled that a CHSCT expert assessment on this issue was legally justified.
This decision is of considerable importance:
it establishes at the highest judicial level that the risk is neither hypothetical, nor fanciful, nor legally negligible.
The Judicial Court of Toulon, in its final judgment of December 19, 2025, ordered the CPAM of the Var to recognize, under occupational disease legislation, the condition declared by a flight engineer, namely an autoimmune central and peripheral neuropathy with demyelination syndrome. The court found that a direct and essential link between the illness and the professional activity had been established, notably due to exposure to toxic substances originating from aircraft engine oils, as well as the consistency between symptoms, exposure chronology, and expert evidence.
This is no longer a theoretical debate:
a court has recognized that a serious neurological condition may fall within occupational risk linked to exposure in an aeronautical environment.
The combination of these two decisions has major legal consequences.
The Court of Cassation states:
the risk is sufficiently serious to justify a specific expert assessment due to possible contamination of cabin air by potentially neurotoxic substances.
The Toulon court states:
the risk may concretely result, in an individual case, in a recognized occupational disease, with the link between exposure and neurological damage judicially acknowledged as direct and essential.
Accordingly, any attempt to present AVISAN as a neutral academic initiative, or as a communication tool intended to demonstrate that Air France is “working on the issue”, becomes legally insufficient and potentially misleading.
From the moment the risk has been judicially qualified as serious, and a pathology has been judicially recognized as occupational, the employer can no longer rely on general scientific uncertainty to delay, mitigate, or dilute its own obligations of prevention, assessment, measurement, traceability, and protection.
If AVISAN is merely an exploratory scientific study, it does not constitute compliance with Air France’s obligations under the Labour Code.
If, on the contrary, AVISAN is invoked as proof that the company is fulfilling its obligations, then Air France must demonstrate, in a complete, documented, and enforceable manner, that this mechanism effectively meets the legal requirements relating to chemical risk assessment, exposure measurement, DUERP updates, employee information, post-exposure medical monitoring, and the implementation of appropriate preventive measures.
Failing this, AVISAN risks appearing not as a compliance tool, but as an institutional screen, or even an attempt to shift the debate away from the binding framework of labour law.
This issue is all the more significant as the very existence of AVISAN tends to demonstrate that Air France has necessarily identified a sufficiently serious risk to justify the implementation of a dedicated system of research, sampling, and health assessment.
Such a system is not established for a subject considered marginal, nonexistent, or purely speculative.
The question therefore becomes unavoidable:
Why was such a study deemed necessary if risk assessment, prevention procedures, measurement systems, exposure traceability, and medical monitoring protocols were already complete, robust, and legally secure?
At present, AVISAN may appear:
as the implicit recognition of a serious risk;
as an admission of previously insufficient documentation;
or, more seriously, as an attempt to shift a matter governed by mandatory occupational health law into the more flexible and less enforceable domain of scientific research.
Such a drift cannot be tolerated.
The Air France CSE cannot remain a passive observer in such a situation.
As a body entrusted with an essential mission of vigilance regarding health, safety, and working conditions, it is its duty not only to address this matter, but to do so immediately, officially, and publicly.
Failing this, there would be a serious risk that a situation persists in which a scientific mechanism is invoked to neutralize, dilute, or delay oversight of the employer’s obligations, despite the fact that the seriousness of the risk and its potential pathological consequences have already been judicially recognized.
For these reasons, the AVSA—whose members include current and former flight crew employees of Air France—formally gives notice to the Air France CSE to:
Officially and without delay address the AVISAN issue, by placing it on the agenda of the next relevant meeting, with an express request for disclosure of all related documents.
Require full disclosure of all documents, protocols, notes, agreements, correspondence, minutes, interim or final reports, methodological sheets, or interpretative documents relating to AVISAN.
Require a written, precise, and enforceable clarification on the following points:
the exact legal status of AVISAN;
its actual purpose;
its possible legal basis;
its relationship with Air France’s obligations regarding chemical risk prevention;
its relationship with the DUERP;
the exact nature of the substances being investigated;
the sampling and analysis methods;
the identity and qualifications of the entities involved;
the operational follow-up given to the findings.
Verify whether Air France has independently fulfilled all its legal obligations, including risk assessment, exposure measurement, DUERP updates, employee information and training, incident traceability, and post-exposure medical monitoring.
Make full use of its legal prerogatives, in case of refusal, silence, or incomplete response, including any measure enabling independent verification of the risk and of any shortcomings by the employer.
We also call upon the General Directorate of Labour and the competent Labour Inspectorate to fully assess the seriousness of the issues raised.
This matter goes far beyond a simple internal or partnership-based study.
It concerns whether, in a major air transport company, an issue involving possible exposure of flight personnel to potentially hazardous contaminants is being handled:
through genuine compliance with labour law, or
through partial displacement into a research framework that does not provide the same guarantees or legal effects as the employer’s obligations.
We also call upon ANSES to clearly clarify the exact nature of its involvement, in order to prevent its name or scientific authority from being used to confer legal weight on AVISAN that a scientific mechanism does not necessarily possess.
No confusion must exist between:
scientific expertise,
exploratory research,
methodological support,
regulatory control falling under employer obligations.
Finally, we call upon representative trade unions to fully engage with this issue.
This is not merely a technical debate.
It concerns occupational health, aviation safety, institutional responsibility, and exposure traceability.
It may also, potentially, involve criminal liability, which we intend to pursue, if necessary, both in France and before international bodies.
Indeed, when an employer is aware of a risk likely to affect employees’ health—particularly one that may impact neurocognitive, neurological, or psychomotor functions in an aeronautical environment—failure to implement adequate prevention, insufficient traceability, inadequate risk assessment, or incomplete information to staff representatives may, depending on the circumstances, give rise to criminal liability.
This is especially true where such conditions may contribute to events affecting flight safety.
In this context, several members of Congress have referred the matter to the Administrator of the FAA (Federal Aviation Administration) to express their concerns.
This is not to assert that an offense is already established in every case; rather, it is to emphasize that, where a risk is known, documented, and judicially recognized, the persistence of uncertainty regarding the measures actually taken by the employer may create serious criminal exposure.
This may involve, among others:
deliberate breaches of safety obligations,
unintentional injuries,
endangerment of others,
obstruction, where information provided to employee representative bodies is incomplete or misleading.
The rulings of the Court of Cassation and the Toulon court reinforce this requirement for vigilance, as they establish both long-standing awareness of the risk and its potential pathological consequences.
If AVISAN were used to give the appearance of adequate risk management while in reality constituting only a scientific protocol without regulatory force, the issue would no longer be merely social or administrative—it could become criminal.
In legal terms, what would then be at stake is not merely insufficient prevention, but the possible concealment of a deficiency under the guise of research.
Given that the risk has long been known, has been recognized as serious by the Court of Cassation, and has already led to judicial recognition of occupational origin in an individual case, the persistence of such ambiguity is particularly serious.
In the event of litigation, this study could be interpreted not as exculpatory evidence, but as:
proof of knowledge of the risk;
evidence of insufficient prior assessment or traceability;
or even the manifestation of a strategy aimed at substituting scientific appearance for legal compliance.
Accordingly, we request a written, precise, documented, and comprehensive response as soon as possible to all the issues raised in this letter.
Failing this, it will be for each recipient, within the scope of their competence, to draw all appropriate consequences, including through institutional, administrative, pre-litigation, and litigation channels.
The protection of the health of flight personnel cannot depend on organized ambiguity.
It requires transparency.
It demands integrity.
It calls for strict application of the law.
Yours faithfully,
Alexandre LACOUDE
President
