Proposed Controlled Evaluation of Duty-of-Care Jet A-1 (DoC Jet A-1) for MOD Rotary‑Wing Operations

Dear Sir / Madam,

DM‑XTech UK Ltd hereby submits for consideration a formal technical proposal for the controlled evaluation, on a funded pilot basis, of its Duty-of-Care Jet A-1 (DoC Jet A-1) at a designated UK military airbase operating a high concentration of rotary‑wing aircraft.

This submission is framed for simultaneous routing to the MOD fuel authority and the Defence safety / health‑protection function because the proposal engages fuel QA and supply, occupational‑health risk management, and airworthiness pathway definition. It is copied to the MOD Surgeon General and the MOD Chief Scientific Adviser because the initial decision sought is a controlled evaluation, not an immediate fleet conversion.

Publicly available material — including the IMEG seventh report, the 8 July 2025 Westminster Hall debate on military helicopters and blood cancers, and earlier MOD‑related exhaust‑exposure reporting — shows that rotary‑wing exhaust exposure remains a serious subject of occupational‑health and parliamentary concern. Those same public sources also indicate that the currently available evidence does not establish causation to the threshold applied by IMEG. DM‑XTech therefore does not ask the MOD to accept any causal conclusion. It asks only that MOD examine whether a specification‑compliant lower‑naphthalene, lower‑soot fuel merits controlled evaluation as a prudent exposure‑reduction option.

Recent public litigation, published research, and wider operational concern indicate that this issue warrants documented technical evaluation. DM‑XTech makes no comment on the legal merits of any individual claim and raises that background only to explain why a forward‑looking exposure‑reduction trial is now timely.

DM‑XTech UK Ltd has developed and independently validated a precision‑engineered aviation fuel, DoC Jet A-1, that directly addresses the fuel‑composition variable DM‑XTech proposes should be evaluated under MOD supervision:

• DoC Jet A-1 contains less than 100 ppm of naphthalene, representing a 99.7% reduction from the 30,000 ppm maximum permitted in standard Jet A‑1 (and a >95% reduction versus typical 8,000–20,000 ppm values).
• DoC Jet A-1 retains 8.5% total aromatics, which DM‑XTech presents as satisfying the minimum aromatics position it relies on for ASTM D7566 and DEF STAN 91‑091 context. This should not be read as a separate bench‑proven seal‑compatibility claim for DoC Jet A-1.
• Independent testing at TERC on a representative military gas turbine demonstrated an 80% reduction in soot mass at idle, a 55% reduction in particle count, and a 33.3% reduction in total unburned hydrocarbons relative to standard Jet A‑1.
• DoC Jet A-1 is presented as fully certified to ASTM D1655 and DEF STAN 91‑091. That specification compliance supports its consideration as a drop‑in fuel candidate, but DM‑XTech recognises that MOD QA acceptance, airworthiness review, and local engineering governance still need to define the exact pathway for any Engine Test Bay or airbase evaluation.
• DoC Jet A-1’s soot reduction implies a proportionate reduction in internal engine soot deposition, supporting extended maintenance intervals, reduced injector coking, and improved fleet operational availability, potentially offsetting a significant proportion of any fuel cost premium.

Full TERC validation data, certification documentation, and technical specifications are enclosed with this submission as Appendix A.

DM‑XTech proposes that the Ministry of Defence authorise a phased Operational Pilot Programme designed to minimise risk at every stage. The programme begins not with flight testing but with a controlled Engine Test Bay evaluation, conducted during a scheduled Major Inspection of a representative military turboshaft engine, before progressing to a six‑month airbase flight trial.

The Engine Test Bay phase is designed to carry low incremental operational risk: the engine would be ground‑mounted in a test facility and operated within an existing maintenance framework, with no aircraft flight activity proposed in this phase. The principal additional items are the trial fuel, agreed monitoring instrumentation, and any independent oversight. Final cost and authorisation route should be validated with the host maintenance organisation, OEA / DFTA, and any relevant airworthiness stakeholders before execution. This precursor phase is intended to generate MOD‑owned, independently monitored, operationally representative performance data before any commitment to a flight trial is considered.

Subject to satisfactory Engine Test Bay results, DM‑XTech proposes that the Ministry subsequently authorise a six‑month Operational Pilot Programme at a single designated military airbase with a high concentration of rotary‑wing aircraft. DM‑XTech does not request full fleet adoption at this stage; it requests the opportunity to demonstrate DoC Jet A-1’s performance under real‑world operational conditions, with independent academic monitoring, and to generate the evidence base required for an informed full fleet adoption decision.

The Pilot Programme is designed to achieve four outcomes simultaneously: (a) generate operational‑scale performance data capable of confirming or challenging the TERC laboratory results; (b) test whether DoC Jet A-1 produces a measurable improvement in the exposure environment for aircrew and ground personnel at the designated airbase; (c) establish a formal institutional record of the MOD’s active, good‑faith response to a reported occupational‑health concern; and (d) if the evidence supports it, inform any later commercial and implementation discussion on a proper evidential footing.

DM‑XTech’s current internal planning estimate for the six‑month Pilot Programme is set out in the accompanying programme proposal, but that figure remains provisional pending MOD scoping. The immediate decision sought is narrower still: agreement to scope the Engine Test Bay Precursor Phase and the associated technical review meeting.

For the avoidance of doubt, DM‑XTech does not invite the Ministry to make any retrospective admission of liability or fault. The proposed Pilot Programme is framed explicitly as a forward‑looking, no‑fault health protection and evidence‑gathering exercise, consistent with the MOD’s existing statutory duties and internal governance.

DM‑XTech respectfully requests: (a) written acknowledgement of this submission within ten working days; (b) a formal technical briefing meeting within thirty working days; and (c) identification of a scheduled Major Inspection of a representative turboshaft engine at which the Engine Test Bay Precursor Phase can be conducted, ideally within sixty working days of this submission.

DM‑XTech emphasises that the Engine Test Bay Precursor Phase requires no flight authorisation, no operational disruption, and minimal incremental cost. It is the lowest‑risk first step available and provides the MOD with its own data, generated in its own facilities, under its own supervision, from which to make any subsequent decision with full confidence.

DM‑XTech is prepared to make its scientific and technical data available, under appropriate non‑disclosure arrangements, to any MOD technical panel, scientific adviser, or independent reviewer the Ministry wishes to appoint.

This submission is made in good faith and in the shared interest of protecting the health of UK armed forces personnel. DM‑XTech looks forward to the Ministry’s response and to the opportunity to present its evidence in detail.

Dear Surgeon General,

This brief sets out the occupational health relevance of DoC Jet A-1, a DEF STAN 91‑091‑certified aviation fuel formulated to reduce naphthalene‑derived soot emissions from legacy rotary‑wing engines, and proposes a monitored Pilot Programme as a proportionate health protection measure under your existing mandate.

Existing litigation and research indicate that aircrew and ground personnel operating around legacy military helicopters are exposed to PAH‑laden ultrafine particles generated from naphthalene‑containing Jet A‑1 under partial‑power conditions. Biomonitoring studies in comparable civilian cohorts demonstrate elevated urinary PAH metabolites in exposed workers.

DoC Jet A-1 reduces naphthalene content to <100 ppm and has demonstrated up to 80% soot mass reduction at idle in a representative gas turbine. It is fully compliant with DEF STAN 91‑091 and is proposed for controlled evaluation without any planned aircraft, engine or ground‑infrastructure modification at pilot stage. DM‑XTech submits that it merits evaluation as a potential engineering / substitution‑type control measure within a COSHH‑style exposure‑control framework.

DM‑XTech respectfully invites your office to consider commissioning a Defence Health Risk Assessment on naphthalene and PAH exposure in rotary‑wing operations, with DoC Jet A-1 evaluated as a candidate control measure, and to support the proposed Pilot Programme as a health protection trial rather than a procurement initiative.

Dear Airworthiness Team,

DM‑XTech writes to seek early guidance on the appropriate regulatory pathway for a proposed, tightly controlled evaluation of Duty-of-Care Jet A-1 (DoC Jet A-1), a DEF STAN 91‑091 and ASTM D1655 compliant aviation turbine fuel formulated to reduce naphthalene and soot precursors while retaining the ≥8% aromatics basis DM‑XTech relies on for legacy‑fleet context.

We do not suggest that specification compliance alone removes the need for military regulatory process. Rather, our position is that the proposed Engine Test Bay precursor phase is specifically designed to generate the representative evidence that MAA and associated engineering authorities may wish to see before any controlled single‑airbase operational trial is considered.

The objective of this note is not to press for immediate operational authorisation. It is to ensure that the evidence‑generation plan is aligned from the outset with MAA expectations, including any requirements arising in practice under the RA 1000 series framework and any base‑level modification or fuel supply change governance.

• DoC Jet A-1 is already specification‑compliant and therefore materially different from an off‑spec experimental fuel.
• The current independent evidence base is strong, but derived primarily from TERC testing on a representative military gas turbine rather than a main propulsion turboshaft in an MOD facility.
• The Engine Test Bay phase is intended to close that gap using MOD‑supervised data from a representative military engine during scheduled maintenance.

DM‑XTech would be grateful for non‑binding early guidance on the following points:

• Whether the proposed Engine Test Bay precursor phase is an appropriate first evidential step before any controlled flight activity.
• What minimum data package the MAA would ordinarily expect to review for a compliant fuel supply change at a single military airbase.
• Whether there are preferred interfaces, sponsoring authorities, or document forms that should be engaged at the outset.
• Whether the MAA would welcome a short technical meeting with DM‑XTech and TERC to review the evidence architecture before formal submission.

DM‑XTech’s aim is to follow the correct institutional route, to minimise operational risk, and to ensure that any future submission is framed in a way that is technically useful to MAA review rather than procedurally premature. We would therefore welcome the opportunity for a short exploratory discussion at your convenience.

This briefing note is submitted to members of the House of Commons Defence Committee who have engaged with concerns raised about reported exhaust‑exposure issues affecting UK military helicopter crews. Its purpose is to bring to the Committee’s attention that a specification‑compliant lower‑naphthalene, lower‑soot aviation fuel option is now available, has been independently tested, and has been formally offered to the Ministry of Defence for controlled evaluation.

Standard Jet A‑1 aviation fuel can contain naphthalene at concentrations permitted up to 30,000 parts per million maximum (typical 8,000–20,000 ppm). DM‑XTech’s case is that lower naphthalene content should translate into lower soot loading under the operating conditions that matter most in legacy rotary‑wing use. Public reporting has also described a January 2024 settlement involving the estate of Flight Sergeant Zach Stubbings and wider claims activity by current and former aircrew. DM‑XTech does not ask the Committee to take a view on legal merits; it asks only that the existence of a controlled, specification‑compliant evaluation pathway be noted.

DM‑XTech UK Ltd has developed an aviation fuel, DoC Jet A-1, that contains less than 100 parts per million of naphthalene, compared to the 30,000 ppm maximum (8,000–20,000 ppm typical) permitted in standard Jet A‑1. Independent testing at TERC demonstrated an 80% reduction in soot mass and a 99.7% reduction in naphthalene content (versus specification maximum) relative to standard Jet A‑1. DoC Jet A-1 is presented as DEF STAN 91‑091 compliant and is intended to be evaluated without planned hardware modification; MOD process and QA acceptance still need to be confirmed.

DM‑XTech has formally submitted a proposal to the Ministry of Defence for a phased, controlled evaluation beginning with an Engine Test Bay step and potentially progressing to a single‑airbase pilot if the evidence supports it. Provisional programme cost planning is set out in the internal pack, but the immediate request is narrower: a technical meeting and scoped ground phase. The formal submission is routed to the MOD fuel authority and Defence safety function, with copies to the Surgeon General function and the MAA consultation route.

DM‑XTech does not seek to predetermine any procurement decision and makes no comment on the legal merits of any individual claim. It respectfully invites members of the Committee to note: (a) that an independently validated, specification‑compliant lower‑soot fuel option now exists; (b) that it has been formally offered to the Ministry of Defence for controlled evaluation; and (c) that the way MOD responds to an available exposure‑reduction option is a legitimate subject of parliamentary interest.

DM‑XTech’s technical team and TERC researchers are available to brief the Committee, or its staff, at any time. Full validation data and certification documentation will be provided on request.

Dear [Partner / Solicitor],

DM‑XTechnologies Inc. (DM-XTechPhil) is the developer of Duty-of-Care (DoC Jet A-1), an aviation fuel formulated to materially reduce naphthalene content and soot emissions from legacy military helicopter engines. I write to bring to your attention evidence that may be relevant to the reported exhaust‑exposure proceedings you are conducting on behalf of former UK military helicopter aircrew and their estates.

I write not as an adversary of the Ministry of Defence, but as a commercial entity that has developed a validated lower‑soot, lower‑naphthalene fuel option and that has, as of the date of this letter, formally submitted that option to the MOD with a proposal for a controlled evaluation programme. The relevance of this evidence to your proceedings arises not from our role but from the scientific and procedural implications of the evidence itself.

Public reporting around the Zach Stubbings settlement and wider claims activity has focused attention on whether legacy rotary‑wing exhaust exposure could have materially contributed to later disease. DM‑XTech does not offer a legal conclusion on causation. Its point is narrower: if fuel composition materially changes soot formation, then the existence of a specification‑compliant lower‑soot alternative may become relevant to questions of mitigation, knowledge, and post‑notification conduct.

DM‑XTech’s evidence bears on two aspects of this chain that may strengthen future proceedings:

• The existence of a validated, specification‑compliant fuel option: TERC testing indicates that materially lower soot and naphthalene outcomes may be achievable with DoC Jet A-1 using the same class of engine and without planned hardware modification. That does not decide liability; it does show that fuel composition is a variable worthy of evidential attention.
• The knowability of a candidate mitigation step: DM‑XTech’s work demonstrates that the soot / naphthalene issue is scientifically characterisable and technically addressable at least to the point of a controlled MOD evaluation. A document trail now exists showing that the Ministry of Defence has been formally notified of that candidate pathway and the scientific evidence supporting the request for evaluation.

DM‑XTech is prepared to provide your expert witnesses with: the full TERC validation dataset and methodology; the ASTM D1655 and DEF STAN 91‑091 certification documentation for DoC Jet A-1; a technical briefing from TERC researchers on the combustion chemistry of naphthalene pyrolysis and the measured difference between Jet A‑1 and DoC Jet A-1 soot output; and, if required and appropriate, expert witness availability from DM‑XTech’s technical team.

DM‑XTech makes no warranty as to the outcome of any legal proceedings and this letter does not constitute legal advice. DM‑XTech’s interest is in seeing DoC Jet A-1 adopted by the MOD; facilitating the legal record reflects our honest assessment that the scientific evidence justifies serious consideration of controlled MOD evaluation.

I would welcome a confidential call or meeting at your earliest convenience.

Operation CLEAR BURN is a phased, funded, independently monitored Operational Pilot Programme beginning with a controlled Engine Test Bay evaluation and progressing to a live airbase flight trial. Its purpose is to evaluate the operational performance, health protection outcomes, and fuel system compatibility of DoC Jet A-1 as a drop‑in replacement for standard Jet A‑1 in legacy rotary‑wing operations.

Prior to any airbase deployment, a controlled Engine Test Bay evaluation will be conducted during a scheduled Major Inspection of a representative military turboshaft engine at an MOD‑approved Depth Maintenance facility. The engine test bay run will follow standard Major Inspection test profiles using DoC Jet A-1 in place of standard Jet A‑1, with TERC exhaust characterisation instrumentation deployed at the test bay stack. This phase is designed to avoid flight activity in this phase and should carry comparatively low incremental cost relative to a full operational trial; final authorisation route and cost should be validated with the host maintenance organisation and MOD sponsor.

• Location: A single designated UK military airbase with a rotary‑wing fleet of not less than 20 operational aircraft.
• Aircraft Platforms: All rotary‑wing aircraft stationed at the designated site throughout the programme period.
• Fuel Specification: DoC Jet A-1, fully ASTM D1655 and DEF STAN 91‑091 certified, verified as specification‑compliant through the MOD’s own standard fuel acceptance QA process.
• Fuel Volume: All aviation fuel consumed at the designated site for rotary‑wing operations during the 6‑month operational period (estimated 800–2,000 tonnes).
• Personnel: Volunteer aircrew and ground crew participation in biomonitoring and structured questionnaire programme (estimated 40–80 participants).
• Independent Monitor: TERC, University of Sheffield, appointed by joint agreement as sole independent data custodian.

Air Quality Monitoring: Continuous ambient particulate monitoring (PM₁, PM₂.₅, PM₁₀) at apron, crew room, and refuelling stations. Weekly averaged data submitted to TERC. Naphthalene and total VOC concentrations measured by photo‑ionisation detection.

Exhaust Characterisation: Monthly DMS500 aerosol spectrometer measurements during representative operational sorties, hover, transit, and hot‑loading flight phases, for each aircraft type present at the station.

Crew Biomonitoring: Urinary analysis of volunteer participants for naphthalene and PAH exposure markers, pre‑ and post‑duty‑cycle monthly.

Fume Event Log: Structured standardised self‑report database for any cabin air quality complaint, odour event, neurological symptom, or eye/respiratory irritation.

Fuel System Integrity: Scheduled inspection of fuel system seals on all participating aircraft at 500‑hour intervals.

Engine Condition & Maintenance Impact: Borescope imagery and EHM trend data compared before and during DoC Jet A-1 operation to quantify engine cleanliness improvements and inform maintenance interval extension recommendations.

DM‑XTech proposes the following commercial structure for MOD consideration:

• DoC Jet A-1 supplied at a fixed price equivalent to standard Jet A‑1 market rate plus a negotiated Health & Safety Premium of GBP 80–120/tonne.
• TERC monitoring costs funded jointly (50:50) by DM‑XTech and the MOD up to an agreed cap of GBP 250,000.
• Crew biomonitoring costs funded by DM‑XTech as part of its research programme up to an agreed cap of GBP 80,000.
• All intellectual property in the DoC Jet A-1 formulation and production process remains vested in DM‑XTech; the MOD acquires no rights beyond the right to use the fuel supplied under the programme.
• All monitoring data is jointly owned by the MOD and DM‑XTech, with academic publication rights agreed in advance with TERC.

Operation CLEAR BURN is better characterised as a controlled evaluation of an alternative fuel within a health‑protection and engineering‑assurance context, rather than as an immediate fleet‑replacement competition. The exact governance route should be settled with OEA / DFTA, Defence Safety, the host maintenance organisation, and any relevant airworthiness stakeholders.

The phased structure provides a lower‑commitment route into the evidence base: Phase Zero (Engine Test Bay) is designed as the narrowest and lowest‑risk entry step. The exact authorisation path should be settled case‑by‑case with the host maintenance organisation, OEA / DFTA, and any relevant airworthiness stakeholders. Any decision to progress to an airbase flight trial should then be made on the basis of the MOD’s own evidence, not DM‑XTech’s claims.

Public reporting in 2025 referred to around 180 current and former aircrew pursuing claims linked to helicopter exhaust exposure, alongside a previously reported January 2024 settlement involving the estate of Zach Stubbings. DM‑XTech includes that context here only as a marker of live external scrutiny, not as a quantified statement of MOD liability.

This note intentionally avoids asserting aggregate liability numbers. The more defensible point is procedural: where claims activity and parliamentary scrutiny already exist, a documented good‑faith evaluation of an available exposure‑reduction option may improve litigation posture more credibly than inaction.

A documented evaluation of DoC Jet A-1 may provide the MOD legal team with three procedural advantages:

• Potential mitigation of ongoing exposure concern: If the evaluation confirms materially lower soot and naphthalene outcomes, MOD would have an evidence‑based basis for reducing future exposure in the relevant operating contexts.
• Evidence of documented response: A funded, independently monitored evaluation is evidence that MOD considered a candidate control measure through a procedurally defensible process.
• Improved decision record: A clear evidence trail and documented rationale can be valuable whether MOD ultimately proceeds, pauses, or declines after testing.

The estimated net incremental cost to the MOD of the six‑month Pilot Programme remains a provisional planning figure pending MOD scoping. The more prudent point is not any single ratio; it is that a documented good‑faith evaluation of an available control measure may materially improve MOD’s future decision record while also generating operational evidence.

DM‑XTech further notes that the proposed programme begins with an Engine Test Bay Precursor Phase whose incremental cost should be materially smaller than a full operational pilot, although the number should still be validated with the host maintenance organisation and MOD sponsor. Even if the MOD’s legal advisers are not yet prepared to support the full Pilot Programme commitment, the ground phase alone may still be the most proportionate way to improve the decision record.

The story in brief: Following years of public concern and claims activity around UK military helicopter exhaust exposure, a British fuel technology company has developed and independently tested an aviation fuel that materially lowers naphthalene content and soot output while being presented as specification‑compliant. The fuel has been formally offered to the Ministry of Defence for controlled evaluation. The MOD has not yet agreed to run a trial.

Standard jet fuel contains a chemical called naphthalene, in concentrations of up to 30,000 parts per million maximum (3% by volume, typically 8,000–20,000 ppm). When naphthalene burns in a helicopter engine at low power, during hovering, patrolling or training, it does not fully combust. Instead, it breaks down into a cascade of toxic soot particles containing PAHs. Some of these compounds are subject to established toxicological concern.

Helicopter engines, unlike jet aircraft engines, are frequently run at partial power. Helicopter rotor blades push exhaust air back toward the aircraft. The result is that crew breathe recycled, soot‑laden exhaust throughout a sortie. DM‑XTech’s fuel, DoC Jet A-1, contains less than 100 parts per million of naphthalene. In independent university testing, it reduced soot emissions from the same engine by up to 80%. It is certified to every applicable UK military fuel standard. It is proposed for controlled evaluation without any planned aircraft modification at pilot stage.

• Public reporting states that the MOD settled a claim involving the estate of Flight Sergeant Zach Stubbings in January 2024.
• Public reporting in 2025 referred to around 180 current and former military helicopter aircrew pursuing claims against the MOD.
• DM‑XTech’s aviation fuel, DoC Jet A-1, was independently tested by TERC and achieved up to an 80% reduction in soot mass on a standard military gas turbine engine.
• DoC Jet A-1 is presented as DEF STAN 91‑091 compliant and is intended to be evaluated without planned hardware modification; MOD process and QA acceptance still need to be confirmed.
• DM‑XTech has formally submitted a proposal to the MOD for a six‑month funded Operational Pilot Programme at a single airbase. Provisional planning estimate only; final scope and cost would need MOD validation.
• DM‑XTech is available for interview and for technical briefings to specialist journalists. TERC researchers are available for independent scientific comment.