SPEAKER PRESENTATIONS - ALPA

AIR CARGO SAFETY SYMPOSIUMAugust 17, 2017

SPEAKER PRESENTATIONS

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Presented to:

By:

Date:

Federal AviationAdministration

Air Cargo:

Cargo Safety SymposiumPatricia Williams Deputy Division Manager, AFS-301A

August 17, 2017

Cargo Focus Team

Review & Update


Topics

• Why - Background

• What - Mission & Vision

• Who - Team Structure

• Accomplishments

• In Progress

• Impact on Safety

• Resources

2


Background

Afghanistan accident led to formation of a team to determine whether systemic problems exist in handling special air cargo loads

3

• Established via FAA Notice 8900.262


Background

NTSB final report on from B-747 accident published July 29, 2015

Six safety recommendations

4

• A-15-13: Revise guidance to specify use of (FAA)-approved data for methods for restraining special cargo. Remove FAA accepted data.

• A-15-14: Create a loadmaster certification.

• A-15-15: Review manuals to ensure cargo operations is based on relevant FAA-approved data (special emphasis on special cargo restraint).

• A-15-16: Define responsibilities for principal inspectors for the loading, restraint, and documentation.

• A-15-17: Initial and recurrent training for principal inspectors

• A-15-18: Surveillance deferrals.


Background:

Part 121 WBCP Review Findings

5

•Source documents• Programs are not derived from approved sources

(TC/STC WBMs) • Operating limitations exceeded• WBMs - Not provided or cannot be found

•Cargo Restraint Methods• Use of procedures not defined by TC/STC WBM • Computer W+B Systems – not validated, not

controlled


Background:

Three Classifications of Cargo

6

Bulk Cargo• Individual pieces loaded and

not restrained

• (Lo-Lo = lift on–lift off)

• Aircraft structure provides necessary restraint for flight loads.

• Requires some loading skills.


Background:


7

Unit Load Device (ULD)• Rolled on - rolled off.

(Ro-Ro)• Grouped within a

device.• Restraint provided by

system of locks restraining the device.

• Certain skills are needed, but restraint calculations not required


Special cargo • Requires advanced skills

to determine how much restraint is needed based on calculations and unique methods defined in the airplane’s weight & balance manuals.

• NOTE: Some airplanes do not have structural provisions for special cargo

• More common on freighter conversions.

Background:


8


9


Background:

Special Cargo

Past practices:

• All outboard tiedowns are in passenger seat tracks. – This is not permitted due

to low strength of track.• Side of vehicle tiedown

locations not permitted.

10


CFT Mission & Vision

• Enhance the safety of air cargo operations.

• Directly support FAA field personnel

• Act as a focal point for the integrity of air cargo operations

• Serve as the FAA’s technical

experts in air cargo operations

11


Team Structure

• Cargo Focus Team (CFT) includes cargo subject matter experts from both Aircraft Certification Service (AIR) and Flight Standards Service (AFS)• Transport Airplane Directorate (ANM-100)

• Air Transport Operations (AFS-200)

• Aircraft Maintenance Division (AFS-300)

• Field Inspectors (CMO- Detailee)

• National Field Office

12


Accomplishments• Safety Alerts for Operators (SAFO)/Information for Operators (InFO)

– SAFO 13005 Part 121Air Carriers Transporting Heavy Vehicle Special Cargo Loads– SAFO 13008 Part 121 Air Carriers Performing Special Cargo Loads Operations– SAFO 17003 Non-compliance with a Manufacturer’s Federal Aviation Administration (FAA)-

approved Aircraft Weight and Balance Manual (WBM) – SAFO 17004 Cargo Retention Methods Using Pallets Straps

– InFO 13012 FAA-approved Boeing 747 Sample Weight and Balance Manual (WBM)– InFO 15010 Approved WBM Supplements for Certain Boeing Aircraft

• Notices:– N8900.317 Accepting/Revising Manuals for All Parts 91K, 121, 125, and 135 Certificate

Holders/Operators Transporting Cargo on Transport Category Aircraft– N8900.262 Review of Weight and Balance Control Programs Including Special Cargo

Operations

• Advisory Circular (AC) 120-85A, Air Cargo Operations – Dated 6/25/15 – Provides guidance for developing a cargo operations program as part of the weight and

balance control program (WBCPs).

13


In Progress:

Evaluations & Notices• CFT is using Safety Assurance System (SAS)

Certificate Holder Evaluation Process (CHEP) to evaluate WBPs

• Notice on delineation of WBP responsibilities: • Guidance to principal inspectors on certificate

management responsibilities• Overview of the responsibilities between the ASI

disciplines and aircraft certification. (NTSB A-15-16)• Display the overlap, and specific areas of discipline

responsibility in relation to elements of weight and balance, airplane limitations, and cargo operations

14


In Progress:

OpSpecs

• E096 – Title Change• Revised from Weight and Balance Control

Procedures to Aircraft Weighing• A002 Definitions

• Updated with definitions for Bulk cargo, Special Cargo and Certified ULD Cargo

• Cargo OpSpecs• A196 – Bulk and Certified ULDs• A396 – 300 series OpSpec for Special Cargo

15


In Progress:

Loadmaster – Industry Tasking

• Aviation Rulemaking Advisory Committee (ARAC)

• Accepted the task on March 23, 2016. • ARAC Loadmaster Certification Working Group

(LCWG) has been formed• Report & recommendations due for FAA review

and acceptance no later than 24 months from the publication date of this notice in the Federal Register, FY2018.

16


In Progress:

Air Cargo Course• Two part course:

• FAA27100256 – Air Cargo Operations web-based training (WBT)

• FAA21000056 – Air Cargo Operations Practical Applications Workshop (PAW) that will be held at the FAA Academy in Oklahoma City, OK.

• First FAA Class to ASIs 4/6/2017• FAA will make these courses available for

industry participation FY18. • Please direct all questions to Ms. Connie

Stone at (405)-954-6346•

17


• SAS CHEP provides standard policies and procedures to evaluate Title 14 of the Code of Federal Regulations (14 CFR) parts 121, 135, and 145 certificate holders.

• CHEP evaluation used at the national, regional, and office levels and is conducted at the national level by the Flight Standards National Field Office (AFS-900).

• CHEP verifies compliance with applicable regulations.• CHEP selection process is data-driven, random and/or

by request.

18

In Progress:

SAS CHEP


• CFT is using SAS CHEP to evaluate certificate holder’s

weight and balance programs (WBP).

• CFT Evaluation team will use the same SAS data collection tools (DCT) that a certificate management team uses as part of normal oversight.

• CFT CHEP is a custom data collection tool (CDCT) created from several of the design assessment DCTs available in SAS that focus on topics such as Flight/Load Manifests/W & B Procedures, Carriage of Cargo, Aircraft Requirements, WBP, and Cargo Handling Equipment, Systems, and Appliances.

19

In Progress:

SAS CHEP

Note: Certificate Management Team retains responsibility for day-to-day certificate management; CFT CHEP is only working to evaluate the Weight & Balance Program.


In Progress:

WBCP Reviews

• 29 Cargo operations / 49 Passenger operations

• 25 of 78 initial reviews complete • 86% of Cargo Operators

• 19 of 78 reviews concurred/closed • 66% of Cargo Operators

• Estimate completion of part 121 in 2020• Passenger Operations and Cargo

• 57% of cargo between the Americas and Europe is on a passenger airplane (Boeing)

• U.S. passenger service flew 7.95 billion revenue ton miles of cargo last year. (FAA)

August 17, 2017 20


21

NOTE:

Location of Part 121 Cargo Operator CMOs

Number shown in

box is the number

of certificates at

office

2

3

1

11

2

3

1

1

5

3

3

1


22

23

1

11

2

3

1

1

5

3

2

3

1

Cargo Workshop23 CMOs

CFT Outreach Completed

IATA

ALPAA4A

DoD

CFT Outreach not completed

Number shown in

box is the number of

certificates at office

at the time of CFT

Outreach seminar. SAE

SAE/ IATA April 2017

In Progress:

CFT Outreach


23

CFT has enhanced safety through:

• Reducing non-compliant practices through CFT reviews

• Guidance:

• AC 12-85A, SAFOs, InFOs

• Enhancing cargo knowledge within the FAA:

• Outreach

• Enhanced FAA cargo course

• Custom cargo workshop for PIs

• Interdependence with CMOs

Impact on Safety


Impact on Safety

24

Working with industry partners to create expanded methods for cargo restraint

• Atlas, Boeing, Cargolux, GE, Kalitta, National, Rolls, UPS, and VRR

Working with SAE and IATA for compliant cargo practices

Consistency

• Level playing field with U.S. carriers

• Outreach to FCAAs


Resources - Cargo Focus Team

• Cargo Focus Team (CFT) exists as a permanent

technical resource for cargo operations

• For cargo operations questions or suggestions contact CFT @ [email protected]

• FAA Air Cargo Operations site: https://avssp.faa.gov/avs/afs300/SharedInfo/CargoInfo/Pages/Air%20Cargo%20Operations.aspx

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Presented to:

By:

Date:


Air Cargo:

Operation

Specifications

A002, A196, A396

Air Cargo Safety SymposiumStephen Moates, AFS-220 ManagerAugust 17, 2017


Overview

• Standardization• Risk Mitigation• Consistency – Operation /

Oversight / Manuals• Identify Limitations by Specific

Aircraft• Recognition of Special Cargo

Challenges• Proper relationship of manuals• Tracking of Aircraft & Programs

2


A002

• Industry requested • Provide standard definitions for common

understanding• Provide baseline for development of FAA

guidance and information• Developed in a collaborative effort between the

FAA and Industry• OpSpecs allow for ease of changes as the

FAA/Industry work on refinement of the process versus rule making

3


A 196 – Bulk / ULD Cargo

• Developed in response to NTSB recommendations

• Standardizes the approval process for Bulk and Cargo Loading systems authorizations

• Incorporates lessons learned through the Cargo Focus Team

• A collaborative effort among all stake holders• Approval at local CMT level

4


A396 - Special Cargo

• Developed in response to NTSB recommendations

• Special cargo requires expert knowledge• Uses FAA resources for continued

standardized process for special cargo• A collaborative effort among all stake holders• Requires headquarters concurrence prior to

issuance so as to provide expert knowledge of process on a continual basis

5

Air Line Pilots Association, Int’l

ARAC

Loadmaster Certification

Working Group (LCWG)

Presented by co-chairs

Mark Phaneuf – ALPA

Martin McKinney - UPS


▪ Formed as the FAA’s method of responding to one of the

NTSB recommendations from the National Airlines accident

to certificate Loadmasters.

▪ Industry lead team (Boeing, FedEx, Kalitta, Alaska Air,

Northern Air Cargo, Atlas Air, National Airlines, Cargo

Airline Association, National Air Carrier Association, UPS,

Professional Loadmaster Association, ALPA)

Working Group Purpose


▪ Provide advice and recommendations to the ARAC on whether

safety would be enhanced if persons engaged in the loading and

supervision of the loading of special cargo, to include the

preparation and accuracy of special cargo load plans, be

certificated.

▪ Determine the effect of its recommendations on impacted

parties.

▪ Develop a report containing recommendations based upon

its analysis and findings.

Tasking


▪ Total of 6 face to face mtgs and 7 Telcons

▪ Group Met November 9-10 at Atlas Air Training Facility -

Huntsville, AL

– To observe “special cargo” loads. The group was able to observe

a 747-400F download and upload, and special cargo that had

been prepared for upload.

– NTSB presentation of the National Airlines 747-400 BCF accident

at Bagram Air Base, for a baseline foundation to the group and

to explain the recommendations made to the FAA in order to

understand the background and development of the ARAC

tasking

Progress and Status


▪ The group is reviewing Part 121 accident data between

1996-2016 with cargo shift or damage to the aircraft from

cargo

▪ Determining which persons are responsible for performing

the functions necessary for special cargo movements

(Loadmaster is undefined in the commercial world):

– SCAF (Special Cargo Analysis Function) – load analysis and

planning for special cargo loads

– Special Cargo Loading Supervisor – validation that special cargo

loading plan was implemented correctly

Progress


▪ Team reviewed 8 options for certification and assigned

those options to small teams for a deep dive analysis to

report back to the group.

– This has continued to be the bulk of our work

– We continue to use the Likert scale and scoring methodology

– This was a helpful exercise which clearly illustrated the

effectiveness for enhancing safety for each option.

Progress


▪ The team reviews progress being made to update Advisory

Circular 120-85A, Air Cargo Operations that includes Bulk

Cargo, Certified Unit Load Device (ULD) and Special Cargo

definitions.

▪ The team has unanimously agreed that the SCAF function,

if certificated, would make a positive enhancement to

safety.

Progress


▪ Team is in the process of determining what method should

be used and what the most effective process would look

like.

Progress


▪ Our FAA economist from FAA APO continues to work with

the team and is applying his economic analysis and scoring

as our decisions narrow and the team continues to drill

down into our list of Part 121 ‘special cargo’ accidents.

▪ The team has begun to develop the report containing

recommendations based on our analysis and findings it is

due to ARAC May, 2018.

Progress

Presented to:

By:

Date:


Air Cargo:

Air Safety Cargo SymposiumPatricia Williams, Deputy Division Manager, AFS-301A

August 17, 2017

IATA & SAE

Procedures


Overview

• NTSB Recommendations

• Regulatory Path

• IATA and SAE Procedures

August 17, 2017 Cargo Focus Team 2


NTSB Recommendations

A-15-13

• Revise the guidance material in Advisory Circular (AC) 120-85, “Air Cargo Operations,” chapter 201(a)(4), to specify that an operator should seek Federal Aviation Administration (FAA)-approved data for any planned method for restraining a special cargo load for which approved procedures do not already exist, and remove the language in the AC that states that procedures other than those based on FAA-approved data can be used.



NTSB RecommendationsA-15-15

Add a special emphasis item for inspectors of 14 Code of Federal Regulations Part 121 cargo operators to review their manuals to ensure that the procedures, documents, and support in the areas of cargo loading, cargo restraint, and methods for securing cargo on transport-category airplanes are based on relevant FAA-approved data, with particular emphasis on restraint procedures for special cargo that is unable to be loaded via unit loading devices or bulk compartments.

• Note: SAE and IATA procedures are not FAA approved.

Cargo Focus Team 4August 17, 2017



§91.1 Applicability.

(a) Except as provided in paragraphs (b) and (c) of this section and §§91.701 and 91.703, this part prescribes rules governing the operation of aircraft (other than moored balloons, kites, unmanned rockets, and unmanned free balloons, which are governed by part 101 of this chapter, and ultralight vehicles operated in accordance with part 103 of this chapter) within the United States, including the waters within 3 nautical miles of the U.S. coast.

Regulatory Path: Operating Limits

Operation of aircraft is covered by 14 CFR part 91


Cargo Focus Team 6


Operation of aircraft is covered by 14 CFR part 91

§91.9 Civil aircraft flight manual, marking, and placard requirements.(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the OPERATING LIMITATIONS

specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.

August 17, 2017



Regulatory Path: Operating Limits14 CFR 21.41: Type certificate includes

OPERATING LIMITATIONS

14 CFR 25.1581: Airplane Flight Manual must contain:

(1) Information required by Secs. 25.1583 through 25.1587.(2) Information that is necessary for safe operation because of design, operating, or handling characteristics.(b) Approved information. Each part of the manual listed in Secs. 25.1583 through 25.1587, that is appropriate to the airplane, must be furnished, verified, and approved

14 CFR 25.1583: OPERATING LIMITATIONS(c) Airplane Flight Manual or separate weight and balance control and loading document that is incorporated by reference in the Airplane Flight Manual: (2) LOADING INSTRUCTIONS necessary to ensure loading of the airplane within the weight and center of gravity limits, and to maintain the loading within these limits in flight.

OPERATING

LIMITATIONS

§ 25.1581,

§ 25.1583

Aircraft Flight

Manual (AFM)

Type Certificate

§ 21.41




What do ....

• “(2) LOADING INSTRUCTIONS necessary to ensure loading of the airplane within the weight and center of gravity limits, and to maintain the loading within these limits in flight. “

.......actually include?



• For a cargo airplane, includes all of the weight and CG diagrams, local limits (running load, area load, lateral load, etc.) in the WBM

AND

• Types of payloads certified to load:• Bulk compartments• Which ULDs can be used in the cargo loading

system• Special Cargo Provisions including restraint locations

and allowables.

Note: Airworthiness Directive 2015-14-09 preamble addresses this topic



Cargo Focus Team 10

• Principal Inspectors are not authorized to accept/approve processes, procedures and/or manuals that exceed the operating limitations of the AFM/WBM; doing so contradicts §91.9(a) and FAA Order 8110.4C.

• This practice has the potential to lead to noncompliance and unsafe conditions.

August 17, 2017




Takeaways• Instructions for loading cargo are required by 14 CFR 25.1583• Operating instructions for loading the cargo defined in the Weight

and Balance Manual (WBM)• 14 CFR 91.9(a) requires compliance with operations limitations in

WBM• If changes to operating limitations defined in the WBM are

desired, an Amended/Supplemental Type Certificate is required.• Procedures such as IATA/SAE which do not alter these limitations

are still permitted (i.e. pallet build up, scales)• Operation outside of WBM limits is a violation of 14 CFR 91.9(a)• It is not possible comply with 14 CFR 91.9 (a) if you cannot find

the TC/STC WBMs




IATA and SAE have expanded their airplane cargo loading procedures from what occurred in the ware house to what can happen inside the airplane.

Question: Can we use these IATA and SAE procedures?

Answer: It depends…..

Many of the procedures enable operators to achieve the WBM operating limitations.

Some procedures are outside of the limitations of the WBM and are not permitted.

IATA and SAE Procedures



IATA and SAE Procedures

WBM

Operating

Limitations

IATA

SAE

MIL-Spec

Etc.

You can use these

limitations

You can NOT use

these limitations.

They exceed WBM

limitsThese procedures are

within WBM limits


FAA Outreach

Collaboration

Undeclared Hazardous

Materials

Janet McLaughlin

Director, FAA Office of Hazardous

Materials Safety


Vision

2

A collaborative program, to reduce the risk of undeclared Hazardous Materials in air

transportation by developing a messaging system aimed at assisting shippers in identifying

Hazardous Materials prior to offering the material into air transportation.

Target audience(s)

•Unconventional, unwitting HM shippers

•Forwarders

•Air carriers

Stakeholders –

•Passenger Air Carriers

•Cargo Air Carriers

•Freight Forwarders

•E-commerce shippers

•Shippers


Problem Statements

3

• To reduce the risk of undeclared Hazardous Materials in air transportation, we need to work collaboratively to assist shippers.

• A good understanding of the impact and risk of undeclared Hazardous Material shipments by air is essential to identifying solutions to the problem.

• The presence of undeclared Hazardous Materials in air commerce represents a clear danger to carriers, the commerce system, and the public, so we all must work together to reduce this risk.

• The proliferation of e-commerce and the nontraditional economy has resulted in an amorphous population of unorthodox, unwitting HM shippers who do not have rigorous management systems and controls to ensure compliance.

• Increasingly complex regulations and varying oversight/enforcement schemes increase likelihood for undeclared HM to enter air commerce.

• Capabilities for detection of HM at point of tender are neither highly developed nor reliably effective.


Undeclared Incidents

CY2011 - 2016

In calendar year 2011 through 2016, there were 3,114 reported

undeclared Hazardous Materials air incidents.

These incidents resulted in the following “Undeclared Sanction

Amount by Entities”:

» Shipper - $12,418,735.00» Air Carrier - $162,250.00» Foreign Air Carrier - $625,000.00» Indirect Air Carrier - $14,000.00» Passenger - $353,887.00» Personal/Business - $20,000.00» Repair Station - $315,000.00» Total - $13,908,872.00

4


Undeclared Incidents

CY2011 - 2016

5

CY2011

CY2012

CY2013

CY2014

CY2015

CY2016

Incidents 184 194 152 164 112 117

050

100150200250

Nu

mb

er

of

Incid

en

ts

All Release

CY2011

CY2012

CY2013

CY2014

CY2015

CY2016

No Release 538 593 588 554 452 466

0200400600800

Nu

mb

er

of

Incid

en

ts

No Release

All Release

No Release


Most Frequent Explanations for

Undeclared Shipments

Federal Hazardous Materials experts believe

that the most frequent explanation for

undeclared shipments is:

Shipper’s lack of knowledge—

an unawareness or misunderstanding of the requirements for properly declaring and transporting Hazardous Materials.

6


Conclusion

To reduce the risk of undeclared Hazardous

Materials, in air transportation, FAA will

initiate a collaborative effort with affected

stakeholders aimed at informing shippers

especially e-commerce shippers what

materials are considered Hazardous

Materials when shipped by aircraft.

7

Mitigation Strategies for Transporting Batteries on Aircraft

Captain Bob BrownIndependent Pilots Association

E-ULD Fire Detection/Suppression

Enhancing Safety for the Aviation Community

E-ULD Fire Detection/Suppression

Goal is 6+ Hours of Fire Containment

Safety Task Force E-ULD Testing

• Test 1– FAA Class-A Fire with fully loaded ULD.

Detected within 2 minutes and extinguished within 30 seconds

• Test 2– FAA Class-A Fire with ½ load ULD.

Detected within 1 minute and extinguished within 30 seconds

• Test 3– Challenging Group A-Plastics fully loaded ULDDetected in 1 minute and Extinguished within 20 seconds

The Path Forward

UL Science Evaluates Design and Conducts Additional

Testing

FAA Supplemental Type Certificate Issued

Airline Industry has a path forward to begin Battery

Testing

Safe2Fly3rd Party Review & Risk Assessment

50%

Battery Science Labeling

Database Risk AssessmentTransport,

Inspect of RejectIdentify and Prosecute

Counterfeit

Packaging

or

Design, Manufacture& Certification

Cargo and Passenger Airlines Benefit

• Batteries from reputable manufacturers and risked as safe via SMS process can be “fast tracked” for transport

• Airlines and Government will have objective data for SMS risk assessments

• Pilots will have confidence in a objective and impartial Third party review and certification process

Safe2Fly

© Copyright 2017 UL LLC. All rights reserved.

J. Thomas Chapin, Ph.D.Vice President Research

Corporate Fellow


Cell Failure and ISC Behavior – How and Why?

Dendrite

Process Issue(s)

MechanicalAbuse

UnstableDesign

Internal Short-Circuit

Overcharge

Imbalance

DropCrush

Material Properties

Impact

Shock / Vibration

Contamination

Burrs

Other (bad welds, loose metal parts, etc.)

Severe Environment

Abnormal Pressure Abnormal

Temperature

Tab/electrode misalignment

Improper Separator

Over design

Handling

Use

ManufactureOperation

Design

1


Cell ISC Failure Test Methods

2

Slow SpeedNail Penetration

ITRI

Low-Melting PointMetal/Alloy

Sandia

Forced ISC (FISC) TestBAJ Pinch Test

Oak Ridge

Indentation InducedISC (IIISC) Test

UL/NASA

ARC Thermal Abuse test

Hot Pad test


Aircraft Battery Cargo Assessment

“Unknown” Battery Cargo

Uncharacterized cellsUnknown/counterfeit cellsUnstable batteriesUnstable batteriesImproperly packaged batteriesImproperly labeled packageUnidentified packageUnverified productsUnverified cargo

“Known” Battery Cargo

“Known” cellsCertified cells/batteriesCertified batteriesCertified batteriesQualified packageVerified labeling Verified identificationCertified productsFire suppression system

Electrical Abuse

Imaging/Detection

Certification

Validation

Validation

Imaging/Validation

Detection/Suppression

Physical Abuse

Testing

3


Mitigating the Fire Risks

v Safety in Designv Product

Certificationv Construction

codesv Maintenance and

housekeeping

Precipitating

Hazard

Ignition

Sources

Fuels

Enabling

Hazards

Vulnerability

HazardFire Impact

PREVENTING THE FIRE MANAGING THE FIRE EVENT

v Intentionalv Human errorv Equipment

malfunctionv Chemical

reaction

v Internal sourcesv External sources

v Combustible items

v Additional combustible materials (furnishings, interior finish, etc.)

v Fire and smoke paths through building structure

v Fire spread to adjoining areas

v Smoke spreadv Blocked agress

pathsv Fire spread to

adjoing buildings

Fire growth

control

Life safety

and

property

protection

Fire

mitigation

v Injuries/fatalities

v Property Loss

v Reduced oxygen environment

v Aspirated gas and smoke detection

v Fire extinguishment systems

v Fire resistancev Fire containmentv Egress pathsv Designated safe

zones

v Firefighter access v Emergency

service responsev Search and

rescue

Ignition

Event

Preventive

measures

Tools

Strategy

NFPA 550 4

Bob RichardPresident Hazmat Safety Consulting LLC

[email protected]

www.hazmatsafety.com

Multilayered LithiumBattery Risk Reduction

Undeclared Dangerous Goods

Undeclared air shipments of hazmat pose a significant risk to public safety.

Undeclared shipments of hazmat occur too frequently but we don’t have data on the frequency or quantity.

The most frequent reasons for undeclared shipments include: 1. shipper's lack of knowledge--an unawareness or misunderstanding of

the requirements for properly declaring and transporting hazmat; and2. economic--an attempt to avoid additional costs associated with

shipping regulated hazmat,

To the extent that such undeclared shipments are discovered, the discovery typically occurs in one of the following ways:

1. an accident or incident (e.g. spill or discovered leaking package in a parcel facility);

2. during a routine cargo inspection; or 3. when a complaint is filed to enforcement staff.



Lithium Battery Dangers


Risk Mitigation must be layered

• Less complicated regulations• Classify based on inherent risk• Improved packaging• Enhanced enforcement and more aggressive penalties• Containment systems for passenger aircraft• ULDs and FRCs• Cargo Liner• Halon Fire Suppression


Less complicated Regulations

ICAO Statement:The risks posed by non-compliant shipments, both deliberate and inadvertent, needs to be addressed.

Fully complying with the complex regulations can be difficult if not impossible to do.

The current regulatory framework depends on shippers knowing that batteries and cells have passed tests in accordance with the UN Manual of Tests and Criteria.


Classification should be based on inherent risk

• The risks posed by lithium batteries varies depending on size, chemistry, design type and quantities shipped and some may pose little risk to aircraft.

• There is no way to distinguish between different batteries types presented for transport other than under the two major groups, lithium ion or lithium metal.

• ICAO’s governing bodies have questioned whether there was a mechanism for ICAO to establish greater granularityand have been advised that this would be an issue for the Sub-committee to consider.


Classification should be based on inherent risk

• New, “safer” technologies and chemistries being

developed • American Engineer Invents A Battery That Cannot Explode

https://www.androidheadlines.com/2017/02/american-engineer-invents-a-battery-that-cannot-explode.html

• Different form factors or chemistries present different risks.

• Provide incentives for development of “safer”

batteries with less stringent regulations?


Improved Packaging


Enhanced Enforcement and Monitoring

• Safe2Fly

• Enhanced inspector training

• Enhanced authority over foreign shippers and improved coordination with other governments

• China to Hong Kong issue needs to be resolved


Containment systems for passenger aircraft


Fire Suppression System

Halon system is the second line of defense. • Designed for fires likely to occur • Lithium batteries were not considered in design of

system. • Halon system may or may not be effective in

controlling PED fires, i.e., the reliability of the system is negatively influenced by PED fires.

Gill Liner only provides minimal protection and if compromised the Halon is not effective.


Fire Suppression System

Need a more aggressive program to replace the Gill liner and Halon Fire Suppression SystemsFire Hardening Cargo Compartments• Working with airlines to design and develop materials that will protect

an aircraft from the catastrophic effects of a lithium battery fire. The material(s) will line the cargo compartment and insulate the aircraft structure, wiring, hydraulics and flight controls from the intense heat generated during a lithium battery fire.

Cargo Liners: Materials used to cover the interior walls and ceilings of the baggage and freight compartments of aircraft.


Real Life Example—The Problem

• US Part 121 Supplemental Airline Miami Air recently signed contracts

to carry two professional sports teams.

• As part of their FAA-accepted, Part 5 Safety Management System

(SMS), Miami Air discovered that these new sports teams had been

flying with large quantities of spare Lithium batteries.

• This large amount of spares was poorly packaged, thrown loosely

into a case and placed in the cargo compartments of the previous

operator on every flight, undeclared.

• Like most passengers, the sports teams were unaware of the danger

of Lithium batteries!

• Risk assessment: High-unacceptable


Real Life Example—A solution

• Miami Air thoroughly examined the problem.

• Telling the teams to not carry these batteries was a problem because

the teams depend on having these spare batteries during the games.

Additionally, regulations allow for each passenger to bring up to two

spare Lithium batteries onboard the cabin.

• Miami Air conducted research on systems that could allow for the

safe transport of these batteries.

– They found that the bar is really low in the industry. The current solutions do not

fully solve the problem. Most carriers use the “Pizza Delivery Oven-type” bags

that contain the fire, but do not deal with the toxic fumes

• Eventually, Miami Air found a manufacturer that created a full fire

and fumes containment system for the teams to safely bring these

batteries on board as carry on.


Bob RichardPresident Hazmat Safety Consulting LLC

[email protected]


Commercial

Aviation

Safety

Team

WHITE HOUSE COMMISSION ON AVIATION

SAFETY AND THE NATIONAL CIVIL AVIATION

REVIEW COMMISSION (NCARC)

1.1 . . . Reduce Fatal Accident Rate . . .

• . . . Strategic Plan to Improve Safety . . .

• . . . Improve Safety Worldwide . . .

CAST BRINGS TOGETHER KEY STAKEHOLDERS TO

COOPERATIVELY DEVELOP AND IMPLEMENT A

PRIORITIZED SAFETY AGENDA.

* Representing P&W and RR

** Observer

A4A

AIA

Airbus

ALPA

ACI–NA

CAPA

IATA**

NACA

Boeing

GE*

RAA

FSF

DOD

FAA

NASA

ICAO**

TCCA

NATCA

NTSB**

EASA**

Industry Government

Commercial Aviation

Safety Team

CAST GOAL

CAST came together in 1997 to form an unprecedented industry-Government partnership. Voluntary commitments, data-driven risk management, implementation-focused. Goal:

Reduce the U.S. commercial aviation fatality

risk by at least 50% from 2010 to 2025.New

Reduce the US commercial aviation fatal accident rate 80%

by 2007.Original

CAST SAFETY STRATEGY

Influence SEs –

Worldwide

Data

Analysis

Set Safety

Priorities

Achieve consensus on

priorities

Integrate into existing

work and distribute

Implement Safety

Enhancements (SE) –

United States

Agree on

problems and

interventions

APPROVED PLAN

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

Re

sou

rce

Co

st (

$ M

illio

ns)

Risk Reduction

Total Cost in

$ (Millions)

2007 2020

0%

25%

50%

75%

100%

Ris

k E

lim

ina

ted

by

Sa

fety

En

ha

nc

em

en

ts

$

$ $ $

$

RESOURCE COST VS. RISK REDUCTION

Do

lla

rs/F

lig

ht

Cyc

le

Part 121 Aviation Industry Cost Due to Fatal/Hull Loss Accidents

100

80

60

40

20

0

Historical cost of

accidents per flight cycle

Savings ~ $71/Flight Cycle or

~ $852 Million Dollars/Year

Cost of accident fatalities

following implementation of the

CAST plan @ 2020 levels

20202007

COST SAVINGS

Study Prioritization

(Fleet Risk)

0

5

10

15

20

25

30

1% 10% 100%Fatality Risk - (Severity)

Yrs

to

1 o

r m

ore

exp

ecte

d a

ccid

en

ts

Risk Level Appropriate for Study1 accident in 20 yrs

RR SEs Risk Levels

Fatality Accident Expectation @ Current Accident Rate

Risk Level Appropriate for Monitoring

STUDY PRIORITIZATION (FLEET RISK)

Ye

ars

to

1 o

r M

ore

Exp

ec

ted

Ac

cid

en

ts

Fatality Risk (Severity)

Completed, 76Completed

(R&D), 10

Underway, 25

Underway (R&D), 11

CAST – SAFETY ENHANCEMENTS

SAFETY PORTFOLIO MONITORING

SE Title OutputLead

OrganizationDue Date

SE 127 Cargo - Cargo Fire Management Output 5 JIMDAT 8/31/2017

SE 186 TCAS - Sensitivity Level Command Output 4 FAA AJI 12/31/2017

SE 199 ASA - Training - Enhanced Crew Resource Management Training Output 2 A4A 8/31/2017

SE 213 RNAV - Safe Operating and Design Practices for STARs and RNAV Departures Output 2 FAA AFS/A4A 8/31/2017

SE 213 RNAV - Safe Operating and Design Practices for STARs and RNAV Departures Output 3 FAA ATO 8/31/2017

SE 213 RNAV - Safe Operating and Design Practices for STARs and RNAV Departures Output 4 FAA ATO 8/31/2017

SE 217 RE - Airline Operations and Training - Takeoff Procedures and Training Output 2 A4A 7/31/2017

SE 218 RE - Design - Overrun Awareness and Alerting Systems Output 3 A4A 6/30/2017

SE 219 RE - Air Traffic Operations - Policies, Procedures, and Training to Prevent Runway Excursions Output 1 FAA ATO 6/30/2017

SE 219 RE - Air Traffic Operations - Policies, Procedures, and Training to Prevent Runway Excursions Output 2 FAA ATO 6/30/2017

SE 227 TOMC - Air Carrier Procedures for Takeoff Configuration Output 1 A4A 4/30/2017

SE 227 TOMC - Air Carrier Procedures for Takeoff Configuration Output 3 FAA AFS–200 8/1/2017

SE 227 TOMC - Air Carrier Procedures for Takeoff Configuration Output 4 AIA 4/30/2017

SE 228 TOMC - Airplane Design Features to Facilitate Proper Takeoff Configuration Output 1 AIA 10/31/2017

SE 229 TOMC - Takeoff Configuration Warning System Maintenance and Operational Assurance Output 1 AIA 10/31/2017

FATALITY RISK

(EQUIVALENT FULL PLANELOADS)

CAST PORTFOLIO ASSESSMENT –CARGO OPERATIONS

Implementation & Effectiveness

Fatal accidents review (6): Four accidents with common causal factors with

passenger operations Two accidents with causal factors specific to all

cargo operations

Distinctions between cargo and passenger operations: Operating environment Logistics/support infrastructure

Key Government and industry initiatives underway: Cargo Focus Team Loadmaster Certification Working Group Cargo Ops Spec development AC 120–85A being revised

Portfolio Assessment

Accident Review

Cargo Operations

Mitigations Underway

CAST Deployed SEs Applicable to Cargo Accidents

Safety Enhancement

Air Tahoma

08/13/2004

FUEL

USA Jet

07/06/2008

CFIT

FedEx

03/23/2009

ARC

UPS

09/03/2010

F–NI

National Air

04/29/2013

RAMP

UPS

08/14/2013

CFIT

2. CFIT SOPs - One Project

3. CFIT PAI-Vertical Angles (PAI 1-7, 11)

10. CFIT Proactive Safety Programs (FOQA + ASAP)

11. CFIT CRM Training

12. CFIT Prevention Training - One Project

14. ALAR Policies (Safety Culture)-CEO and DOS more visible (1-2)

15. ALAR Policies (Safety Culture)-Safety info into manuals (3)

23. ALAR Flight Crew Training - One Project

26. LOC Policies and Procedures - SOP - One Project

27. LOC Policies and Procedures - Risk Assessment and Management - One Project

29. LOC Policies and Procedures - Policies - Flight Crew Proficiency Program (2)

30. LOC Training - Human Factors and Automation - One Project

85. Vertical Situation Display

120. TAWS Improvements (GPS)

121. Cargo Loading Training and SOPs

131. Cargo Safety Culture

Applicable = Implemented

Applicable CAST SEs Not in Effect at Time of Accidents

Applicable = Implemented

Safety Enhancement

Air Tahoma

08/13/2004

FUEL

USA Jet

07/06/2008

CFIT

FedEx

03/23/2009

ARC

UPS

09/03/2010

F–NI

National Air

04/29/2013

RAMP

UPS

08/14/2013

CFIT

127. Fire Management

194. ASA - Standard Operating Procedures Effectiveness and Adherence

198. ASA - Scenario-Based Training for Go-Around Maneuvers

199. ASA - Enhanced Crew Resource Management Training

200. ASA - Virtual Day-VMC Displays

216. RE - Airline Operations and Training - Flight Crew Landing Training

219. ATO Policies and Procedures

223. Cargo - Hazardous Material Fires - Prevention and Mitigation

224. Cargo - Hazardous Material Fires - Enhanced Fire Detection Systems

225. Cargo - Hazardous Material Fires - Containment and Suppression

226. Cargo - Hazardous Material Fires - Enhanced Protection of Occupants and Aircraft

JIMDAT CARGO SUBGROUP

CAST SE portfolio is effective in reducing risk in cargo operations.

JIMDAT portfolio assessment indicates a lower level of effectiveness when

compared to passenger operations.

Continue subgroup activity to quantify differences in the cargo operating environment that may characterize a different risk signature the SEs may not be as effective in mitigating.

CARGO AND PASSENGER OPERATIONS

Conventional wisdom: same aircraft, same airports, runways, taxiways, airspace, etc.

What is the same for pilots: Part 121 experience requirements. Part 121 training requirements.

Beyond that, some risk attributes may not be so intuitive.

AIRCRAFT DEMOGRAPHICS

21

Age Aircraft technology generation In production vs. out of production Wide-body vs. narrow-body:

A Boeing 777 landing on an 8,000 ft. x 150 ft. runway looks different than a Boeing 737.

Weights: Are cargo aircraft operated closer to MAX T/O & LDG weights?

PILOT DEMOGRAPHICS

Is there different risk associated with pilot experience vs. operation when a new hire with no wide-body or international experience is a pilot for a cargo operator? Career progression Right to wide-body international High turnover

22

SYSTEM FORM DIFFERENCES

Hub and Spoke System (sort facilities make the network work) Freight moves at night

What is the day-night ratio of flying (~60% for cargo)?

How does the risk change with reduced— Air traffic services (radar update, HF, etc.)? Tower operations (non-tower ops, pilot controlled lighting)? Aircraft Rescue and Fire Fighting (requirements not based on cargo aircraft)?

ETOPS OXYGEN REQUIREMENTS

Extended-range Twin-engine Operational Performance Standards (ETOPS) requirements are based on diversion time for the most time-limiting system (usually fire suppression). Is the oxygen supply requirement for onboard persons matched

against this fire suppression time?

How is this requirement defined?

REGULATORY DIFFERENCES

Aircraft Rescue and Fire Fighting (ARFF): Based on largest passenger aircraft (by aircraft length and frequency). Cargo aircraft often are the largest aircraft operating to/from an airport.

Flight/Duty/Rest requirements: How do the operational environments differ? How is risk is characterized and mitigated?

25

SUMMARY

We welcome participation on the JIMDAT Cargo Subgroup. Need to ensure JIMDAT understands the differences in the cargo

operating environment that may characterize a different risk signature the SEs may not be as effective in mitigating.

CAST SE portfolio is available to you on the USB stick. Please reach out to us if you have questions or thoughts.

Presented to:

By:

Date:


Air Cargo:

Part 135 Operations

Cargo Safety SymposiumPatricia Williams Deputy Division Manager AFS-301AAugust 17, 2017


Overview• Reasons to evaluate part

135 weight & balance programs

• Part 135 findings & risks

• Timelines for evaluating part 135 weight & balance programs

2


Reasons to Evaluate Part 135 OpsDual operations under one certificate (4)

• Operating in a manner that doesn’t distinguish between

the two different types of operations. • Four 121/135 operators evaluated - deficiencies found

Fleet wide evaluation

Accidents have increased• Accidents/incidents with cargo shift occurred in part 135• Increased the overall risk of the certificate holder

Operating at the highest level of safety • Mandated for certificated operators • CFT has uncovered systemic findings regarding special

cargo loads on 99.9% of the operators evaluated to date

3


Part 135 Weight & Balance

Program Findings

Design Approval Holder Documents

• Not provided or cannot be found. Thus could not determine: – Programs are derived from approved TC/STC document– Aircraft operating limitations tolerance precluded from exceedance– Cargo loading and restraint methods compliance with the airplane limitations

Part 121 Contracted Operations

• Using the contractor’s ramp and loading procedures in lieu of their own procedures.

• Lack of their own manual system, procedures and guidance• Result = non compliance with TC/STC operating limitations

4


Timelines for Part 135 Operations

• Part 121 certificate holder evaluations continue through FY20

• Part 135 certificates as part of fleet wide evaluation will be conducted through FY20

• Completion of remaining part 135 certificates not yet determined – Change will be based on risk and accident data

5


Part 135 Operators

• 177 (10 or more)-SAS Peer Group B• 533 (9 or less)- SAS Peer Group C• 483 (9 or less Single Pilot Operator) SAS Peer

Group D• 58 Large 135• 30 Cargo Only• 44 Pilot in Command

6

Presented to: Cargo Symposium

By: Darcy D Reed Manager International

Operations Branch

Date: August 17, 2017


Foreign Air Carrier

Update


Cargo Symposium

August 17, 2017

Quick Overview

2

Current 129 Operations

129 Oversight functions

Non Compliance

CAA Outreach

ICAO


Cargo Symposium

August 17, 2017

Current Technical Authorizations

3

There are approximately 400 14 CFR part 129 air

carrier’s conduction operations into and out of the

U.S. NAS.

Of these 400 operators 23 conduct cargo operations.

129 operators account for 45% of the international

flights into and out of the U.S. NAS on a daily basis.


Cargo Symposium

August 17, 2017

Part 129 Oversight FunctionsInternational Flight Standards Office (IFO)

& Geographic Office share responsibilities.

The IFO is primary responsible for the management of

the technical authorizations i.e.; 129 operations

specifications; however the IFO can provide

assistance in conducting surveillance.

Under the National Work Program Order ramp

inspections are accomplished by the local Flight

Standards District Office within its geographic

district.

4


Cargo Symposium

August 17, 2017

Non Compliance

5

Operator

• letter or enforcement process.

Civil Aviation Authority

• Informal communication or formal notification.

• Processed through the U.S. State Department

Heighten Surveillance List

• Two foreign (Cargo) air carriers are currently on

the list for increased surveillance.


Cargo Symposium

August 17, 2017

CAA Outreach

On March 13, 2017 Flight Standards reached out to 90

IASA CAT 1 CAA’s who oversee operators that

conduct operations into the U.S. NAS.

“Among the findings identified, it was noted that

Aircraft Flight Manuals (AFM) and operating manuals

were not derived from or in accordance with the

operating limitations of the applicable Type

Certificate, Supplemental Type Certificate and or

Mass and Balance Manual (MBM).”

6


Cargo Symposium

August 17, 2017

State of the Operator

Responsibilities

7

Provisions in Annex 6, Part I, require the State to have

made a technical evaluation. These provisions

contain the phrases:

“Acceptable to the State”, “satisfactory to the State”,

“determined by the State”, “deemed acceptable by

the State”, and “prescribed by the State”.

.


Cargo Symposium

August 17, 2017

Annex 6, Part 1, Appendix 2

Annex 6, Part 1, Appendix 2 requires the Ops Manual to

have instructions for:

2.1.9 Ground handling arrangements and procedures.

2.1.14 Instructions for mass and balance control.

2.2.1 Certification limitations and operating limitations.

2.2.6 Instructions and data for mass and balance

calculations.

2.2.7 Instructions for aircraft loading and securing of

load.

These standards are approved by the State of the Operator

8


Cargo Symposium

August 17, 2017

Thank you

9

Presented to:

By:

Date:



Cargo

Certification

Process

Air Cargo Safety Symposium

Phil FordeManager, Airframe SectionSeattle ACO Branch

August 17, 2017


Overview

• Review – Operating Limitations

• FAA Order 8110.4C, Type Certification

• Issues found during Cargo Focus Team (CFT) reviews

• Resolution of design approval issues

• Modification of existing supplemental type certificates (STCs)

• Cargo-related design guidance

• Structural assessment

• Surrendered STCs

• Closing

2


Review – Operating Limitations

3

14 CFR 21.41: Type certificate includes operating limitations

14 CFR 25.1581: Airplane Flight Manual (AFM) must contain:(1) Information required by Secs. 25.1583 through 25.1587.(2) Information that is necessary for safe operation because of design, operating, or handling characteristics.(b) Approved information. Each part of the manual listed in Secs. 25.1583 through 25.1587, that is appropriate to the airplane, must be furnished, verified, and approved

14 CFR 25.1583: Operating limitations

(c) Airplane Flight Manual or separate weight and balance

control and loading document that is incorporated by

reference in the Airplane Flight Manual:

(2) Loading instructions necessary to ensure loading of the

airplane within the weight and center of gravity limits, and to

maintain the loading within these limits in flight.

Operating

Limitations

§ 25.1581,

§ 25.1583

Aircraft Flight

Manual (AFM)

Type Certificate

§ 21.41

14 CFR Sec. 91.9(a): “No person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual”


FAA Order 8110.4C, Type Certification

• Applies to both type certificates (TCs) and

STCs

• Defines the design certification process

– Process flow times are dictated by the complexity and priority of the project

• Applies to FAA employees

and delegated persons and

organizations

4


Changes to the Type Certificate

• Section 25.1583(c) requires the AFM to include weight and balance information, including loading instructions, as operating limitations– Operating limitations must be FAA-approved and are part

of the type certificate• A change to the loading instructions required

by § 25.1583 are a change to the type certificate, and must be made via an amended TC, STC, or amended STC– Changes to the AFM submitted by someone other than

the TC holder must be accomplished by an AFM Supplement

5


Issues Found During CFT Reviews

• Operators not staying in the operating limitations defined in the original equipment manufacturer (OEM) weight and balance manual (WBM) – Almost 100% of the 25 initial reviews

• Root cause of some findings related to design approvals– Impacted 7 of 25 reviews– The CFT is working directly with the Aircraft Certification

Service (AIR) to resolve these issues– To date, most of the issues have been resolved

6


Problem Areas Impacting

Operating Limitations

• Use of military pallets as unit load devices (ULDs) without an STC– Does not engage all locks along the fuselage length-wise– Results in broken locks and potential for unrestrained cargo

• Altering TSO ULD pallets with straps, pallet couplers, modifying pallets - while retaining classification as a TSO ULD– Straps concentrate load, break locks, can overload the floor

locally• Simplifying restraint calculations

– Results in not enough straps to restrain cargo for flight loads

7


FAA records for U.S. Part 121 carriers since 2000 show:

● freighters, 6% of flights, have 56% of the accidents: their probability of an accident is 20 times than of PAX aircraft.

● 2/3 of freighter accidents (17) had causal factors similar to•those of passenger airplane accidents.

● 1/3 (9, nearly 1 per year) had cargo related causal factors.

8

Aircraft types Total Passenger ( 94% ) Freighter ( 6 %)

Number of hull loss and/or fatal accidents

46 ( 100 %) 20 ( 44 % ) 26 ( 56 %)


9


Design Approval Issues

• Unauthorized approvals of changes to the airplane operating limitations in the WBMs made by Designated Engineering Representatives (DERs)

• DER approvals beyond their authorizations, such as:– DER approval of a modification to a Technical Standard Order (TSO) – DER approval of deviations to lock or loading configurations that do not

conform to NAS 3610 or AS36100• Engineering errors in the TC WBMs and STC WBM

Supplements– Undefined loading configurations – Non-compliant loading configurations that exceed the airplane design

capabilities (potentially unsafe)• STCs without associated airplane operating limitations (WBM

Supplement) needed for operations

• A DER should recommend approval of the AFM or AFM Supplement unless specifically authorized in writing to approve – Must be in connection with TC or STC

10


Resolution of Design Approval Issues

• What is AIR doing to correct these issues?

– Instructed certification offices that: • Cargo project STCs must have an associated WBM or WBM

supplement with loading instructions and procedures• Loading instructions must prevent exceeding airplane design

capability• Loading instructions must be identified as operating limitations

on the TC or STC via the AFM or AFM supplement– Multiple internal standardization briefings and project

consultation– Upcoming policy on certification of cargo projects – Upcoming training for FAA employees and designees

11


Modification of Existing STCs

• What is required to modify an existing STC

held by another party?

– Same requirements as for a new STC– § 21.115 Applicable requirements

• (a) Each applicant for a supplemental type certificate must show that the altered product meets applicable requirements specified in § 21.101

12


Cargo-Related Design Guidance

• Where can I find guidance on data needed

to support approval of cargo-related STCs?

– Your local certification office – AC 120-85A, Air Cargo Operations

– AC 25-18, Transport Category Airplanes Modified for

Cargo Service

13


AC 120-85A, Air Cargo Operations

• Provides guidance on cargo operations and related modifications– Appendix E

• Structural data for passenger-to-cargo conversion project

– Appendix F• Passenger-to-cargo

conversions supplemental type certificate data package for systems and equipment

– Appendix G• Design criteria for outward

opening doors

14


AC 120-85A, Air Cargo Operations

• Appendix E, paragraph E.2– Aircraft Loading Document

• Describes the types of cargo containers allowed, how the containers are restrained, and loading requirements when latches are missing or broken

• This may* be contained in the Weight and Balance (W&B) manual

• Ensures compatibility of the cargo loading system (CLS) with the cargo conversion

• If the use of tiedown fittings is permitted, the tiedown strength and limitation data should be provided

* 14 CFR 25.1583 permits a separate manual incorporated by reference in the AFM

15


AC 25-18, Transport Category

Airplanes Modified for Cargo Service

• Provides guidance on:

– Structural requirements– Compartment classification– Fire protection features– Emergency egress– Ventilation– Loading procedures and limitations

16


Structural Assessment

• The retention of cargo to the airplane is like

the strength of a chain.

17

Wing

Fuselage

Floor

CLS fitting

Pallet

Net or Strap

Cargo

Having one

strong link does

not increase the

strength of the

chain



• For example: A 463L pallet tie down ring might be rated at 7,500 lbs

– What if you don’t have the data and don’t know the floor is only adequate for a tie down load of 1,500 lbs?

– What if you don’t know loads from other adjacent pallet tie downs that affect the structural capacity of the floor structure?

18



• What happens if you make the wrong

assumptions?

• For example:

– Using 75% of the rated strap strength for restraining cargo

– Assuming that any location in the airplane that a strap double stud fitting can be attached is rated at 5,000 lbs

19



20

Location of seat track used by National Flight 102

Not permitted by Boeing WBM

Location of the permitted straps found

Source: NTSB National Accident docket Structures Report attachment #2

MRAP #4 MATV #5


Surrendered STCs

• FAA Order 8110.120, Processing Surrendered,

Abandoned, and Historical Aircraft Type

Certificates

– Current policy and procedures for processing TCs or STCs surrendered by a design approval holder (DAH)

– The surrender of a TC does not affect the airworthiness certificates of existing aircraft

– All data surrendered by the former DAH is retained by the FAA for FAA use only, unless the DAH has given the FAA permission to release the data to others

21


Surrendered STCs

• Typically results in inability to obtain data

and provide technical support for affected

airplanes

• The surrender of a certificate is a final

action

– Once surrendered, the action cannot be reversed – A certificate cannot be reissued to a third party or a

former holder

22


In Closing• Cargo operations are an ever changing industry

• AIR is working with applicants for new or expanded

cargo capabilities

• Some industry participants such as Kalitta, Atlas and

Boeing are leading the way on addressing emerging

issues

• No new rules or standards are being imposed, only

compliance to existing rules and standards

• We recognize the difficulties facing industry in

dealing with abandoned STCs, missing/incomplete

documentation, and configuration migration, and will

do what we can to assist

23

CERTIFICATION PROCESS LESSONS LEARNED

Presented to: Air Cargo Safety Symposium

August 17, 2017

Discussion Points

• Background

• Issues Found by the Cargo Focus Team (CFT)

• Progress made by Industry, Manufactures, and the FAA to Resolve Issues

• Legacy Aircraft Issues Needing Resolution

• Best Practices Going Forward

• Closing

Background

After the National Air Cargo Crash in 2013 , 747 industry operators, Boeing, and the FAA met to discuss safer methods for cargo restraint with a focus on heavy military vehicles, but with an additional conversation regarding other types of large and special cargo that was being carried by industry. As a result of issues found during this meeting all in attendance agreed that additional review of current procedures were required and to best method to accomplish this was for industry, type certificate (TC)/supplemental type certificate holders (STC), and the FAA all work together to accomplish reviews and any required changes to operator procedures and Weight and Balance Manual issues. Additionally the FAA formed the Cargo Focus Team to assist with review of operators manuals, review and revise FAA guidance as needed and assist Certificate Management Teams to ensure that training and oversight complied with the aircraft limitations and FAA guidance

Issues Found by the Cargo Focus Team (CFT)

During initial reviews, particularly of the Boeing 747 operators many issues were found that were being used by industry and were not contained in the Boeing 747 Weight and Balance and Loading Control Manual. Some of these items were:

• Straps to pallets

• Carriage of Code B-Mil (463L) Pallets

• Pallet Couplers

• Cargo Tied Down Straps Used in Unapproved Locations

• Simplified Strap Tie Down Strength Calculations

• Side Loaded Carriage of Intermodal Containers

• Aircraft Engine Transport

Progress made by Industry, Manufactures, and the FAA to Resolve

Issues

Working together 747 operators, Boeing, and the FAA were able to starting in 2015 create the Boeing Supplemental Procedures Manual as well as revise the Weight and Balance and Loading Control Manual to either incorporate industry needed changes or to clarify limitations for a better understanding of the limitation. These documents produced by Boeing with FAA approval has resolved and clarified almost all issues that were initially identified. Additionally the Supplemental Procedures Manual was written to include all Boeing 747F aircraft, Boeing 777F aircraft, and the Boeing 767-300F aircraft. Some of the resolved issues in these changes include:

Progress made by Industry, Manufactures, and the FAA to Resolve Issues

In the Boeing Supplemental Procedures Manual these items were addressed:

• Use of Restraint Straps as Primary Restraint to a Pallet

• Carriage of Size Code B-MIL (463L) Pallets

• Intermodal Container Carriage

• Pallet Coupler Devices

• Aircraft Engine Transport

• Expanded CG Versus Reduced Weight ULD

Work continues for several other items of concerns that may be added to this document, however the items addressed to this date have been very significant and have allowed the operators of these aircraft to adequately address FAA concerns and continue to operate while largely maintaining many of the past procedures that were being used.

The Boeing Sample Weight and Balance Manual has additionally addressed both operator and FAA concerns and several revisions of this document have addressed issues that I will not go into detail on due to lack of time, but they also have been significant and have been able to be incorporated because of co-operation, and the desire to work together of all parties. Work also continues with this manual and like the Supplemental Procedures Manual the continued cooperation of all parties is vital to ensure the best product is produced as a final document.

Other Aircraft Addressed

Other aircraft types have also had some issues addressed. Most of these address straps to pallets such as IAI Bedek, and Aeronautical Engineers. These STC holders are continuing with additional projects that will hopefully in the near future be able be FAA approved and implemented into their prospective manuals.

Legacy Aircraft Issues Needing Resolution

Older, out of production or those models no longer being converted are now the largest issue remaining for aircraft currently under review. These concern several aircraft types but for this discussion I will only include the Douglas DC-9 and the Boeing 727 aircraft. While it is important to understand that in many cases the operators, manufacturer, and the FAA have been able to resolve some issues many significant issues remain. Examples of some of these issues will be discussed in the following slides

Legacy Aircraft Issues Needing Resolution

DC-9 aircraft:

• Differences in manuals indicating different allowed procedures.

• Cargo tie down information that is not complete.

• Approved Pallet designations that differ between manuals

• Typos and inconsistencies in manuals.

Cargo tie down information

Tie Down for the DC-9 series aircraft provides the following information:

This is an example of the Brownline Fitting required:

There is no other data in this manual instructing an operator on how this device is used to restrain the cargo. The concern is that based on these instructions an operator could apply a strap or rope per the manuals instructions and assume that each strap fitting regardless of direction, strap angle, or strap strength has 5,000 pounds of restraint in all directions. This is of course in error and even without a correction to this Weight and Balance Manual, operators should change their manuals to provide accurate procedures for restraint to the floors using straps.

Other examples including differences in pallets, procedural differences between manuals, and other typos are not as significant.

One additional point for the DC-9 manual: Recently the Boeing Company released a revision to the manual clarifying the requirement for compressable cargo. In some manuals the requirement was listed as 8,900 lbs., not the 89 inches that others specified and is the actual requirement. This was an item identified during review by the CFT and AIR and has now been corrected.

727 Aircraft Converted by STC

Some 727 aircraft converted by various STCs have missing or incomplete documentation as will be presented in the following slides. These documents have been in existence for a considerable period of time and currently the FAA is working with operators for resolution as in many cases the STC the aircraft was converted under has been surrendered and as such it is not possible to correct or create an FAA approved Weight and Balance Manual. Complicating this is a number of associated STCs that were accomplished that do not adequately address changes required to the Weight and Balance Manual.

Cargo Loading

One (or more) STC’s provide a document called “Cargo Loading in B-727” (Or a similar title). This document is not an FAA approved Weight and Balance Manual and although it is listed in the Master Data List (MDL) of the STC was not submitted as the weight and balance manual or the aircraft loading manual to the FAA for approval during modification during the STC. There are numerous errors in this document and it should not be used for loading of the aircraft. Such errors exist as a bulk loading statement that provides: “Bulk loading of cargo such as cartons, boxes, and crates shall be loaded in such a manner that the tie down straps and ropes may be used over the top of the cargo to restrain movement sideways, upward, fore, and aft.” The use of straps only over the top of the cargo does not ensure movement of forward, aft, and sideways as given in this manual. Additionally this manual does not provide a limitation for the distance that straps may be applied to the floor which may result in overloading the structure. Again this is not an FAA approved manual and a review of several aircraft that have additional supplemental STC’s installed do not in any case supersede the information provided in this document.

Closing

Why does this matter? My manuals have already for the most part been corrected, or no issues have been found.

This does matter, not only for cargo operators and cargo, but for all matters, particularly those that are limitations set forth by certification during the aircraft TC or STC process. This issue should teach operators, manufactures, and the FAA that continued dialogue between each other as an industry as well as individual operators is extremely important so we all understand what new procedures, operations, and for the cargo industry what types of products we carry. The lesson learned is had we all spoken to each other and developed approved processes when we desired to implement them we in all likelihood would have saved lives, aircraft, time, and would have not had to put all of ourselves through a time consuming and costly review and recovery that we have done over the last few years. There are many events by industry groups, manufactures, and the FAA that provide for the format to discuss these items and my hope is that from this we have all learned that the best practice moving forward is proactive and ensuring we address needed changes to any limitation ahead of incorporating the change so that we operate at a higher level of safety and more efficiently than any other operators in the world.

SPEAKER PRESENTATIONS - ALPA

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