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AIR CARGO SAFETY SYMPOSIUMAugust 17, 2017
SPEAKER PRESENTATIONS
PRESENTATIONS MENUClick on the PowerPoint Icon to jump to presentation
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
Federal AviationAdministration
Topics
• Why - Background
• What - Mission & Vision
• Who - Team Structure
• Accomplishments
• In Progress
• Impact on Safety
• Resources
2
Federal AviationAdministration
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
Federal AviationAdministration
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.
Federal AviationAdministration
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
Federal AviationAdministration
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.
Federal AviationAdministration
Background:
Three Classifications of Cargo
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
Federal AviationAdministration
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:
Three Classifications of Cargo
8
Federal AviationAdministration
9
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
• 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
Federal AviationAdministration
• 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.
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
25
Presented to:
By:
Date:
Federal AviationAdministration
Air Cargo:
Operation
Specifications
A002, A196, A396
Air Cargo Safety SymposiumStephen Moates, AFS-220 ManagerAugust 17, 2017
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Air Line Pilots Association, Int’l
▪ 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
Air Line Pilots Association, Int’l
▪ 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
Air Line Pilots Association, Int’l
▪ 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
Air Line Pilots Association, Int’l
▪ 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
Air Line Pilots Association, Int’l
▪ 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
Air Line Pilots Association, Int’l
▪ 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
Air Line Pilots Association, Int’l
▪ Team is in the process of determining what method should
be used and what the most effective process would look
like.
Progress
Air Line Pilots Association, Int’l
▪ 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:
Federal AviationAdministration
Air Cargo:
Air Safety Cargo SymposiumPatricia Williams, Deputy Division Manager, AFS-301A
August 17, 2017
IATA & SAE
Procedures
Federal AviationAdministration
Overview
• NTSB Recommendations
• Regulatory Path
• IATA and SAE Procedures
August 17, 2017 Cargo Focus Team 2
Federal AviationAdministration
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.
August 17, 2017 Cargo Focus Team 3
Federal AviationAdministration
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
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 5
§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
Federal AviationAdministration
Cargo Focus Team 6
Regulatory Path: Operating Limits
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
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 7
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
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 8
Regulatory Path: Operating Limits
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?
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 9
• 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
Regulatory Path: Operating Limits
Federal AviationAdministration
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
Regulatory Path: Operating Limits
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 11
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
Regulatory Path: Operating Limits
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 12
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
Federal AviationAdministration
August 17, 2017 Cargo Focus Team 13
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
Federal AviationAdministration
FAA Outreach
Collaboration
Undeclared Hazardous
Materials
Janet McLaughlin
Director, FAA Office of Hazardous
Materials Safety
Federal AviationAdministration
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
Federal AviationAdministration
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.
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
© Copyright 2017 UL LLC. All rights reserved.
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
© Copyright 2017 UL LLC. All rights reserved.
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
© Copyright 2017 UL LLC. All rights reserved.
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
© Copyright 2017 UL LLC. All rights reserved.
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
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.
www.hazmatsafety.com
www.hazmatsafety.com
Lithium Battery Dangers
www.hazmatsafety.com
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
www.hazmatsafety.com
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.
www.hazmatsafety.com
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.
www.hazmatsafety.com
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?
www.hazmatsafety.com
Improved Packaging
www.hazmatsafety.com
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
www.hazmatsafety.com
Containment systems for passenger aircraft
www.hazmatsafety.com
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.
www.hazmatsafety.com
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.
www.hazmatsafety.com
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
www.hazmatsafety.com
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.
www.hazmatsafety.com
Bob RichardPresident Hazmat Safety Consulting LLC
www.hazmatsafety.com
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:
Federal AviationAdministration
Air Cargo:
Part 135 Operations
Cargo Safety SymposiumPatricia Williams Deputy Division Manager AFS-301AAugust 17, 2017
Federal AviationAdministration
Overview• Reasons to evaluate part
135 weight & balance programs
• Part 135 findings & risks
• Timelines for evaluating part 135 weight & balance programs
2
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
Foreign Air Carrier
Update
Federal AviationAdministration
Cargo Symposium
August 17, 2017
Quick Overview
2
Current 129 Operations
129 Oversight functions
Non Compliance
CAA Outreach
ICAO
Federal AviationAdministration
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.
Federal AviationAdministration
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
Federal AviationAdministration
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.
Federal AviationAdministration
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
Federal AviationAdministration
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”.
.
Federal AviationAdministration
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
Federal AviationAdministration
Cargo Symposium
August 17, 2017
Thank you
9
Presented to:
By:
Date:
Federal AviationAdministration
Federal AviationAdministration
Cargo
Certification
Process
Air Cargo Safety Symposium
Phil FordeManager, Airframe SectionSeattle ACO Branch
August 17, 2017
Federal AviationAdministration
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
Federal AviationAdministration
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”
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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 %)
Federal AviationAdministration
9
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
Structural Assessment
• 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
Federal AviationAdministration
Structural Assessment
• 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
Federal AviationAdministration
Structural Assessment
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
Federal AviationAdministration
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
Federal AviationAdministration
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
Federal AviationAdministration
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.