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Cargo Focus Team

Cargo Focus Team. Cargo Operations. Ops Spec Work Group. Patricia K Williams, Manager, AFS-340. March 08, 2017. Overview. Background Cargo Focus Team NTSB Working with Stakeholders Accomplishments Short and Long Term Goals AC 120-85A Highlights Cargo Operations

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Cargo Focus Team

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  1. Cargo Focus Team Cargo Operations Ops Spec Work Group Patricia K Williams, Manager, AFS-340 March 08, 2017

  2. Overview • Background • Cargo Focus Team • NTSB • Working with Stakeholders • Accomplishments • Short and Long Term Goals • AC 120-85A Highlights • Cargo Operations • Current Issues and Initiatives Cargo Focus Team

  3. Background • Following the Air Cargo accident in Afghanistan, a team was assembled to determine whether or not systemic problems exist regarding special cargo loads • Aircraft Certification (AIR) and Flight Standards (AFS) are working jointly to address Cargo Operation with a focus on “Special Cargo” Cargo Focus Team

  4. Cargo Focus Team • The FAA, Cargo Focus Team (CFT) exists as a permanent technical resource for cargo operations • For cargo operations questions or suggestions contact CFT @ 9-NATL-Cargo-CFT@faa.gov • FAA Air Cargo Operations site: https://avssp.faa.gov/avs/afs300/SharedInfo/CargoInfo/Pages/Air%20Cargo%20Operations.aspx Cargo Focus Team

  5. Cargo Focus Team Team Structure • Interdependency • Multi Discipline • Transport Airplane Directorate (ANM-100) • Air Transport Operations (AFS-200) • Aircraft Maintenance Division (AFS-300) • National Field Office (AFS-900) • Field Inspector (CMO- Detailees) Cargo Focus Team

  6. Cargo Focus Team • The CFT Vision is to enhance the safety of air cargo operations. • The CFT Mission is to directly support FAA field personnel, act as a focal point for the integrity of air cargo operations while serving as the FAA’s technical matter expert in air cargo operations Cargo Focus Team

  7. NTSB • NTSB final report on from B-747 accident published July 29, 2015. • Three of the NTSB Safety recommendations from Fine Air accident (1997) mirror the six Safety recommendations based on National Air accident (2013). Cargo Focus Team

  8. NTSB • Fine Air issues linger… • Problems with Operator Manuals • Ensure cargo loading procedures are based on manufacturer’s data applicable to the airplane being operated • Lack of FAA Oversight • Positively verify that all loading steps have been accomplished for each loaded position on the airplane and that the condition, weight, and sequencing of each pallet is correct. • Gaps in FAA/Operator training • Training for cargo handling (initial and recurrent) • Use of Multiple entities (Outsourcing) and Freight Forwarders Cargo Focus Team

  9. NTSB Recommendations - AFG • 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-15-15Review 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-15-17Initial and recurrent training for PI’s. • A-15-18 Surveillance deferrals. Cargo Focus Team

  10. Unified efforts with Stakeholders * Boeing Supplement D636H000-NASCLCr02 • Boeing • Weight and Balance Manual Supplemental Procedures • Department of Defense (DoD) • Trade Associations • National Air Carrier Association (NACA) • International Air Transport Association (IATA) Cargo Focus Team

  11. Boeing Supplemental Procedures • D636H000-NASCLC • Applicability • 4th revision includes: • Use of Restraint Straps as a Primary Restraint to a Pallet • Intermodal Container Carriage • Size Code B-Mil Pallets • 2 side nets/1 top net • Top net (Low profile) • 2 side nets/7 straps • Aircraft Engine Transport • Pallet Coupler Devices Cargo Focus Team

  12. Accomplishments • Updated FAA guidance published June 26, 2015 • (*NTSB Rec A-15-13) • Issued guidance • InFOs and SAFOs (*NEW D6 Hook) • Airworthiness Directive and CANIC for Intermodal Containers • Notice for making changes to AFM/WBM (N8900.317) • Aviation Rulemaking Advisory Committee for Loadmaster certification (*NTSB Rec A-15-14) • FAA Weight and Balance Workshop • Human Factors Study (*NTSB Rec A-15-14) • https://www.faa.gov/data_research/research/med_humanfacs/oamtechreports/ Cargo Focus Team

  13. Short Term Goals • OpSpec Proposal(s) • Cargo Load and Control • Revise Air Cargo Operations Training Course (*NTSB Recs A-15-17) • Web-based training • FAA Academy Course • Weight And Balance Control Program (WBCP) reviews – Cargo (*NTSB Rec A-15-15) • Outreach Cargo Focus Team

  14. Air Cargo Operations Training Course • Overview of Air Cargo Operations Training Course • Two part course, must complete both. • FAA27100256 – Air Cargo Operations Web-based Training (WBT); • The online course is the first element of the air cargo education. • 7 modules • FAA21000056 – Air Cargo Operations Practical Applications Workshop (PAW) • Opportunity to apply the knowledge from the online course and learn more about FAA oversight responsibilities regarding air cargo. Cargo Focus Team

  15. Air Cargo Operations Training Course • Air Cargo Operations PAW Content Highlights • Interactive instruction containing Q&A, Exercises, Case Study, and weight and balance calculations • Operation Specifications • Air craft configurations • Cargo Compartment design and construction requirements • Cargo restraint systems and ULDs • ULD Standards • Special Cargo • Hazardous Materials Cargo Focus Team

  16. Updating Policy and Guidance • Delineation of responsibilities • Its intent is to display the overlap, and specific areas of ASI discipline responsibility in relation to elements of W&B, airplane limitations, and cargo operations.  • To close NTSB Recommendation A-15-16 • CFT transitioning to SAS • CFT will follow the Certificate Holder’s Evaluation Process (CHEP) outlined in FAA Order 8900.1 Volume 10, Safety Assurance System • Focus on weight and balance programs only • Collaborating with the Flight Standards National Field Office (AFS-900) on CHEPs Cargo Focus Team

  17. Updating Policy and Guidance • Operation Specifications • Definitions (AFS-200) • Notice to revise A002 definitions by including new definitions for certified unit load devices, bulk cargo and Special Cargo, published on January 27, 2017 • Aircraft Weighing (AFS-300) • Notice to revise E096 title published on November 21, 2016 • Cargo Load and Control (AFS-200) • A196 is for certified unit load device and bulk cargo • A396 is for Special Cargo and requires headquarters approval Cargo Focus Team

  18. Industry Tasking - ARAC • Aviation Rulemaking Advisory Committee (ARAC) • Accepted the task on March 23, 2016. • The new ARAC subgroup: Loadmaster Certification Working Group (LCWG) • 12 working group candidates selected • Working group meets monthly • The ARAC Recommendation Report • Should be submitted to the FAA for review and acceptance no later than 24 months from the publication date of this notice in the Federal Register, FY2018. Cargo Focus Team

  19. Where are the Cargo Operator CMOs? Number shown in box is the number of certificates at office – 33 total 1 1 2 5 2 4 1 1 1 3 1 2 3 4 Cargo Focus Team

  20. CFT Outreach Completed Number shown in box is the number of certificates at office at the time of CFT Outreach seminar. CFT Outreach not done 1 1 2 Cargo Workshop 23 CMOs 5 2 1 1 DoD ALPA A4A 1 3 IATA 1 2 4 SAE 4 3 -Jan 31, 2017 Cargo Focus Team

  21. Long Term Goals • WBCP Reviews – Passenger (*NTSB Rec A-15-15) • Feasibility of a Loadmaster Certification (*NTSB Rec A-15-14) • Evaluate Cargo Systems Program Manager • Evaluation of load manifest rule • Evaluating cargo operations guidance for Parts 91, 125 and 135 operations Cargo Focus Team

  22. Industry Tasking - ARAC • Aviation Rulemaking Advisory Committee (ARAC) • Accepted the task on March 23, 2016. • The new ARAC subgroup: Loadmaster Certification Working Group (LCWG) • The recommendation report should be submitted to the FAA for review and acceptance no later than 24 months from the publication date of this notice in the Federal Register, FY2018. Cargo Focus Team

  23. Current Initiatives • Working with TAD for TC/STC/DER resolutions • Address safety findings discovered during reviews • STC adequacy (Car Pallet)(courier) • Coupled pallets Cargo Focus Team Cargo Focus Team

  24. AC 120-85A Highlights • The Airline uses the airplane AFM as the basis for the Airline’s WBM • Removed the allowance for accepted data (*NTSB Rec A-15-13) • Preparing CargoIAW with Airline WBM • Cargo Weights must be actual and accurate • NEW Sections containing guidance on: • Staging/Storing Cargo • Transport of Special Cargo • Closed loop continuing analysis, evaluation and surveillance system • Use of Multiple Entities in the movement of cargo Cargo Focus Team

  25. AC 120-85A Highlights • ULDs • ULDs defined by TSO C90/NAS3610/AS36100 • Restraint • Definitions of primary and supplemental restraint • Explain primary and supplemental restraint and when it is appropriate to use. • Differences between new definitions : • Cargo requiring special handling procedures vs Special Cargo • Responsibility • The operator is always ultimately responsible for cargo loading/securing and safety of flight Cargo Focus Team

  26. Part 121 WBCP Reviews • WBCP reviews (29 Cargo operations/49 Passenger operations) • 22 of 78 initial reviews complete (76% of Cargo Operators) • 11 of 78 reviews concurred/closed (38% of Cargo Operators) • NOTE: 4 out of 29 cargo operators are 121/135. Reviewing both at this time. • Under review: • Initial Review: 5 (2 are complete and in formal coordination) • Follow-up Reviews: 11 (Working with CMTs) Cargo Focus Team

  27. Part 121 WBCP Findings • Source documents • Programs are not derived from approved sources (TC/STC WBMs) • Operating limitations exceeded • Not provided or cannot be found • Cargo Restraint Methods • Using procedures not defined by TC/STC WBM • Engineering groups for Special Cargo • Computer W+B Systems Cargo Focus Team

  28. Regulatory Path: Operating limits • Operation of aircraft is covered by 14 CFR part 91 • §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 • §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. Cargo Focus Team

  29. Regulatory Path: Operating limits • 14 CFR 21.41: Type certificate includes OPERATING LIMITATIONS • 14 CFR 25.1581: Airplane Flight Manual (AFM) (1) Information required by Secs. 25.1583 - 25.1587. (2) Information necessary for safe operation because of design, operating, or handling characteristics. (b) Approved information. • 14 CFR 25.1583: OPERATING LIMITATIONS (c) AFM or separate weight and balance control and loading document that is incorporated by reference in the AFM: (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. Type Certificate § 21.41 Aircraft Flight Manual (AFM) OPERATING LIMITATIONS § 25.1581, § 25.1583 Cargo Focus Team

  30. Regulatory Path: Operating limits • What does .... • “(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? Cargo Focus Team

  31. Regulatory Path: Operating limits • For a cargo airplane, this is all of the weight and CG diagrams, local limits (running load, area load, lateral load, etc.) in the WBM AND • The 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. Cargo Focus Team

  32. Changes To The AFM/WBM • Principal Inspectors are not authorized to accept/approve 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. Cargo Focus Team

  33. Regulatory Path: Operating limits • Takeaways • The instructions for loading cargo are required by 14 CFR 25.1583 • The operation instructions for loading the cargo is defined in the Weight and Balance Manual (WBM) • 14 CFR 91.9(a) requires compliance to the operations limitations in the WBM • If changes to the 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 the WBM limits is a violation of 14 CFR 91.9(a) • It is not possible comply with 14 CFR 91.9 (a) if you can’t find the TC/STC WBMs Cargo Focus Team

  34. Types of Cargo • Cargo is either a ULD, Bulk or Special Cargo • ULD: A Unit Load Device (ULD) is a device for grouping, transferring, and restraining cargo for transit. It may consist of a cargo pallet and cargo net combination or a container • Bulk Cargo: Cargo enclosed in a certified bulk compartment. • Special Cargo: Cargo that is not contained in a ULD certified for the airplane CLS or enclosed in a cargo compartment certified for bulk loading is special cargo. This type of cargo requires special handling and securing/restraining procedures. Cargo Focus Team

  35. Types of Cargo 238.5 inches long by 96 inches wide • Unit Load Device Examples Cargo Focus Team Cargo Focus Team

  36. Container Unit Load Device Cargo Focus Team

  37. TSO Tag Cargo Focus Team

  38. Pallet Identification Cargo Focus Team

  39. Hazardous Material Notification Cargo Focus Team

  40. Pallet Couplers • What are Coupled pallets or a Pallet Train? • 2 or more pallets “coupled” together in a line. • This is seen mostly with military 463L pallets Two 463L military pallets coupled together Cargo Focus Team

  41. Pallet Couplers • Pallet coupler installed between two 463L pallets • Pallet couplers because each pallet is restrained along the inboard and outboard sides of the pallet providing fwd/aft, vertical, and side directions. Cargo Focus Team

  42. Pallet Couplers • Problem: Although 463L pallets fit on the Boeing 747, they are restrained on the side only in the lateral direction because of the notches in the pallet. Cargo Focus Team

  43. Pallet Couplers • Problem: Although 463L pallets fit on the Boeing 747, they are certified only as a netted pallet. This means one pallet/net at a time, not coupled. Cargo Focus Team

  44. Pallet Couplers • Problem: Although 463L pallets fit on the Boeing 747 at some locations, the 463L notches align with the center line vertical locks. This truck is unrestrained along the inboard side vertically. Cargo Focus Team

  45. Pallet Couplers • Pallet coupler installed between two 463L pallets • Problem: This is where the Boeing 747 pallet locks are supposed to be raised up to react fwd/aft and vertical loads. • Problem: These locks are not raised and the pallet is sitting on top of them. Cargo Focus Team

  46. Pallet Couplers • Result • Coupled pallets do not comply with the required WBM. • Under vertical gust loads, the unrestrained middle portions are forced upward causing the forward and aft locks to disengage. • Because of the missing pallet locks in the center and the coupler fails in compression: • The forward pallet is unrestrained in the aft direction. • The aft pallet is unrestrained in the forward direction Two 463L military pallets coupled together This is unsafe. Cargo Focus Team

  47. Special Cargo • What has been done in the past? • All of the outboard tiedowns are in the passenger seat tracks. This is not permitted due to low strength of track. • The side of the vehicle tiedown locations were not permitted by ATTLA. Cargo Focus Team

  48. Unit Load Device Cargo Focus Team

  49. Special Cargo • This cargo exceeds the certified unit load device capability. It is special cargo. Cargo Focus Team

  50. Intermodals • This cargo is offset on the pallet. • Under flight loads, can shift outboard. • Prohibited by AD 2015-14-09 • The intermodal can still be carried, but restrained directly to the airplane as a special load. Cargo Focus Team

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