Cargo Focus Team Cargo Operations Presented to Ops

Cargo Focus Team Cargo Operations Presented to: Ops Spec Work Group By: Patricia K Williams, Manager, AFS-340 Date: March 08, 2017 Federal Aviation Administration

Overview q Background q Cargo Focus Team § NTSB § Working with Stakeholders § Accomplishments § Short and Long Term Goals § AC 120 -85 A Highlights q Cargo Operations q Current Issues and Initiatives March 8, 2017 Cargo Focus Team Federal Aviation Administration 2

Background q Following the Air Cargo accident in Afghanistan, a team was assembled to determine whether or not systemic problems exist regarding special cargo loads q Aircraft Certification (AIR) and Flight Standards (AFS) are working jointly to address Cargo Operation with a focus on “Special Cargo” March 8, 2017 Cargo Focus Team Federal Aviation Administration 3

Cargo Focus Team q The FAA, Cargo Focus Team (CFT) exists as a permanent technical resource for cargo operations q For cargo operations questions or suggestions contact CFT @ 9 -NATL-Cargo-CFT@faa. gov q. FAA Air Cargo Operations site: https: //avssp. faa. gov/avs/afs 300/Shared. Info/Cargo. Inf o/Pages/Air%20 Cargo%20 Operations. aspx March 8, 2017 Cargo Focus Team Federal Aviation Administration 4

Cargo Focus Team Structure q Interdependency q 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) March 8, 2017 Cargo Focus Team Federal Aviation Administration 5

Cargo Focus Team q The CFT Vision is to enhance the safety of air cargo operations. q 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 March 8, 2017 Cargo Focus Team Federal Aviation Administration 6

NTSB q NTSB final report on from B-747 accident published July 29, 2015. q Three of the NTSB Safety recommendations from Fine Air accident (1997) mirror the six Safety recommendations based on National Air accident (2013). March 8, 2017 Cargo Focus Team Federal Aviation Administration 7

NTSB q Fine Air issues linger… § Problems with Operator Manuals o Ensure cargo loading procedures are based on manufacturer’s data applicable to the airplane being operated § Lack of FAA Oversight o 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 o Training for cargo handling (initial and recurrent) o Use of Multiple entities (Outsourcing) and Freight Forwarders March 8, 2017 Cargo Focus Team Federal Aviation Administration 8

NTSB Recommendations - AFG q A-15 -13 Revise guidance to specify use of (FAA)-approved data for methods for restraining special cargo. Remove FAA Accepted data. q A-15 -14 Create a Loadmaster certification. q A-15 -15 Review manuals to ensure cargo operations is based on relevant FAA-approved data (special emphasis on special cargo restraint). q A-15 -16 Define responsibilities for principal inspectors for the loading, restraint, and documentation. q A-15 -17 Initial and recurrent training for PI’s. q A-15 -18 Surveillance deferrals. March 8, 2017 Cargo Focus Team Federal Aviation Administration 9

Unified efforts with Stakeholders q Boeing § Weight and Balance Manual Supplemental Procedures q Department of Defense (Do. D) * Boeing Supplement D 636 H 000 -NASCLCr 02 q Trade Associations § National Air Carrier Association (NACA) § International Air Transport Association (IATA) March 8, 2017 Cargo Focus Team Federal Aviation Administration 10

Boeing Supplemental Procedures q D 636 H 000 -NASCLC § Applicability q 4 th revision includes: § § § Use of Restraint Straps as a Primary Restraint to a Pallet Intermodal Container Carriage Size Code B-Mil Pallets o o o § § March 8, 2017 2 side nets/1 top net Top net (Low profile) 2 side nets/7 straps Aircraft Engine Transport Pallet Coupler Devices Cargo Focus Team Federal Aviation Administration 11

Accomplishments q Updated FAA guidance published June 26, 2015 (*NTSB Rec A-15 -13) q Issued guidance § In. FOs and SAFOs (*NEW D 6 Hook) § Airworthiness Directive and CANIC for Intermodal Containers § Notice for making changes to AFM/WBM (N 8900. 317) q Aviation Rulemaking Advisory Committee for Loadmaster certification (*NTSB Rec A-15 -14) q FAA Weight and Balance Workshop q Human Factors Study (*NTSB Rec A-15 -14) § https: //www. faa. gov/data_research/med_humanfacs/oa mtechreports/ March 8, 2017 Cargo Focus Team Federal Aviation Administration 12

Short Term Goals q Op. Spec Proposal(s) § Cargo Load and Control q Revise Air Cargo Operations Training Course (*NTSB Recs A-15 -17) q Web-based training q FAA Academy Course q Weight And Balance Control Program (WBCP) reviews – Cargo (*NTSB Rec A-15 -15) q Outreach March 8, 2017 Cargo Focus Team Federal Aviation Administration 13

Air Cargo Operations Training Course q Overview of Air Cargo Operations Training Course § Two part course, must complete both. § FAA 27100256 – Air Cargo Operations Web-based Training (WBT); o The online course is the first element of the air cargo education. o 7 modules § FAA 21000056 – Air Cargo Operations Practical Applications Workshop (PAW) o Opportunity to apply the knowledge from the online course and learn more about FAA oversight responsibilities regarding air cargo. March 8, 2017 Cargo Focus Team Federal Aviation Administration 14

Air Cargo Operations Training Course q 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 March 8, 2017 Cargo Focus Team Federal Aviation Administration 15

Updating Policy and Guidance q 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 q 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 March 8, 2017 Cargo Focus Team Federal Aviation Administration 16

Updating Policy and Guidance q Operation Specifications § Definitions (AFS-200) § Notice to revise A 002 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 E 096 title published on November 21, 2016 § Cargo Load and Control (AFS-200) § A 196 is for certified unit load device and bulk cargo § A 396 is for Special Cargo and requires headquarters approval March 8, 2017 Cargo Focus Team Federal Aviation Administration 17

Industry Tasking - ARAC q 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 q The ARAC Recommendation Report q 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, FY 2018. March 8, 2017 Cargo Focus Team Federal Aviation Administration 18

Where are the Cargo Operator CMOs? Number shown in box is the number of certificates at office – 33 total 1 1 5 4 2 1 1 1 3 1 2 2 3 March 8, 2017 4 Cargo Focus Team Federal Aviation Administration 19

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 Cargo Workshop 23 CMOs 5 2 1 Do. D 1 1 IAT A 3 ALPA A 4 A 1 2 4 SAE 2 4 3 - Jan 31, 2017 March 8, 2017 Cargo Focus Team Federal Aviation Administration 20

Long Term Goals q WBCP Reviews – Passenger (*NTSB Rec A-15 -15) q Feasibility of a Loadmaster Certification (*NTSB Rec A-15 -14) q Evaluate Cargo Systems Program Manager q Evaluation of load manifest rule q Evaluating cargo operations guidance for Parts 91, 125 and 135 operations March 8, 2017 Cargo Focus Team Federal Aviation Administration 21

Industry Tasking - ARAC q Aviation Rulemaking Advisory Committee (ARAC) § Accepted the task on March 23, 2016. § The new ARAC subgroup: Loadmaster Certification Working Group (LCWG) q 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, FY 2018. March 8, 2017 Cargo Focus Team Federal Aviation Administration 22

Current Initiatives q Working with TAD for TC/STC/DER resolutions q Address safety findings discovered during reviews § STC adequacy (Car Pallet)(courier) § Coupled pallets March 8, 2017 Cargo Team Cargo. Focus Team Federal Aviation Administration 23

AC 120 -85 A Highlights q The Airline uses the airplane AFM as the basis for the Airline’s WBM q Removed the allowance for accepted data (*NTSB Rec A-15 -13) q Preparing Cargo IAW with Airline WBM q Cargo Weights must be actual and accurate q 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 March 8, 2017 Cargo Focus Team Federal Aviation Administration 24

AC 120 -85 A Highlights q ULDs § ULDs defined by TSO C 90/NAS 3610/AS 36100 q Restraint § Definitions of primary and supplemental restraint § Explain primary and supplemental restraint and when it is appropriate to use. q Differences between new definitions : § Cargo requiring special handling procedures vs Special Cargo q Responsibility § The operator is always ultimately responsible for cargo loading/securing and safety of flight March 8, 2017 Cargo Focus Team Federal Aviation Administration 25

Part 121 WBCP Reviews q 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. q Under review: § Initial Review: 5 (2 are complete and in formal coordination) § Follow-up Reviews: 11 (Working with CMTs) March 8, 2017 Cargo Focus Team Federal Aviation Administration 26

Part 121 WBCP Findings q Source documents § Programs are not derived from approved sources (TC/STC WBMs) § Operating limitations exceeded § Not provided or cannot be found q Cargo Restraint Methods § Using procedures not defined by TC/STC WBM § Engineering groups for Special Cargo q Computer W+B Systems March 8, 2017 Cargo Focus Team Federal Aviation Administration 27

Regulatory Path: Operating limits q 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 LIMITATIONS or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry. March 8, 2017 Cargo Focus Team Federal Aviation Administration 28

Regulatory Path: Operating limits Type Certificate § 21. 41 Aircraft Flight Manual (AFM) OPERATING LIMITATIONS § 25. 1581, § 25. 1583 March 8, 2017 q 14 CFR 21. 41: Type certificate includes OPERATING LIMITATIONS q 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. q 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 LOADING INSTRUCTIONS the airplane within the weight and center of gravity limits, and to maintain the loading within these limits in flight. Cargo Focus Team Federal Aviation Administration 29

Regulatory Path: Operating limits q What does. . q “(2) LOADING INSTRUCTIONS necessary to LOADING INSTRUCTIONS ensure loading of the airplane within the weight and center of gravity limits, and to maintain the loading within these limits in flight. “ q. . . . actually include? March 8, 2017 Cargo Focus Team Federal Aviation Administration 30

Regulatory Path: Operating limits q 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 q The types of payloads certified to load: § § § March 8, 2017 Bulk compartments Which ULDs can be used in the cargo loading system Special Cargo Provisions including restraint locations and allowables. Cargo Focus Team Federal Aviation Administration 31

Changes To The AFM/WBM q 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. 4 C. q This practice has the potential to lead to noncompliance and unsafe conditions. March 8, 2017 Cargo Focus Team Federal Aviation Administration 32

Regulatory Path: Operating limits q 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 March 8, 2017 Cargo Focus Team Federal Aviation Administration 33

Types of Cargo q 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. March 8, 2017 Cargo Focus Team Federal Aviation Administration 34

Types of Cargo q Unit Load Device Examples 238. 5 inches long by 96 inches wide March 8, 2017 Cargo Team Cargo. Focus Team Federal Aviation Administration 35

Container Unit Load Device March 8, 2017 Cargo Focus Team Federal Aviation Administration 36

TSO Tag March 8, 2017 Cargo Focus Team Federal Aviation Administration 37

Pallet Identification March 8, 2017 Cargo Focus Team Federal Aviation Administration 38

Hazardous Material Notification March 8, 2017 Cargo Focus Team Federal Aviation Administration 39

Pallet Couplers q What are Coupled pallets or a Pallet Train? § 2 or more pallets “coupled” together in a line. § This is seen mostly with military 463 L pallets March 8, 2017 Cargo Focus Team • Two 463 L military pallets coupled together Federal Aviation Administration 40

Pallet Couplers q Pallet coupler installed between two 463 L pallets q Pallet couplers because each pallet is restrained along the inboard and outboard sides of the pallet providing fwd/aft, vertical, and side directions. March 8, 2017 Cargo Focus Team Federal Aviation Administration 41

Pallet Couplers q. Problem: Although 463 L pallets fit on the Boeing 747, they are restrained on the side only in the lateral direction because of the notches in the pallet. March 8, 2017 Cargo Focus Team Federal Aviation Administration 42

Pallet Couplers q. Problem: Although 463 L pallets fit on the Boeing 747, they are certified only as a netted pallet. This means one pallet/net at a time, not coupled. March 8, 2017 Cargo Focus Team Federal Aviation Administration 43

Pallet Couplers q. Problem: Although 463 L pallets fit on the Boeing 747 at some locations, the 463 L notches align with the center line vertical locks. This truck is unrestrained along the inboard side vertically. March 8, 2017 Cargo Focus Team Federal Aviation Administration 44

Pallet Couplers q Pallet coupler installed between two 463 L pallets q Problem: This is where the Boeing 747 pallet locks are supposed to be raised up to react fwd/aft and vertical loads. q Problem: These locks are not raised and the pallet is sitting on top of them. March 8, 2017 Cargo Focus Team Federal Aviation Administration 45

Pallet Couplers q 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: o The forward pallet is unrestrained in the aft direction. o The aft pallet is unrestrained in the forward direction March 8, 2017 Cargo Focus Team Two 463 L military pallets coupled together This is unsafe. Federal Aviation Administration 46

Special Cargo q What has been done in the past? q All of the outboard tiedowns are in the passenger seat tracks. This is not permitted due to low strength of track. q The side of the vehicle tiedown locations were not permitted by ATTLA. March 8, 2017 Cargo Focus Team Federal Aviation Administration 47

Unit Load Device March 8, 2017 Cargo Focus Team Federal Aviation Administration 48

Special Cargo q This cargo exceeds the certified unit load device capability. It is special cargo. March 8, 2017 Cargo Focus Team Federal Aviation Administration 49

Intermodals q This cargo is offset on the pallet. q Under flight loads, can shift outboard. q Prohibited by AD 2015 -14 -09 q The intermodal can still be carried, but restrained directly to the airplane as a special load. March 8, 2017 Cargo Focus Team Federal Aviation Administration 50

Special Cargo Restraint q Special cargo requires restrain directly to the aircraft structure using the methods defined in the airplanes weight and balance manuals NOTE: Some airplanes do NOT have provisions for special cargo. More common on freighter conversions. March 8, 2017 Cargo Focus Team Federal Aviation Administration 51

Calculating Restraint q Some Operators are still using an over simplified method where the tiedown is based on strength of the strap rather than airplane. (Some de-rate the rated strap strength to 75% or 3, 750 pounds. Some use no reduction) q Note – Many TC/STC WBMs allowable loads in certain directions are less than the assumed “conservative” 3, 750 lbs. q Sometimes the airplane is the weakest link in the chain. March 8, 2017 Cargo Focus Team Federal Aviation Administration 52

Operating Limitation (OL) Examples q Processes/procedures that may exceed OL: § Seat track and attachment allowable load limitations exceeding WBM limitations § Intermodal containers loaded offset on ULDs § ULDs (e. g. 463 L w/net) not listed in the WBM § Altering Unit Load Devices (ULD) as defined by AFM/WBM § Oversimplified restraint calculation method March 8, 2017 Cargo Focus Team Federal Aviation Administration 53

Cargo Compliance Expectations q Compliance expectations for operators: § Comply with operating limitations specified in the approved AFM or as otherwise prescribed by the certificating authority of the country of registry § AC 120 -85 A is an alternate means but not the only means of compliance with 14 CFR q What should operators expect from the FAA: § Meet intent of AC 120 -85 A § Review all part 121 weight and balance control programs using job aid March 8, 2017 Cargo Focus Team Federal Aviation Administration 54

In Closing q Cargo operations are an ever changing industry q The risk of a weight and balance (W&B) related accident occurring with cargo flights is between 20 to 50 times higher than with passenger flights q Cargo operations continue to be evaluated for areas of high risk q The Cargo Focus Team reviews are based on compliance to 14 CFR 91. 9 using the TC/STC WBM operating limitations. March 8, 2017 Cargo Focus Team Federal Aviation Administration 55

Questions March 8, 2017 Cargo Focus Team Federal Aviation Administration