AIR CARGO SAFETY SYMPOSIUM August 17, 2017 SPEAKER PRESENTATIONS

Transcription

1 AIR CARGO SAFETY SYMPOSIUM August 17, 2017 SPEAKER PRESENTATIONS

2 PRESENTATIONS MENU Click on the PowerPoint Icon to jump to presentation

3 Air Cargo: Cargo Focus Team Review & Update Federal Aviation Presented to: By: Date: Cargo Safety Symposium Patricia Williams Deputy Division Manager, AFS-301A August 17, 2017

4 Topics Why - Background What - Mission & Vision Who - Team Structure Accomplishments In Progress Impact on Safety Resources Federal Aviation 2

5 Background Afghanistan accident led to formation of a team to determine whether systemic problems exist in handling special air cargo loads Established via FAA Notice Federal Aviation 3

6 Background NTSB final report on from B-747 accident published July 29, 2015 Six safety recommendations 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 Aviation 4

7 Background: Part 121 WBCP Review Findings 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 Aviation 5

8 Background: Three Classifications of Cargo 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 Aviation 6

9 Background: Three Classifications of Cargo 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 Aviation 7

10 Background: Three Classifications of Cargo 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. Federal Aviation 8

11 Federal Aviation 9

12 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. Federal Aviation 10

13 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 Federal Aviation 11

14 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 Federal Aviation 12

15 Accomplishments Safety Alerts for Operators (SAFO)/Information for Operators (InFO) SAFO Part 121Air Carriers Transporting Heavy Vehicle Special Cargo Loads SAFO Part 121 Air Carriers Performing Special Cargo Loads Operations SAFO Non-compliance with a Manufacturer s Federal Aviation (FAA)- approved Aircraft Weight and Balance Manual (WBM) SAFO Cargo Retention Methods Using Pallets Straps InFO FAA-approved Boeing 747 Sample Weight and Balance Manual (WBM) InFO Approved WBM Supplements for Certain Boeing Aircraft Notices: N Accepting/Revising Manuals for All Parts 91K, 121, 125, and 135 Certificate Holders/Operators Transporting Cargo on Transport Category Aircraft N Review of Weight and Balance Control Programs Including Special Cargo Operations Advisory Circular (AC) A, 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). Federal Aviation 13

16 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 Federal Aviation 14

17 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 A series OpSpec for Special Cargo Federal Aviation 15

18 In Progress: Loadmaster Industry Tasking Aviation Rulemaking Advisory Committee (ARAC) Accepted the task on March 23, 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. Federal Aviation 16

19 In Progress: Air Cargo Course Two part course: FAA Air Cargo Operations web-based training (WBT) FAA 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) Federal Aviation 17

20 In Progress: SAS CHEP 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. Federal Aviation 18

21 In Progress: SAS CHEP CFT is using SAS CHEP to evaluate certificate holder s weight and balance programs (WBP). CFT Evaluation team will use the same SAS data collection tools (DCT) that a certificate management team uses as part of normal oversight. CFT CHEP is a custom data collection tool (CDCT) created from several of the design assessment DCTs available in SAS that focus on topics such as Flight/Load Manifests/W & B Procedures, Carriage of Cargo, Aircraft Requirements, WBP, and Cargo Handling Equipment, Systems, and Appliances. Note: Certificate Management Team retains responsibility for day-to-day certificate management; CFT CHEP is only working to evaluate the Weight & Balance Program. Federal Aviation 19

22 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) Federal Aviation August 17,

23 NOTE: Location of Part 121 Cargo Operator CMOs Number shown in box is the number of certificates at office Federal Aviation 21

24 In Progress: CFT Outreach CFT Outreach not completed 1 1 Cargo Workshop 23 CMOs CFT Outreach Completed Number shown in box is the number of certificates at office at the time of CFT Outreach seminar. IATA SAE DoD 1 1 SAE/ IATA April ALPA A4A Federal Aviation 22

25 Impact on Safety 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 Federal Aviation 23

26 Impact on Safety 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 Aviation 24

27 Resources - Cargo Focus Team Cargo Focus Team (CFT) exists as a permanent technical resource for cargo operations For cargo operations questions or suggestions contact 9-NATL-Cargo-CFT@faa.gov FAA Air Cargo Operations site: nfo/pages/air%20cargo%20operations.aspx Federal Aviation 25

28 Air Cargo: Operation Specifications A002, A196, A396 Federal Aviation Presented to: By: Date: Air Cargo Safety Symposium Stephen Moates, AFS-220 Manager August 17, 2017

29 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 Federal Aviation 2

30 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 Federal Aviation 3

31 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 Federal Aviation 4

32 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 Federal Aviation 5

33 ARAC Loadmaster Certification Working Group (LCWG) Presented by co-chairs Mark Phaneuf ALPA Martin McKinney - UPS Air Line Pilots Association, Int l

34 Working Group Purpose 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) Air Line Pilots Association, Int l

35 Tasking 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. Air Line Pilots Association, Int l

36 Progress and Status 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 F download and upload, and special cargo that had been prepared for upload. NTSB presentation of the National Airlines 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 Air Line Pilots Association, Int l

37 Progress The group is reviewing Part 121 accident data between 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 Air Line Pilots Association, Int l

38 Progress Team reviewed 8 options for certification and assigned those options to small teams for a deep dive analysis to report back to the group. This has continued to be the bulk of our work We continue to use the Likert scale and scoring methodology This was a helpful exercise which clearly illustrated the effectiveness for enhancing safety for each option. Air Line Pilots Association, Int l

39 Progress The team reviews progress being made to update Advisory Circular A, 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. Air Line Pilots Association, Int l

40 Progress Team is in the process of determining what method should be used and what the most effective process would look like. Air Line Pilots Association, Int l

41 Progress Our FAA economist from FAA APO continues to work with the team and is applying his economic analysis and scoring as our decisions narrow and the team continues to drill down into our list of Part 121 special cargo accidents. The team has begun to develop the report containing recommendations based on our analysis and findings it is due to ARAC May, Air Line Pilots Association, Int l

42 Air Cargo: IATA & SAE Procedures Federal Aviation Presented to: By: Date: Air Safety Cargo Symposium Patricia Williams, Deputy Division Manager, AFS-301A August 17, 2017

43 Overview NTSB Recommendations Regulatory Path IATA and SAE Procedures Federal Aviation August 17, 2017 Cargo Focus Team 2

44 NTSB Recommendations A Revise the guidance material in Advisory Circular (AC) , Air Cargo Operations, chapter 201(a)(4), to specify that an operator should seek Federal Aviation (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. Federal Aviation August 17, 2017 Cargo Focus Team 3

45 NTSB Recommendations A 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. August 17, 2017 Federal Aviation Cargo Focus Team 4

46 Regulatory Path: Operating Limits Operation of aircraft is covered by 14 CFR part Applicability. (a) Except as provided in paragraphs (b) and (c) of this section and and , 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. August 17, 2017 Cargo Focus Team Federal Aviation 5

47 Regulatory Path: Operating Limits Operation of aircraft is covered by 14 CFR part 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 Cargo Focus Team Federal Aviation 6

48 Regulatory Path: Operating Limits 14 CFR 21.41: Type certificate includes OPERATING LIMITATIONS Type Certificate Aircraft Flight Manual (AFM) OPERATING LIMITATIONS , CFR : Airplane Flight Manual must contain: (1) Information required by Secs through (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 through , that is appropriate to the airplane, must be furnished, verified, and approved 14 CFR : 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. August 17, 2017 Cargo Focus Team Federal Aviation 7

49 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? August 17, 2017 Cargo Focus Team Federal Aviation 8

50 Regulatory Path: Operating Limits 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 preamble addresses this topic August 17, 2017 Cargo Focus Team Federal Aviation 9

51 Regulatory Path: Operating Limits 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 C. This practice has the potential to lead to noncompliance and unsafe conditions. August 17, 2017 Cargo Focus Team Federal Aviation 10

52 Regulatory Path: Operating Limits Takeaways Instructions for loading cargo are required by 14 CFR 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 August 17, 2017 Cargo Focus Team Federal Aviation 11

53 IATA and SAE Procedures 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. August 17, 2017 Cargo Focus Team Federal Aviation 12

54 IATA and SAE Procedures You can use these limitations These procedures are within WBM limits You can NOT use these limitations. They exceed WBM limits WBM Operating Limitations IATA SAE MIL-Spec Etc. August 17, 2017 Cargo Focus Team Federal Aviation 13

55 FAA Outreach Collaboration Federal Aviation Undeclared Hazardous Materials Janet McLaughlin Director, FAA Office of Hazardous Materials Safety

56 Vision 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 Aviation 2

57 Problem Statements 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 Aviation 3

58 Undeclared Incidents CY 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, Federal Aviation 4

59 Number of Incidents Number of Incidents Undeclared Incidents CY All Release CY 2011 All Release CY 2012 CY 2013 CY 2014 CY 2015 CY 2016 Incidents No Release No Release CY 2011 CY 2012 CY 2013 CY 2014 CY 2015 CY 2016 No Release Federal Aviation 5

60 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. Federal Aviation 6

61 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. Federal Aviation 7

62 Mitigation Strategies for Transporting Batteries on Aircraft Captain Bob Brown Independent Pilots Association

63 E-ULD Fire Detection/Suppression Enhancing Safety for the Aviation Community

64 E-ULD Fire Detection/Suppression Goal is 6+ Hours of Fire Containment

65 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 ULD Detected in 1 minute and Extinguished within 20 seconds

66 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

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68 Safe2Fly 3 rd Party Review & Risk Assessment Battery Science Design, Manufacture & Certification Packaging Labeling 50% or Database Risk Assessment Transport, Inspect of Reject Identify and Prosecute Counterfeit

69 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 Safe2Fly Pilots will have confidence in a objective and impartial Third party review and certification process

70 J. Thomas Chapin, Ph.D. Vice President Research Corporate Fellow Copyright 2017 UL LLC. All rights reserved.

71 Cell Failure and ISC Behavior How and Why? Use Overcharge Drop Crush Handling Design Imbalance Material Properties Improper Separator Over design Abnormal Pressure Unstable Design Dendrite Severe Environment Abnormal Temperature Internal Short-Circuit Mechanical Abuse Process Issue(s) Other (bad welds, loose metal parts, etc.) Impact Shock / Vibration Contamination Burrs Tab/electrode misalignment Operation Manufacture Copyright 2017 UL LLC. All rights reserved. 1

72 Cell ISC Failure Test Methods Slow Speed Nail Penetration ITRI Forced ISC (FISC) Test BAJ Pinch Test Oak Ridge Hot Pad test Low-Melting Point Metal/Alloy Sandia ARC Thermal Abuse test Indentation Induced ISC (IIISC) Test UL/NASA Copyright 2017 UL LLC. All rights reserved. 2

73 Aircraft Battery Cargo Assessment Unknown Battery Cargo Uncharacterized cells Unknown/counterfeit cells Unstable batteries Unstable batteries Improperly packaged batteries Improperly labeled package Unidentified package Unverified products Unverified cargo Testing Certification Electrical Abuse Physical Abuse Validation Validation Imaging/Detection Imaging/Validation Detection/Suppression Known Battery Cargo Known cells Certified cells/batteries Certified batteries Certified batteries Qualified package Verified labeling Verified identification Certified products Fire suppression system Copyright 2017 UL LLC. All rights reserved. 3

74 Mitigating the Fire Risks PREVENTING THE FIRE MANAGING THE FIRE EVENT Strategy Preventive measures Fire growth control Life safety and property protection Fire mitigation Ignition Sources Precipitating Hazard v Intentional v Human error v Equipment malfunction v Chemical reaction v Internal sources v External sources Fuels v Combustible items Ignition Event Enabling Hazards v Additional combustible materials (furnishings, interior finish, etc.) v Fire and smoke paths through building structure Vulnerability Hazard v Fire spread to adjoining areas v Smoke spread v Blocked agress paths v Fire spread to adjoing buildings Fire Impact v Injuries/ fatalities v Property Loss Tools v Safety in Design v Product Certification v Construction codes v Maintenance and housekeeping Copyright 2017 UL LLC. All rights reserved. v Reduced oxygen environment v Aspirated gas and smoke detection v Fire extinguishment systems v Fire resistance v Fire containment v Egress paths v Designated safe zones v Firefighter access v Emergency service response v Search and rescue NFPA 550 4

75 Multilayered Lithium Battery Risk Reduction Bob Richard President Hazmat Safety Consulting LLC

76 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; and 2. 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.

77 Lithium Battery Dangers

78 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

79 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.

80 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 granularity and have been advised that this would be an issue for the Sub-committee to consider.

81 Classification should be based on inherent risk New, safer technologies and chemistries being developed American Engineer Invents A Battery That Cannot Explode Different form factors or chemistries present different risks. Provide incentives for development of safer batteries with less stringent regulations?

82 Improved Packaging

83 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

84 Containment systems for passenger aircraft

85 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.

86 Fire Suppression System Need a more aggressive program to replace the Gill liner and Halon Fire Suppression Systems Fire 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.

87 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

88 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.

89 Bob Richard President Hazmat Safety Consulting LLC

90 Commercial Aviation Safety Team

91 WHITE HOUSE COMMISSION ON AVIATION SAFETY AND THE NATIONAL CIVIL AVIATION REVIEW COMMISSION (NCARC) Reduce Fatal Accident Rate Strategic Plan to Improve Safety Improve Safety Worldwide...

92 CAST BRINGS TOGETHER KEY STAKEHOLDERS TO COOPERATIVELY DEVELOP AND IMPLEMENT A PRIORITIZED SAFETY AGENDA. A4A AIA Airbus ALPA ACI NA CAPA IATA** NACA Boeing GE* RAA FSF Industry Commercial Aviation Safety Team Government DOD FAA NASA ICAO** TCCA NATCA NTSB** EASA** * Representing P&W and RR ** Observer

93 CAST GOAL CAST came together in 1997 to form an unprecedented industry-government partnership. Voluntary commitments, data-driven risk management, implementation-focused. Goal: Original New Reduce the US commercial aviation fatal accident rate 80% by Reduce the U.S. commercial aviation fatality risk by at least 50% from 2010 to 2025.

94 CAST SAFETY STRATEGY Data Analysis Implement Safety Enhancements (SE) United States Agree on problems and interventions Set Safety Priorities Achieve consensus on priorities Influence SEs Worldwide Integrate into existing work and distribute

95 Risk Eliminated by Safety Enhancements Resource Cost ($ Millions) RESOURCE COST VS. RISK REDUCTION 100% 75% $ Risk Reduction Total Cost in $ (Millions) APPROVED PLAN % $ % % $ $ $

96 Dollars/Flight Cycle COST SAVINGS Part 121 Aviation Industry Cost Due to Fatal/Hull Loss Accidents 100 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 2020 levels

97 30 Study Prioritization (Fleet Risk) Yrs to 1 or more expected accidents Years to 1 or More Expected Accidents STUDY PRIORITIZATION (FLEET RISK) Risk Level Appropriate for Monitoring 1 accident in 20 yrs Risk Level Appropriate for Study RR SEs Risk Levels Fatality Accident Current Accident Rate 0 1% 10% 100% Fatality Risk - (Severity) Fatality Risk (Severity)

98 CAST SAFETY ENHANCEMENTS Underway (R&D), 11 Underway, 25 Completed (R&D), 10 Completed, 76

99 SAFETY PORTFOLIO MONITORING SE Title Output Lead Organization Due 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

100 FATALITY RISK (EQUIVALENT FULL PLANELOADS)

101 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 Accident Review Cargo Operations Mitigations Underway Key Government and industry initiatives underway: Cargo Focus Team Loadmaster Certification Working Group Portfolio Assessment Cargo Ops Spec development AC A being revised

102 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 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 UPS 08/14/2013 CFIT Applicable = Implemented

103 Applicable CAST SEs Not in Effect at Time of 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 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 Applicable = Implemented

104 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.

105 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.

106 AIRCRAFT DEMOGRAPHICS 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? 21

107 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

108 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)?

109 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?

110 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

111 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.

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122 Air Cargo: Part 135 Operations Federal Aviation Presented to: By: Date: Cargo Safety Symposium Patricia Williams Deputy Division Manager AFS-301A August 17, 2017

123 Overview Reasons to evaluate part 135 weight & balance programs Part 135 findings & risks Timelines for evaluating part 135 weight & balance programs Federal Aviation 2

124 Reasons to Evaluate Part 135 Ops Dual 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 Federal Aviation 3

125 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 Federal Aviation 4

126 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 Federal Aviation 5

127 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 Cargo Only 44 Pilot in Command Federal Aviation 6

128 Federal Aviation Foreign Air Carrier Update Presented to: Cargo Symposium By: Darcy D Reed Manager International Operations Branch Date: August 17, 2017

129 Quick Overview Current 129 Operations 129 Oversight functions Non Compliance CAA Outreach ICAO Cargo Symposium August 17, 2017 Federal Aviation 2

130 Current Technical Authorizations There are approximately CFR part 129 air carrier s conduction operations into and out of the U.S. NAS. Of these 400 operators 23 conduct cargo operations. 129 operators account for 45% of the international flights into and out of the U.S. NAS on a daily basis. Cargo Symposium August 17, 2017 Federal Aviation 3

131 Part 129 Oversight Functions International 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. Cargo Symposium August 17, 2017 Federal Aviation 4

132 Operator Non Compliance letter or enforcement process. Civil Aviation Authority Informal communication or formal notification. Processed through the U.S. State Department Heighten Surveillance List Two foreign (Cargo) air carriers are currently on the list for increased surveillance. Cargo Symposium August 17, 2017 Federal Aviation 5

133 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). Cargo Symposium August 17, 2017 Federal Aviation 6

134 State of the Operator Responsibilities Provisions in Annex 6, Part I, require the State to have made a technical evaluation. These provisions contain the phrases: Acceptable to the State, satisfactory to the State, determined by the State, deemed acceptable by the State, and prescribed by the State.. Cargo Symposium August 17, 2017 Federal Aviation 7

135 Annex 6, Part 1, Appendix 2 Annex 6, Part 1, Appendix 2 requires the Ops Manual to have instructions for: Ground handling arrangements and procedures Instructions for mass and balance control Certification limitations and operating limitations Instructions and data for mass and balance calculations Instructions for aircraft loading and securing of load. These standards are approved by the State of the Operator Cargo Symposium August 17, 2017 Federal Aviation 8

136 Thank you Cargo Symposium August 17, 2017 Federal Aviation 9

137 Cargo Certification Process Federal Aviation Presented to: By: Date: Air Cargo Safety Symposium Phil Forde Manager, Airframe Section Seattle ACO Branch August 17, 2017 Federal Aviation

138 Overview Review Operating Limitations FAA Order C, 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 Federal Aviation 2

139 Review Operating Limitations 14 CFR 21.41: Type certificate includes operating limitations Type Certificate Aircraft Flight Manual (AFM) Operating Limitations , CFR : Airplane Flight Manual (AFM) must contain: (1) Information required by Secs through (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 through , that is appropriate to the airplane, must be furnished, verified, and approved 14 CFR : 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. 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 Aviation 3

140 FAA Order C, 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 Federal Aviation 4

141 Changes to the Type Certificate Section (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 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 Federal Aviation 5

142 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 Federal Aviation 6

143 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 Federal Aviation 7

144 FAA records for U.S. Part 121 carriers since 2000 show: Aircraft types Total Passenger ( 94% ) Freighter ( 6 %) Number of hull loss and/or fatal accidents 46 ( 100 %) 20 ( 44 % ) 26 ( 56 %) 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. Federal Aviation 8

145 Federal Aviation 9

146 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 Federal Aviation 10

147 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 Federal Aviation 11

148 Modification of Existing STCs What is required to modify an existing STC held by another party? Same requirements as for a new STC Applicable requirements (a) Each applicant for a supplemental type certificate must show that the altered product meets applicable requirements specified in Federal Aviation 12

149 Cargo-Related Design Guidance Where can I find guidance on data needed to support approval of cargo-related STCs? Your local certification office AC A, Air Cargo Operations AC 25-18, Transport Category Airplanes Modified for Cargo Service Federal Aviation 13

150 AC A, Air Cargo Operations Provides guidance on cargo operations and related modifications Appendix E Structural data for passengerto-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 Federal Aviation 14

151 AC A, 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 permits a separate manual incorporated by reference in the AFM Federal Aviation 15

152 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 Federal Aviation 16

153 Structural Assessment The retention of cargo to the airplane is like the strength of a chain. Having one strong link does not increase the strength of the chain Wing Fuselage Floor CLS fitting Pallet Net or Strap Cargo Federal Aviation 17

154 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? Federal Aviation 18

155 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 Federal Aviation 19

156 Structural Assessment Location of seat track used by National Flight 102 Not permitted by Boeing WBM MRAP #4 MATV #5 Location of the permitted straps found Source: NTSB National Accident docket Structures Report attachment #2 Federal Aviation 20

157 Surrendered STCs FAA Order , 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 Federal Aviation 21

158 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 Federal Aviation 22

159 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 Federal Aviation 23

160 CERTIFICATION PROCESS LESSONS LEARNED Presented to: Air Cargo Safety Symposium August 17, 2017

161 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

162 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

163 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

164 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 F aircraft. Some of the resolved issues in these changes include:

165 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.

166 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.

167 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.

168 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

169 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.

170 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: