Cargo Certification Process Presented to: By: Date: Air Cargo Safety Symposium Phil Forde Manager, Airframe Section Seattle ACO Branch August 17, 2017
Overview Review Operating Limitations FAA Order 8110.4C, Type Certification Issues found during Cargo Focus Team (CFT) reviews Resolution of design approval issues Modification of existing supplemental type certificates (STCs) Cargo-related design guidance Structural assessment Surrendered STCs Closing 2
Review Operating Limitations 14 CFR 21.41: Type certificate includes operating limitations Type Certificate 21.41 Aircraft Flight Manual (AFM) Operating Limitations 25.1581, 25.1583 14 CFR 25.1581: Airplane Flight Manual (AFM) must contain: (1) Information required by Secs. 25.1583 through 25.1587. (2) Information that is necessary for safe operation because of design, operating, or handling characteristics. (b) Approved information. Each part of the manual listed in Secs. 25.1583 through 25.1587, that is appropriate to the airplane, must be furnished, verified, and approved 14 CFR 25.1583: Operating limitations (c) Airplane Flight Manual or separate weight and balance control and loading document that is incorporated by reference in the Airplane Flight Manual: (2) Loading instructions necessary to ensure loading of the airplane within the weight and center of gravity limits, and to maintain the loading within these limits in flight. 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 3
FAA Order 8110.4C, Type Certification Applies to both type certificates (TCs) and STCs Defines the design certification process Process flow times are dictated by the complexity and priority of the project Applies to FAA employees and delegated persons and organizations 4
Changes to the Type Certificate Section 25.1583(c) requires the AFM to include weight and balance information, including loading instructions, as operating limitations Operating limitations must be FAA-approved and are part of the type certificate A change to the loading instructions required by 25.1583 are a change to the type certificate, and must be made via an amended TC, STC, or amended STC Changes to the AFM submitted by someone other than the TC holder must be accomplished by an AFM Supplement 5
Issues Found During CFT Reviews Operators not staying in the operating limitations defined in the original equipment manufacturer (OEM) weight and balance manual (WBM) Almost 100% of the 25 initial reviews Root cause of some findings related to design approvals Impacted 7 of 25 reviews The CFT is working directly with the Aircraft Certification Service (AIR) to resolve these issues To date, most of the issues have been resolved 6
Problem Areas Impacting Operating Limitations Use of military pallets as unit load devices (ULDs) without an STC Does not engage all locks along the fuselage length-wise Results in broken locks and potential for unrestrained cargo Altering TSO ULD pallets with straps, pallet couplers, modifying pallets - while retaining classification as a TSO ULD Straps concentrate load, break locks, can overload the floor locally Simplifying restraint calculations Results in not enough straps to restrain cargo for flight loads 7
FAA records for U.S. Part 121 carriers since 2000 show: 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. 8
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Design Approval Issues Unauthorized approvals of changes to the airplane operating limitations in the WBMs made by Designated Engineering Representatives (DERs) DER approvals beyond their authorizations, such as: DER approval of a modification to a Technical Standard Order (TSO) DER approval of deviations to lock or loading configurations that do not conform to NAS 3610 or AS36100 Engineering errors in the TC WBMs and STC WBM Supplements Undefined loading configurations Non-compliant loading configurations that exceed the airplane design capabilities (potentially unsafe) STCs without associated airplane operating limitations (WBM Supplement) needed for operations A DER should recommend approval of the AFM or AFM Supplement unless specifically authorized in writing to approve Must be in connection with TC or STC 10
Resolution of Design Approval Issues What is AIR doing to correct these issues? Instructed certification offices that: Cargo project STCs must have an associated WBM or WBM supplement with loading instructions and procedures Loading instructions must prevent exceeding airplane design capability Loading instructions must be identified as operating limitations on the TC or STC via the AFM or AFM supplement Multiple internal standardization briefings and project consultation Upcoming policy on certification of cargo projects Upcoming training for FAA employees and designees 11
Modification of Existing STCs What is required to modify an existing STC held by another party? Same requirements as for a new STC 21.115 Applicable requirements (a) Each applicant for a supplemental type certificate must show that the altered product meets applicable requirements specified in 21.101 12
Cargo-Related Design Guidance Where can I find guidance on data needed to support approval of cargo-related STCs? Your local certification office AC 120-85A, Air Cargo Operations AC 25-18, Transport Category Airplanes Modified for Cargo Service 13
AC 120-85A, Air Cargo Operations Provides guidance on cargo operations and related modifications Appendix E Structural data for 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 14
AC 120-85A, Air Cargo Operations Appendix E, paragraph E.2 Aircraft Loading Document Describes the types of cargo containers allowed, how the containers are restrained, and loading requirements when latches are missing or broken This may* be contained in the Weight and Balance (W&B) manual Ensures compatibility of the cargo loading system (CLS) with the cargo conversion If the use of tiedown fittings is permitted, the tiedown strength and limitation data should be provided * 14 CFR 25.1583 permits a separate manual incorporated by reference in the AFM 15
AC 25-18, Transport Category Airplanes Modified for Cargo Service Provides guidance on: Structural requirements Compartment classification Fire protection features Emergency egress Ventilation Loading procedures and limitations 16
Structural Assessment The retention of cargo to the airplane is like the strength of a chain. Having one strong link does not increase the strength of the chain Wing Fuselage Floor CLS fitting Pallet Net or Strap Cargo 17
Structural Assessment For example: A 463L pallet tie down ring might be rated at 7,500 lbs What if you don t have the data and don t know the floor is only adequate for a tie down load of 1,500 lbs? What if you don t know loads from other adjacent pallet tie downs that affect the structural capacity of the floor structure? 18
Structural Assessment What happens if you make the wrong assumptions? For example: Using 75% of the rated strap strength for restraining cargo Assuming that any location in the airplane that a strap double stud fitting can be attached is rated at 5,000 lbs 19
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 20
Surrendered STCs FAA Order 8110.120, Processing Surrendered, Abandoned, and Historical Aircraft Type Certificates Current policy and procedures for processing TCs or STCs surrendered by a design approval holder (DAH) The surrender of a TC does not affect the airworthiness certificates of existing aircraft All data surrendered by the former DAH is retained by the FAA for FAA use only, unless the DAH has given the FAA permission to release the data to others 21
Surrendered STCs Typically results in inability to obtain data and provide technical support for affected airplanes The surrender of a certificate is a final action Once surrendered, the action cannot be reversed A certificate cannot be reissued to a third party or a former holder 22
In Closing Cargo operations are an ever changing industry AIR is working with applicants for new or expanded cargo capabilities Some industry participants such as Kalitta, Atlas and Boeing are leading the way on addressing emerging issues No new rules or standards are being imposed, only compliance to existing rules and standards We recognize the difficulties facing industry in dealing with abandoned STCs, missing/incomplete documentation, and configuration migration, and will do what we can to assist 23