AIR SAFETY SYMPOSIUM August 17, 2017

SPEAKER PRESENTATIONS PRESENTATIONS MENU Click on the PowerPoint Icon to jump to presentation Air Cargo: Federal Aviation Administration Cargo Focus Team Review & Update

Presented to: Cargo Safety Symposium By: Patricia Williams Deputy Division Manager, AFS-301A

Date: August 17, 2017 Topics

• Why - Background • What - Mission & Vision • Who - Team Structure • Accomplishments • In Progress • Impact on Safety • Resources

Federal Aviation 2 Administration 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 8900.262

Federal Aviation 3 Administration Background • A-15-13: Revise guidance to specify use of (FAA)-approved data for methods for restraining special cargo. Remove FAA accepted data. NTSB final report • A-15-14: Create a loadmaster on from B-747 certification. accident published • A-15-15: Review manuals to ensure July 29, 2015 cargo operations is based on relevant FAA-approved data (special emphasis on special cargo restraint).

• A-15-16: Define responsibilities for Six safety principal inspectors for the loading, recommendations restraint, and documentation. • A-15-17: Initial and recurrent training for principal inspectors

• A-15-18: Surveillance deferrals.

Federal Aviation 4 Administration 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 Administration 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 Administration 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 Administration 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 Administration Federal Aviation 9 Administration Background: Special Cargo

Past practices:

• All outboard tiedowns are in seat tracks. – This is not permitted due to low strength of track. • Side of vehicle tiedown locations not permitted.

Federal Aviation 10 Administration 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 Administration 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 Administration Accomplishments • Safety Alerts for Operators (SAFO)/Information for Operators (InFO) – SAFO 13005 Part 121Air Carriers Transporting Heavy Vehicle Special Cargo Loads – SAFO 13008 Part 121 Air Carriers Performing Special Cargo Loads Operations – SAFO 17003 Non-compliance with a Manufacturer’s Federal Aviation Administration (FAA)- approved Aircraft Weight and Balance Manual (WBM) – SAFO 17004 Cargo Retention Methods Using Straps

– InFO 13012 FAA-approved Sample Weight and Balance Manual (WBM) – InFO 15010 Approved WBM Supplements for Certain Boeing Aircraft

• Notices: – N8900.317 Accepting/Revising Manuals for All Parts 91K, 121, 125, and 135 Certificate Holders/Operators Transporting Cargo on Transport Category Aircraft – N8900.262 Review of Weight and Balance Control Programs Including Special Cargo Operations • Advisory Circular (AC) 120-85A, Air Cargo Operations – Dated 6/25/15 – Provides guidance for developing a cargo operations program as part of the weight and balance control program (WBCPs).

Federal Aviation 13 Administration 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 Administration In Progress: OpSpecs

• E096 – Title Change • Revised from Weight and Balance Control Procedures to Aircraft Weighing • A002 Definitions • Updated with definitions for Bulk cargo, Special Cargo and Certified ULD Cargo • Cargo OpSpecs • A196 – Bulk and Certified ULDs • A396 – 300 series OpSpec for Special Cargo

Federal Aviation 15 Administration In Progress: Loadmaster – Industry Tasking

• Aviation Rulemaking Advisory Committee (ARAC)

• Accepted the task on March 23, 2016. • ARAC Loadmaster Certification Working Group (LCWG) has been formed • Report & recommendations due for FAA review and acceptance no later than 24 months from the publication date of this notice in the Federal Register, FY2018.

Federal Aviation 16 Administration In Progress: Air Cargo Course • Two part course: • FAA27100256 – Air Cargo Operations web-based training (WBT) • FAA21000056 – Air Cargo Operations Practical Applications Workshop (PAW) that will be held at the FAA Academy in Oklahoma City, OK. • First FAA Class to ASIs 4/6/2017 • FAA will make these courses available for industry participation FY18. • Please direct all questions to Ms. Connie Stone at (405)-954-6346

•

Federal Aviation 17 Administration 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 Administration 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 Administration In Progress: WBCP Reviews • 29 Cargo operations / 49 Passenger operations • 25 of 78 initial reviews complete • 86% of Cargo Operators • 19 of 78 reviews concurred/closed • 66% of Cargo Operators • Estimate completion of part 121 in 2020 • Passenger Operations and Cargo • 57% of cargo between the Americas and Europe is on a passenger airplane (Boeing) • U.S. passenger service flew 7.95 billion revenue ton miles of cargo last year. (FAA)

August 17, 2017 Federal Aviation 20 Administration NOTE: Location of Part 121 Cargo Operator CMOs

Number shown in box is the number 1 of certificates at 1 office 5

1 1 1 3 3 1

2 2

3 3

Federal Aviation 21 Administration In Progress: CFT Outreach CFT Outreach 1 1 Completed CFT Outreach not completed Cargo Workshop 5 23 CMOs 2 1

DoD 1 ALPA A4A IATA 1 3 Number shown in box is the number of 1 certificates at office 2 at the time of CFT Outreach seminar. SAE 3 SAE/ 2 IATA April 3 2017 3

Federal Aviation 22 Administration 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 Administration 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 Administration Resources - Cargo Focus Team

• Cargo Focus Team (CFT) exists as a permanent technical resource for cargo operations

• For cargo operations questions or suggestions contact CFT @ [email protected]

• FAA Air Cargo Operations site: https://avssp.faa.gov/avs/afs300/SharedInfo/CargoI nfo/Pages/Air%20Cargo%20Operations.aspx

Federal Aviation 25 Administration Air Cargo: Federal Aviation Operation Administration Specifications A002, A196, A396

Presented to: Air Cargo Safety Symposium Stephen Moates, By: AFS-220 Manager Date: August 17, 2017 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 Administration 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 Administration 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 Administration 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 Administration ARAC Loadmaster Certification Working Group (LCWG)

Presented by co-chairs Mark Phaneuf – ALPA Martin McKinney - UPS

Air Line Pilots Association, Int’l Working Group Purpose

▪ Formed as the FAA’s method of responding to one of the NTSB recommendations from the National accident to certificate Loadmasters. ▪ Industry lead team (Boeing, FedEx, Kalitta, Alaska Air, Northern Air Cargo, Atlas Air, National Airlines, Cargo Association, National Air Carrier Association, UPS, Professional Loadmaster Association, ALPA)

Air Line Pilots Association, Int’l 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 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 747-400F download and upload, and special cargo that had been prepared for upload. – NTSB presentation of the National Airlines 747-400 BCF accident at Bagram Air Base, for a baseline foundation to the group and to explain the recommendations made to the FAA in order to understand the background and development of the ARAC

tasking Air Line Pilots Association, Int’l Progress

▪ The group is reviewing Part 121 accident data between 1996-2016 with cargo shift or damage to the aircraft from cargo ▪ Determining which persons are responsible for performing the functions necessary for special cargo movements (Loadmaster is undefined in the commercial world): – SCAF (Special Cargo Analysis Function) – load analysis and planning for special cargo loads – Special Cargo Loading Supervisor – validation that special cargo loading plan was implemented correctly

Air Line Pilots Association, Int’l 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 Progress

▪ The team reviews progress being made to update Advisory Circular 120-85A, Air Cargo Operations that includes Bulk Cargo, Certified Unit Load Device (ULD) and Special Cargo definitions. ▪ The team has unanimously agreed that the SCAF function, if certificated, would make a positive enhancement to safety.

Air Line Pilots Association, Int’l 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 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, 2018.

Air Line Pilots Association, Int’l Air Cargo: Federal Aviation Administration IATA & SAE Procedures

Presented to: Air Safety Cargo Symposium By: Patricia Williams, Deputy Division Manager, AFS-301A

Date: August 17, 2017 Overview

• NTSB Recommendations

• Regulatory Path

• IATA and SAE Procedures

August 17, 2017 Cargo Focus Team Federal Aviation 2 Administration NTSB Recommendations A-15-13

• Revise the guidance material in Advisory Circular (AC) 120-85, “Air Cargo Operations,” chapter 201(a)(4), to specify that an operator should seek Federal Aviation Administration (FAA)-approved data for any planned method for restraining a special cargo load for which approved procedures do not already exist, and remove the language in the AC that states that procedures other than those based on FAA-approved data can be used.

Cargo Focus Team Federal Aviation 3 August 17, 2017 Administration NTSB Recommendations A-15-15

Add a special emphasis item for inspectors of 14 Code of Federal Regulations Part 121 cargo operators to review their manuals to ensure that the procedures, documents, and support in the areas of cargo loading, cargo restraint, and methods for securing cargo on transport-category airplanes are based on relevant FAA-approved data, with particular emphasis on restraint procedures for special cargo that is unable to be loaded via unit loading devices or bulk compartments.

• Note: SAE and IATA procedures are not FAA approved.

August 17, 2017 Cargo Focus Team Federal Aviation 4 Administration 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 (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 Administration Regulatory Path: Operating Limits

Operation of aircraft is covered by 14 CFR part 91

§91.9 Civil aircraft flight manual, marking, and placard requirements. (a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the OPERATING LIMITATIONS specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.

August 17, 2017 Cargo Focus Team Federal Aviation 6 Administration Regulatory Path: Operating Limits 14 CFR 21.41: Type certificate includes OPERATING LIMITATIONS

14 CFR 25.1581: Airplane Flight Manual must contain: Type Certificate (1) Information required by Secs. 25.1583 through § 21.41 25.1587. (2) Information that is necessary for safe operation because of design, operating, or handling characteristics. Aircraft Flight (b) Approved information. Each part of the manual listed in Manual (AFM) Secs. 25.1583 through 25.1587, that is appropriate to the airplane, must be furnished, verified, and approved OPERATING 14 CFR 25.1583: OPERATING LIMITATIONS LIMITATIONS (c) Airplane Flight Manual or separate weight and balance § 25.1581, control and loading document that is incorporated by § 25.1583 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 Administration 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 Administration 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 2015-14-09 preamble addresses this topic

August 17, 2017 Cargo Focus Team Federal Aviation 9 Administration 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 8110.4C.

• This practice has the potential to lead to noncompliance and unsafe conditions.

August 17, 2017 Cargo Focus Team Federal Aviation 10 Administration Regulatory Path: Operating Limits Takeaways • Instructions for loading cargo are required by 14 CFR 25.1583 • Operating instructions for loading the cargo defined in the Weight and Balance Manual (WBM) • 14 CFR 91.9(a) requires compliance with operations limitations in WBM • If changes to operating limitations defined in the WBM are desired, an Amended/Supplemental Type Certificate is required. • Procedures such as IATA/SAE which do not alter these limitations are still permitted (i.e. 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 Administration 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.

Cargo Focus Team Federal Aviation 12 August 17, 2017 Administration IATA and SAE Procedures You can NOT use You can use these these limitations. limitations These procedures are They exceed WBM within WBM limits limits

WBM IATA Operating SAE Limitations MIL-Spec Etc.

August 17, 2017 Cargo Focus Team Federal Aviation 13 Administration Federal Aviation FAA Outreach Administration Collaboration

Undeclared Hazardous Materials

Janet McLaughlin Director, FAA Office of Hazardous Materials Safety 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 Administration 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 Administration Undeclared Incidents CY2011 - 2016

 In calendar year 2011 through 2016, there were 3,114 reported undeclared Hazardous Materials air incidents.

 These incidents resulted in the following “Undeclared Sanction Amount by Entities”: » Shipper - $12,418,735.00 » Air Carrier - $162,250.00 » Foreign Air Carrier - $625,000.00 » Indirect Air Carrier - $14,000.00 » Passenger - $353,887.00 » Personal/Business - $20,000.00 » Repair Station - $315,000.00 » Total - $13,908,872.00

Federal Aviation 4 Administration Undeclared Incidents CY2011 - 2016

All Release  All Release 250 200 150 100 50 0

Number ofIncidents CY CY CY CY CY CY 2011 2012 2013 2014 2015 2016 Incidents 184 194 152 164 112 117

No Release 800  No Release 600 400 200 0 CY CY CY CY CY CY Number ofIncidents 2011 2012 2013 2014 2015 2016 No Release 538 593 588 554 452 466

Federal Aviation 5 Administration 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 Administration 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 Administration Mitigation Strategies for Transporting Batteries on Aircraft

Captain Bob Brown Independent Pilots Association E-ULD Fire Detection/Suppression

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

Goal is 6+ Hours of Fire Containment Safety Task Force E-ULD Testing

• Test 1– FAA Class-A Fire with fully loaded ULD. Detected within 2 minutes and extinguished within 30 seconds

• Test 2– FAA Class-A Fire with ½ load ULD. Detected within 1 minute and extinguished within 30 seconds

• Test 3– Challenging Group A- Plastics fully loaded ULD Detected in 1 minute and Extinguished within 20 seconds The Path Forward

UL Science Evaluates Design FAA Supplemental Type Airline Industry has a path and Conducts Additional Certificate Issued forward to begin Battery Testing Testing

Safe2Fly 3rd Party Review & Risk Assessment

Design, Manufacture Battery Science Packaging Labeling & Certification

50%

or

Transport, Database Risk Assessment Identify and Prosecute Inspect of Reject Counterfeit Cargo and Passenger Airlines Benefit

• Batteries from reputable manufacturers and risked as safe via SMS process can be “fast tracked” for transport Safe2Fly • Airlines and Government will have objective data for SMS risk assessments

• Pilots will have confidence in a objective and impartial Third party review and certification process J. Thomas Chapin, Ph.D. Vice President Research Corporate Fellow

© Copyright 2017 UL LLC. All rights reserved. Cell Failure and ISC Behavior – How and Why?

Handling Use Overcharge Drop Crush

Imbalance Impact Mechanical Material Dendrite Abuse Properties Shock / Vibration Internal Improper Short-Circuit Contamination Separator Unstable Design Process Over design Severe Issue(s) Burrs Environment Abnormal Tab/electrode misalignment Pressure Abnormal Other (bad welds, Design Temperature loose metal parts, etc.)

Operation Manufacture

© Copyright 2017 UL LLC. All rights reserved. 1 Cell ISC Failure Test Methods

Slow Speed Forced ISC (FISC) Test Nail Penetration BAJ Pinch Test ITRI Oak Ridge

Hot Pad test

Indentation Induced Low-Melting Point ISC (IIISC) Test Metal/Alloy UL/NASA Sandia ARC Thermal Abuse test

© Copyright 2017 UL LLC. All rights reserved. 2 Aircraft Battery Cargo Assessment

“Unknown” Battery Cargo “Known” Battery Cargo Testing Uncharacterized cells “Known” cells Certification Unknown/counterfeit cells Certified cells/batteries Electrical Abuse Unstable batteries Certified batteries Physical Abuse Unstable batteries Certified batteries Validation Improperly packaged batteries Qualified package Validation Improperly labeled package Verified labeling Imaging/Detection Unidentified package Verified identification Imaging/Validation Unverified products Certified products Detection/Suppression Unverified cargo Fire suppression system

© Copyright 2017 UL LLC. All rights reserved. 3 Mitigating the Fire Risks

PREVENTING THE FIRE MANAGING THE FIRE EVENT

Life safety Preventive Fire growth Fire and measures control mitigation Strategy property protection

Ignition Sources

v Internal sources v External sources Ignition Enabling Vulnerability Precipitating Fire Impact Hazard Event Hazards Hazard v v Additional Fire spread to v Injuries/ v Intentional combustible adjoining areas fatalities v v Human error materials Smoke spread v Property v v Equipment Fuels (furnishings, interior Blocked agress Loss malfunction finish, etc.) paths v v Chemical v Fire and smoke Fire spread to reaction v Combustible paths through adjoing buildings items building structure

v Safety in Design v Reduced oxygen v Fire resistance v Firefighter access v Product environment v Fire containment v Emergency Certification v Aspirated gas v Egress paths service response v Construction and smoke v Designated safe v Search and Tools codes detection zones v Maintenance and v Fire rescue housekeeping extinguishment systems © Copyright 2017 UL LLC. All rights reserved. NFPA 550 4 Multilayered Lithium Battery Risk Reduction

Bob Richard President Hazmat Safety Consulting LLC

773-540-0837 [email protected] www.hazmatsafety.com 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.

www.hazmatsafety.com Lithium Battery Dangers

www.hazmatsafety.com Risk Mitigation must be layered

• Less complicated regulations • Classify based on inherent risk • Improved packaging • Enhanced enforcement and more aggressive penalties • Containment systems for passenger aircraft • ULDs and FRCs • Cargo Liner • Halon Fire Suppression

www.hazmatsafety.com Less complicated Regulations

ICAO Statement: The risks posed by non-compliant shipments, both deliberate and inadvertent, needs to be addressed.

Fully complying with the complex regulations can be difficult if not impossible to do.

The current regulatory framework depends on shippers knowing that batteries and cells have passed tests in accordance with the UN Manual of Tests and Criteria.

www.hazmatsafety.com Classification should be based on inherent risk

• The risks posed by lithium batteries varies depending on size, chemistry, design type and quantities shipped and some may pose little risk to aircraft.

• There is no way to distinguish between different batteries types presented for transport other than under the two major groups, lithium ion or lithium metal.

• ICAO’s governing bodies have questioned whether there was a mechanism for ICAO to establish greater granularity and have been advised that this would be an issue for the Sub-committee to consider.

www.hazmatsafety.com Classification should be based on inherent risk

• New, “safer” technologies and chemistries being developed • American Engineer Invents A Battery That Cannot Explode https://www.androidheadlines.com/2017/02/american-engineer-invents-a-battery-that-cannot-explode.html

• Different form factors or chemistries present different risks.

• Provide incentives for development of “safer” batteries with less stringent regulations?

www.hazmatsafety.com Improved Packaging

www.hazmatsafety.com Enhanced Enforcement and Monitoring

• Safe2Fly

• Enhanced inspector training

• Enhanced authority over foreign shippers and improved coordination with other governments

• China to Hong Kong issue needs to be resolved

www.hazmatsafety.com Containment systems for passenger aircraft

www.hazmatsafety.com Fire Suppression System

Halon system is the second line of defense. • Designed for fires likely to occur • Lithium batteries were not considered in design of system. • Halon system may or may not be effective in controlling PED fires, i.e., the reliability of the system is negatively influenced by PED fires.

Gill Liner only provides minimal protection and if compromised the Halon is not effective.

www.hazmatsafety.com Fire Suppression System

Need a more aggressive program to replace the Gill liner and Halon Fire Suppression 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 and freight compartments of aircraft.

www.hazmatsafety.com Real Life Example—The Problem

• US Part 121 Supplemental Airline Miami Air recently signed contracts to carry two professional sports teams.

• As part of their FAA-accepted, Part 5 Safety Management System (SMS), Miami Air discovered that these new sports teams had been flying with large quantities of spare Lithium batteries.

• This large amount of spares was poorly packaged, thrown loosely into a case and placed in the cargo compartments of the previous operator on every flight, undeclared.

• Like most , the sports teams were unaware of the danger of Lithium batteries!

• Risk assessment: High-unacceptable

www.hazmatsafety.com Real Life Example—A solution

• Miami Air thoroughly examined the problem.

• Telling the teams to not carry these batteries was a problem because the teams depend on having these spare batteries during the games. Additionally, regulations allow for each passenger to bring up to two spare Lithium batteries onboard the cabin.

• Miami Air conducted research on systems that could allow for the safe transport of these batteries.

– They found that the bar is really low in the industry. The current solutions do not fully solve the problem. Most carriers use the “Pizza Delivery Oven-type” bags that contain the fire, but do not deal with the toxic fumes

• Eventually, Miami Air found a manufacturer that created a full fire and fumes containment system for the teams to safely bring these batteries on board as carry on.

www.hazmatsafety.com Bob Richard President Hazmat Safety Consulting LLC

773-540-0837 [email protected] www.hazmatsafety.com

www.hazmatsafety.com Commercial Team WHITE HOUSE COMMISSION ON AVIATION SAFETY AND THE NATIONAL REVIEW COMMISSION (NCARC)

1.1 . . . Reduce Fatal Accident Rate . . .

•. . . Strategic Plan to Improve Safety . . . •. . . Improve Safety Worldwide . . . CAST BRINGS TOGETHER KEY STAKEHOLDERS TO COOPERATIVELY DEVELOP AND IMPLEMENT A PRIORITIZED SAFETY AGENDA.

Industry Government A4A DOD AIA FAA NASA ALPA ICAO** ACI–NA CAPA TCCA IATA** Safety Team NATCA NACA NTSB** Boeing EASA** GE* RAA FSF * Representing P&W and RR ** Observer CAST GOAL

 CAST came together in 1997 to form an unprecedented industry-Government partnership.  Voluntary commitments, data-driven risk management, implementation-focused.  Goal: Original Reduce the US commercial aviation fatal accident rate 80% by 2007. New Reduce the U.S. commercial aviation fatality risk by at least 50% from 2010 to 2025. CAST SAFETY STRATEGY

Data Implement Safety Analysis Enhancements (SE) – United States

Set Safety Priorities Agree on problems and interventions Influence SEs – Achieve consensus on Worldwide priorities

Integrate into existing work and distribute RESOURCE COST VS. RISK REDUCTION

100% 10000 Risk Reduction APPROVED PLAN 9000 $ Total Cost in $ (Millions) 8000 75% 7000

6000

50% $ 5000 2007 2020 4000

3000

25% Resource Cost ($ Millions) ($ Cost Resource 2000

Risk Eliminated by Safety Enhancements Safety by Eliminated Risk 1000 $ $ $ 0% 0 Dollars/Flight Cycle 100 20 40 60 80 0 Part 121 Aviation Cost DuetoFatal/Hull IndustryLoss Accidents accidents accidents cycleper flight Historical cost of 2007 C OST S AVINGS ~ $852 Million $852 Million ~ Dollars/Year Savings Cycle $71/Flight Savings ~ 2020 CAST plan @2020plan CASTlevels the of implementation following fatalities accident of Cost o r STUDY PRIORITIZATIONStudy Prioritization (FLEET RISK) (Fleet Risk)

30

25 Risk Level Appropriate for Monitoring

1 accident in 20 yrs 20 Risk Level Appropriate for Study

15 RR SEs Risk Levels

10

5

Yrs Yrs to 1 or accidents more expected Fatality Accident Expectation @ Current Accident Rate Years to Years 1 to More or Accidents Expected 0 1% 10% 100% FatalityFatality Risk Risk - (Severity)(Severity) CAST – SAFETY ENHANCEMENTS

Underway (R&D), 11

Underway, 25

Completed, Completed 76 (R&D), 10 SAFETY PORTFOLIO MONITORING

Lead SE Title Output Due Date Organization

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 Excursions Output 1 FAA ATO 6/30/2017 SE 219 RE - Air Traffic Operations - Policies, Procedures, and Training to Prevent Runway Excursions Output 2 FAA ATO 6/30/2017 SE 227 TOMC - Air Carrier Procedures for Takeoff Configuration Output 1 A4A 4/30/2017 SE 227 TOMC - Air Carrier Procedures for Takeoff Configuration Output 3 FAA AFS–200 8/1/2017 SE 227 TOMC - Air Carrier Procedures for Takeoff Configuration Output 4 AIA 4/30/2017 SE 228 TOMC - Airplane Design Features to Facilitate Proper Takeoff Configuration Output 1 AIA 10/31/2017 SE 229 TOMC - Takeoff Configuration Warning System Maintenance and Operational Assurance Output 1 AIA 10/31/2017 FATALITY RISK (EQUIVALENT FULL PLANELOADS) CAST PORTFOLIO ASSESSMENT – CARGO OPERATIONS Implementation & Effectiveness

 Fatal accidents review (6):  Four accidents with common causal factors with passenger operations  Two accidents with causal factors specific to all Cargo cargo operations Operations  Distinctions between cargo and passenger operations: Accident Mitigations  Operating environment Review Underway  Logistics/support infrastructure  Key Government and industry initiatives underway:  Cargo Focus Team Portfolio Assessment  Loadmaster Certification Working Group  Cargo Ops Spec development  AC 120–85A being revised CAST Deployed SEs Applicable to Cargo Accidents

Air Tahoma USA Jet FedEx UPS National Air UPS Safety Enhancement 08/13/2004 07/06/2008 03/23/2009 09/03/2010 04/29/2013 08/14/2013 FUEL CFIT ARC F–NI RAMP CFIT 2. CFIT SOPs - One Project   3. CFIT PAI-Vertical Angles (PAI 1-7, 11)  10. CFIT Proactive Safety Programs (FOQA + ASAP)   11. CFIT CRM Training    12. CFIT Prevention Training - One Project  14. ALAR Policies (Safety Culture)-CEO and DOS more visible (1-2)  15. ALAR Policies (Safety Culture)-Safety info into manuals (3)  23. ALAR Flight Crew Training - One Project  26. LOC Policies and Procedures - SOP - One Project   27. LOC Policies and Procedures - Risk Assessment and Management - One Project

29. LOC Policies and Procedures - Policies - Flight Crew Proficiency Program (2)  30. LOC Training - Human Factors and Automation - One Project

85. Vertical Situation Display

120. TAWS Improvements (GPS) 121. Cargo Loading Training and SOPs  131. Cargo Safety Culture

Applicable  = Implemented Applicable CAST SEs Not in Effect at Time of Accidents

Air Tahoma USA Jet FedEx UPS National Air UPS Safety Enhancement 08/13/2004 07/06/2008 03/23/2009 09/03/2010 04/29/2013 08/14/2013 FUEL CFIT ARC F–NI RAMP 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 JIMDAT CARGO SUBGROUP

CAST SE portfolio is effective in reducing risk in cargo operations.

 JIMDAT portfolio assessment indicates a lower level of effectiveness when compared to passenger operations.

 Continue subgroup activity to quantify differences in the cargo operating environment that may characterize a different risk signature the SEs may not be as effective in mitigating. CARGO AND PASSENGER OPERATIONS

 Conventional wisdom: same aircraft, same , runways, taxiways, airspace, etc.  What is the same for pilots:  Part 121 experience requirements.  Part 121 training requirements.  Beyond that, some risk attributes may not be so intuitive. AIRCRAFT DEMOGRAPHICS

 Age  Aircraft technology generation  In production vs. out of production  Wide-body vs. narrow-body:  A landing on an 8,000 ft. x 150 ft. runway looks different than a .  Weights:  Are cargo aircraft operated closer to MAX T/O & LDG weights? 21 PILOT DEMOGRAPHICS

 Is there different risk associated with pilot experience vs. operation when a new hire with no wide-body or international experience is a pilot for a cargo operator?  Career progression  Right to wide-body international  High turnover

22 SYSTEM FORM DIFFERENCES

 Hub and Spoke System (sort facilities make the network work)  Freight moves at night  What is the day-night ratio of flying (~60% for cargo)?  How does the risk change with reduced—  Air traffic services (radar update, HF, etc.)?  Tower operations (non-tower ops, pilot controlled lighting)?  Aircraft Rescue and Fire Fighting (requirements not based on cargo aircraft)? ETOPS OXYGEN REQUIREMENTS

 Extended-range Twin-engine Operational Performance Standards (ETOPS) requirements are based on diversion time for the most time-limiting system (usually fire suppression).  Is the oxygen supply requirement for onboard persons matched against this fire suppression time?  How is this requirement defined? REGULATORY DIFFERENCES

 Aircraft Rescue and Fire Fighting (ARFF):  Based on largest passenger aircraft (by aircraft length and frequency).  Cargo aircraft often are the largest aircraft operating to/from an .  Flight/Duty/Rest requirements:  How do the operational environments differ?  How is risk is characterized and mitigated?

25 SUMMARY

 We welcome participation on the JIMDAT Cargo Subgroup.  Need to ensure JIMDAT understands the differences in the cargo operating environment that may characterize a different risk signature the SEs may not be as effective in mitigating.  CAST SE portfolio is available to you on the USB stick.  Please reach out to us if you have questions or thoughts.

Air Cargo: Federal Aviation Administration Part 135 Operations

Presented to: Cargo Safety Symposium By: Patricia Williams Deputy Division Manager AFS-301A

Date: August 17, 2017 Overview • Reasons to evaluate part 135 weight & balance programs

• Part 135 findings & risks

• Timelines for evaluating part 135 weight & balance programs

Federal Aviation 2 Administration 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 Administration 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 Administration 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 Administration Part 135 Operators

• 177 (10 or more)-SAS Peer Group B • 533 (9 or less)- SAS Peer Group C • 483 (9 or less Single Pilot Operator) SAS Peer Group D • 58 Large 135 • 30 Cargo Only • 44

Federal Aviation 6 Administration Federal Aviation Administration

Foreign Air Carrier Update

Presented to: Cargo Symposium By: Darcy D Reed Manager International Operations Branch Date: August 17, 2017 Quick Overview

 Current 129 Operations

 129 Oversight functions

 Non Compliance

 CAA Outreach

 ICAO

Cargo Symposium Federal Aviation 2 August 17, 2017 Administration Current Technical Authorizations

There are approximately 400 14 CFR part 129 air carrier’s conduction operations into and out of the U.S. NAS.

Of these 400 operators 23 conduct cargo operations. 129 operators account for 45% of the international flights into and out of the U.S. NAS on a daily basis.

Cargo Symposium Federal Aviation 3 August 17, 2017 Administration 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 Federal Aviation 4 August 17, 2017 Administration Non Compliance Operator • letter or enforcement process.

Civil Aviation Authority • Informal communication or formal notification. • Processed through the U.S. State Department

Heighten Surveillance List • Two foreign (Cargo) air carriers are currently on the list for increased surveillance.

Cargo Symposium Federal Aviation 5 August 17, 2017 Administration 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 Federal Aviation 6 August 17, 2017 Administration 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 Federal Aviation 7 August 17, 2017 Administration Annex 6, Part 1, Appendix 2

Annex 6, Part 1, Appendix 2 requires the Ops Manual to have instructions for:

2.1.9 Ground handling arrangements and procedures. 2.1.14 Instructions for mass and balance control. 2.2.1 Certification limitations and operating limitations. 2.2.6 Instructions and data for mass and balance calculations. 2.2.7 Instructions for aircraft loading and securing of load.

These standards are approved by the State of the Operator

Cargo Symposium Federal Aviation 8 August 17, 2017 Administration Thank you

Cargo Symposium Federal Aviation 9 August 17, 2017 Administration Federal Aviation Cargo Administration Certification Process

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

Federal Aviation 2 Administration Review – Operating Limitations

14 CFR 21.41: Type certificate includes operating limitations

14 CFR 25.1581: Airplane Flight Manual (AFM) must contain: (1) Information required by Secs. 25.1583 through 25.1587. Type Certificate § 21.41 (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 Aircraft Flight Secs. 25.1583 through 25.1587, that is appropriate to the airplane, Manual (AFM) must be furnished, verified, and approved

Operating 14 CFR 25.1583: Operating limitations Limitations (c) Airplane Flight Manual or separate weight and balance § 25.1581, control and loading document that is incorporated by § 25.1583 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 Administration 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

Federal Aviation 4 Administration 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

Federal Aviation 5 Administration 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 Administration 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 Administration FAA records for U.S. Part 121 carriers since 2000 show:

Aircraft types Total Passenger ( 94% ) Freighter ( 6 %)

Number of hull loss 46 ( 100 %) 20 ( 44 % ) 26 ( 56 %) and/or fatal accidents

● 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 Administration Federal Aviation 9 Administration 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 Administration 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 Administration 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

Federal Aviation 12 Administration 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

Federal Aviation 13 Administration AC 120-85A, Air Cargo Operations

• Provides guidance on cargo operations and related modifications – Appendix E • Structural data for passenger- to-cargo conversion project – Appendix F • Passenger-to-cargo conversions supplemental type certificate data package for systems and equipment – Appendix G • Design criteria for outward opening doors

Federal Aviation 14 Administration 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

Federal Aviation 15 Administration 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 Administration Structural Assessment

• The retention of cargo to the airplane is like the strength of a chain.

Having one

strong link does Wing not increase the Fuselage strength of the Floor chain CLS fitting Pallet Net or Strap Cargo

Federal Aviation 17 Administration 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 Administration 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 Administration Structural Assessment

Location of seat track used by National Flight 102 Not permitted by Boeing WBM

Location of MRAP #4 MATV #5 the permitted straps found

Source: NTSB National Accident docket Structures Report attachment #2

Federal Aviation 20 Administration 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

Federal Aviation 21 Administration 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 Administration 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 Administration CERTIFICATION PROCESS LESSONS LEARNED

Presented to: Air Cargo Safety Symposium August 17, 2017 Discussion Points • Background • Issues Found by the Cargo Focus Team (CFT) • Progress made by Industry, Manufactures, and the FAA to Resolve Issues • Legacy Aircraft Issues Needing Resolution • Best Practices Going Forward • Closing

Background

After the National Air Cargo Crash in 2013 , 747 industry operators, Boeing, and the FAA met to discuss safer methods for cargo restraint with a focus on heavy military vehicles, but with an additional conversation regarding other types of large and special cargo that was being carried by industry. As a result of issues found during this meeting all in attendance agreed that additional review of current procedures were required and to best method to accomplish this was for industry, type certificate (TC)/supplemental type certificate holders (STC), and the FAA all work together to accomplish reviews and any required changes to operator procedures and Weight and Balance Manual issues. Additionally the FAA formed the Cargo Focus Team to assist with review of operators manuals, review and revise FAA guidance as needed and assist Certificate Management Teams to ensure that training and oversight complied with the aircraft limitations and FAA guidance Issues Found by the Cargo Focus Team (CFT)

During initial reviews, particularly of the Boeing 747 operators many issues were found that were being used by industry and were not contained in the Boeing 747 Weight and Balance and Loading Control Manual. Some of these items were:

• Straps to pallets • Carriage of Code B-Mil (463L) Pallets • Pallet Couplers • Cargo Tied Down Straps Used in Unapproved Locations • Simplified Strap Tie Down Strength Calculations • Side Loaded Carriage of Intermodal Containers • Aircraft Engine Transport

Progress made by Industry, Manufactures, and the FAA to Resolve Issues Working together 747 operators, Boeing, and the FAA were able to starting in 2015 create the Boeing Supplemental Procedures Manual as well as revise the Weight and Balance and Loading Control Manual to either incorporate industry needed changes or to clarify limitations for a better understanding of the limitation. These documents produced by Boeing with FAA approval has resolved and clarified almost all issues that were initially identified. Additionally the Supplemental Procedures Manual was written to include all Boeing 747F aircraft, Boeing 777F aircraft, and the -300F aircraft. Some of the resolved issues in these changes include:

Progress made by Industry, Manufactures, and the FAA to Resolve Issues In the Boeing Supplemental Procedures Manual these items were addressed: • Use of Restraint Straps as Primary Restraint to a Pallet • Carriage of Size Code B-MIL (463L) Pallets • Carriage • Pallet Coupler Devices • Aircraft Engine Transport • Expanded CG Versus Reduced Weight ULD Work continues for several other items of concerns that may be added to this document, however the items addressed to this date have been very significant and have allowed the operators of these aircraft to adequately address FAA concerns and continue to operate while largely maintaining many of the past procedures that were being used. The Boeing Sample Weight and Balance Manual has additionally addressed both operator and FAA concerns and several revisions of this document have addressed issues that I will not go into detail on due to lack of time, but they also have been significant and have been able to be incorporated because of co-operation, and the desire to work together of all parties. Work also continues with this manual and like the Supplemental Procedures Manual the continued cooperation of all parties is vital to ensure the best product is produced as a final document.

Other Aircraft Addressed

Other aircraft types have also had some issues addressed. Most of these address straps to pallets such as IAI Bedek, and Aeronautical Engineers. These STC holders are continuing with additional projects that will hopefully in the near future be able be FAA approved and implemented into their prospective manuals. Legacy Aircraft Issues Needing Resolution Older, out of production or those models no longer being converted are now the largest issue remaining for aircraft currently under review. These concern several aircraft types but for this discussion I will only include the Douglas DC-9 and the aircraft. While it is important to understand that in many cases the operators, manufacturer, and the FAA have been able to resolve some issues many significant issues remain. Examples of some of these issues will be discussed in the following slides Legacy Aircraft Issues Needing Resolution DC-9 aircraft: • Differences in manuals indicating different allowed procedures. • Cargo tie down information that is not complete. • Approved Pallet designations that differ between manuals • Typos and inconsistencies in manuals.

Cargo tie down information Tie Down for the DC-9 series aircraft provides the following information:

This is an example of the Brownline Fitting required:

There is no other data in this manual instructing an operator on how this device is used to restrain the cargo. The concern is that based on these instructions an operator could apply a strap or rope per the manuals instructions and assume that each strap fitting regardless of direction, strap angle, or strap strength has 5,000 pounds of restraint in all directions. This is of course in error and even without a correction to this Weight and Balance Manual, operators should change their manuals to provide accurate procedures for restraint to the floors using straps.

Other examples including differences in pallets, procedural differences between manuals, and other typos are not as significant.

One additional point for the DC-9 manual: Recently the Boeing Company released a revision to the manual clarifying the requirement for compressable cargo. In some manuals the requirement was listed as 8,900 lbs., not the 89 inches that others specified and is the actual requirement. This was an item identified during review by the CFT and AIR and has now been corrected. 727 Aircraft Converted by STC Some 727 aircraft converted by various STCs have missing or incomplete documentation as will be presented in the following slides. These documents have been in existence for a considerable period of time and currently the FAA is working with operators for resolution as in many cases the STC the aircraft was converted under has been surrendered and as such it is not possible to correct or create an FAA approved Weight and Balance Manual. Complicating this is a number of associated STCs that were accomplished that do not adequately address changes required to the Weight and Balance Manual. Cargo Loading One (or more) STC’s provide a document called “Cargo Loading in B-727” (Or a similar title). This document is not an FAA approved Weight and Balance Manual and although it is listed in the Master Data List (MDL) of the STC was not submitted as the weight and balance manual or the aircraft loading manual to the FAA for approval during modification during the STC. There are numerous errors in this document and it should not be used for loading of the aircraft. Such errors exist as a bulk loading statement that provides: “Bulk loading of cargo such as cartons, boxes, and crates shall be loaded in such a manner that the tie down straps and ropes may be used over the top of the cargo to restrain movement sideways, upward, fore, and aft.” The use of straps only over the top of the cargo does not ensure movement of forward, aft, and sideways as given in this manual. Additionally this manual does not provide a limitation for the distance that straps may be applied to the floor which may result in overloading the structure. Again this is not an FAA approved manual and a review of several aircraft that have additional supplemental STC’s installed do not in any case supersede the information provided in this document. Closing

Why does this matter? My manuals have already for the most part been corrected, or no issues have been found.

This does matter, not only for cargo operators and cargo, but for all matters, particularly those that are limitations set forth by certification during the aircraft TC or STC process. This issue should teach operators, manufactures, and the FAA that continued dialogue between each other as an industry as well as individual operators is extremely important so we all understand what new procedures, operations, and for the cargo industry what types of products we carry. The lesson learned is had we all spoken to each other and developed approved processes when we desired to implement them we in all likelihood would have saved lives, aircraft, time, and would have not had to put all of ourselves through a time consuming and costly review and recovery that we have done over the last few years. There are many events by industry groups, manufactures, and the FAA that provide for the format to discuss these items and my hope is that from this we have all learned that the best practice moving forward is proactive and ensuring we address needed changes to any limitation ahead of incorporating the change so that we operate at a higher level of safety and more efficiently than any other operators in the world.