BOB ROGERS

VICE PRESIDENT ULD CARE

What will it take to “do” ULD properly

The very beginning…

Original Lockheed photo, courtesy of

Martin Bleasdale/freighterdata.aero

collection

Evolution of Cargo loading

Evolution of aircraft

Evolution of aircraft holds

What do we mean by safety? The placing and securing of air cargo in the aircraft in a defined manner that protects the aircraft and its systems during flight

Which requires.. • Understanding “What

the aircraft expects”

• Complying with the aircraft Weight and Balance Manual

• Recognizing that the aircraft has limitations

What can possibly go

wrong?

You can’t manage it unless you can measure it

Fine Air Flt 101 National Flt 102

Locks Not Raised Nets Not Secure Incorrect Loading Position Incorrect Weights of Cargo / baggage ULDs badly built Load sheet errors

Accidents … 2

Serious Incidents… ~ 1 per week Aircraft Tip Aircraft Tail Scrape Load shifts Significant Loadsheet Error

Daily Operations… ~ 16 per day*

Data from IATA STEADES Database

So what goes wrong? A random data sample of 1088 reports

was broken down into 3 categories of aircraft loading issues:

Unsecured Loads: The loads were not secured due to OPS handling, procedures not followed, or faulty equipment.

Load Sheet: Errors in the load sheet for departure due to load sheet preparation procedures not being followed.

Weight / Balance: Undesired change in weight / balance due to documentation errors.

Data from IATA STEADES Database

What’s moving?

Data from IATA STEADES Database

When are the issues being

identified?

Found: Errors identified and rectified before the aircraft is pushed back.

Escapes: Errors that are found after pushback, mainly on arrival by unloading staff.

Data from IATA STEADES Database

Why…

Data from IATA STEADES Database

Data from

the IATA

Ground

Damage

Database

( GDDB)

Data from IATA GDDB Database

ULD ranked #2

Data from IATA GDDB Database

What do the regulators say?

• Fine Air Accident Investigation Report

• 21.The loaders who loaded the accident airplane were not aware of the

potentially catastrophic consequences of misloading the airplane and

failing to properly secure cargo, and this contributed to the accident.

• 22.Formal training is necessary to ensure that cargo handling personnel

receive standardized instruction on safety-critical aspects of the loading

process.

FAA actions.. • AC 120-85, detailed

guidance into cargo operations

• Applies to US carriers and all carriers landing in the US

• Cargo Focus team

• Increasing oversight of cargo operations.

• National Air Cargo

– A repeat of Fine Air

– Tribal knowledge being used instead of following the WBM

– A significant number of common practices are not stated in the WBM

• Boeing supplemental procedures to Weight and Balance Control and Loading Manual

• 44 pages long, 5 specific processes, being continuously updated

FAA SAFO’s • Subject: Non-compliance with a Manufacturer’s Federal Aviation

Administration (FAA)-approved Aircraft Weight and Balance Manual (WBM)

• Purpose: This SAFO serves to warn Title 14 of the Code of Federal Regulations (14 CFR) Part 121 Air Carriers of safety concerns and operational compliance issues regarding Weight and Balance Programs

• In some isolated cases, air carriers have developed procedures for

aircraft loading that exceeds the structural design capability of the

aircraft. Exceeding this capability can lead to catastrophic failure of

the aircraft.

• Subject: Cargo Retention Methods Using Pallets Straps

• Purpose: This SAFO serves to warn operators that strapping cargo to a pallet to restrain cargo must be done in accordance with configurations explicitly permitted by the design approval holder’s Federal Aviation Administration (FAA)-approved Weight and Balance Manual (WBM) or WBM supplement

Are you doing ULD properly ? • Staff formally trained in ULD safety

and operations?

• Facilities and equipment?

• Supervision?

• Management support?

What does it take to “do” ULD

properly • Do’s

– Trained staff

– Adequate

infrastructure

– SOP’s for ULD

– Taking responsibility

• Don'ts

– It’s only a “box”

attitude

– It doesn't matter how

we do it as long as we

get if on the plane on

time

• High staff turnover

• Inadequate and unsupportive airport infrastructure

• Airlines responsible for flight safety but lack the ability to exert meaningful control

• Uneven regulatory environment

• Focus on cost not on safety

Pain points…

Start here…

IATA ULD Regulations • Step by step

processes

• A complete

standard for all

ULD operations

and handling

IATA CHM • Step by step processes

• Developed by the IATA

Cargo Handling

Council, equal

representation of

airlines and handlers

IATA ULD Safety Campaign • Its not just a

box..

ULD Explained by ULD CARE

Amended SGHA • ARTICLE 5. STANDARD OF WORK • 5.2 In the case of absence of instructions by the Carrier,

the Handling Company shall follow its own standard

practices and procedures provided they comply with the

applicable IATA industry developed standards including

but not limited to: ….

• … ULD Regulations (ULDR), CSC RP 1681

Why is all this important.. • Air cargo is growing in both size and

complexity…safety cannot be neglected

• Changing demands for air cargo places

additional demands on ULD operations..

• Two major accidents have highlighted the

safety risks associated with air cargo

Temperature Controlled

Containers

FCC and FRC

Collapsible Containers

What will it take to “do” ULD

properly? • Establish more procedures?

• Implement more audits?

• Treat the damage and near misses as “cost/risk of doing business”?

• Pay more for greater safety?

• Use less outsourcing?

Safe for flight?

Suitable conditions for a piece of aircraft equipment?

Does he understand the safety aspect of his job?

Thank You