Curiosity Quest: The FAA Cargo Focus Team

By Scott Spangler on October 24th, 2016

Image result for air cargo

To keep up with the FAA, I subscribe to the news feeds for most of its branches. The other day, the Flight Standards Service (AFS) sent me notice of a draft policy document, and its subject, updated air cargo definitions and abbreviations caught my attention. In aviation, abbreviations and acronyms seem to breed exponentially,  so keeping up is worth my time. I found a subject way more interesting than I expected.

The changed definition and abbreviations support the air safety initiative on air cargo operations under Part 91K. 121. 125. 135. and Letter of Deviation Authority (LODA). Addressing the background before introducing the changes, the notices said, “ The FAA’s Cargo Focus Team (CFT), created following an aircraft accident in Bagram, Afghanistan, determined that OpSpecs A196, Air Cargo Operations, and A396, Special Cargo Operations, provide the best process for management of cargo operations.”

Image result for air cargoWhat, I wondered, is the Cargo Focus Team? A search of the FAA website revealed no page dedicated to the CFT. The closest I got was a list of responsibilities of AFS-330, the FAA’s Air Carrier Maintenance Branch. The CFT was well down on the long list that included corrosion prevention and control programs; oversight of safety and education plans about aging aircraft; and developing and standardizing regs and national guidance on maintenance for Part 91K, 119, 121, 125, 135, and 136.

With that lead unsatisfying my curiosity, I started over with the accident, mentioned in the note, that led to the accident at Bagram Air Base. In the grand scheme of aviation excitement, air cargo may often seem mundane, except maybe when a Boeing 747-400 freighter is loaded with five mine-resistant ambush-protected (MRAP) vehicles that, all together, weigh 78 tons and the aft-most 12-ton MRAP ATV breaks free of its tie downs on takeoff and damages the hydraulic systems that control the 747’s horizontal stabilizers.

Certainly you remember the video of the freighter’s last flight on April 29, 2013. Aviation is one of the world’s most thoroughly regulated industries, at least I thought it was when I started reading the NTSB Accident Report on the cargo plane’s final flight.

Image result for unit load deviceGiven their size, the MRAPs do not fit it a Unit Load Device (ULD), the trapezoidal boxes that make the most of the fuselage’s interior space. They are filled with small packages, or other cargo that fits within them, and the aircraft’s main deck handling system holds them securely in place.

To get the three 18-ton Cougars (pictured below on its double pallet) and two 12-ton M-ATVs on the plane, they loaded each of them on a floating pallet and strapped them down on the cargo deck centerline. On takeoff, the aft M-ATV broke free of its restraints and floated aft on its pallet.

imageIn going through the probable causes, the NTSB noted that the airline’s cargo operations manual omitted required, safety-critical information from Boeing and the manufacturer of the STC’d main deck cargo handling system. It also “contained incorrect and unsafe methods for restraining cargo that cannot be contained in ULDs. The procedures did not correctly specify which components in the cargo system (such as available seat tracks) were available for use as tie-down attach points, did not define individual tie-down allowable loads, and did not describe the effect of measured strap angle on the capability of the attach fittings.”

Turning to the FAA, the report said its guidance at the time, Advisory Circular 120-85, “that conflicts with the safety requirements for using procedures based only on airplane manufacturer, STC-holder, or other FAA-approved data.”

Given the role weight and balance plays in the safety of any flight, let alone cargo airplanes, this is the part that surprised me: “Cargo handling personnel are not FAA-certificated; thus, there are no standardized procedures, training, and duty hour limitations and rest requirements for personnel who perform the safety-critical functions of loading and securing cargo.”

Image result for weight and balanceIn addition to the previously mentioned inadequacies, the flight’s loadmaster had been on duty for 21 hours at the time of the accident. Another interesting bit of information later in the report is that oversight of the loadmaster responsibilities  was found in the crack between the FAA’s principal operation and principal maintenance inspectors. “The FAA stated that both operations and airworthiness inspectors, who possess various degrees and types of expertise and experience, had oversight responsibility.”

And it’s not just loadmasters who suffer from a lack of training. FAA inspectors who oversee air cargo operations are right there with them, the report said. “After the accident, the FAA initiated extensive and ongoing action, including improving inspector training, developing inspector job aids, and establishing a permanent cargo focus team to provide inspectors with direct technical validation of operator cargo procedures, documents, and support for technical decisions related to cargo.”

The FAA created its Cargo Focus Team in June 2013, about two months after the accident. In August 2013 it issued SAFO 13008 that recommends tie-down procedures for special cargo loads. And it “developed a strategic action plan to address certification, operations, and airworthiness issues with the intent of providing clearer, more precise guidance on cargo loading procedures; offering operators improved practices and safer procedures to aid in their decision-making processes concerning cargo operations; and enhancing coordination and outreach efforts with internal and external stakeholders to establish safer cargo operations.”

Image result for air cargoThe CFT issued the updated AC 120-85A, Air Cargo Operations, on June 25, 2015. The page count is a good indication of the additional detail on this version; it is 97 pages, 33 more than its predecessor.

And the revision of the definitions and abbreviations in the related operational and military specs and LOA A002, are, it turns out, another step in this continuing air cargo effort. If you are curious about them, “the following three air cargo-related definitions are added to A002:”

(1) Bulk Cargo. Cargo usually transported as individual pieces and loaded into a compartment certified for bulk cargo. These items are generally loaded planeside and loaded directly into the bulk compartment.

(2) Certified Unit Load Device (ULD) Cargo. Cargo loaded into a ULD, as defined by National Aerospace Standard (NAS) 3610, SAE Aerospace Standard (AS) 36100, Technical Standard Order (TSO)-C90, or other certification standards as specified in the type design or supplemental type design weight and balance manual.

(3) Special Cargo. Cargo not contained in a certified ULD approved for the airplane Cargo Loading System (CLS) or enclosed in a cargo compartment certified for bulk loading. Special cargo requires special handling and securing/restraining procedures. –Scott M. Spangler, Editor

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