Emirates Endorses Harmonized ULD Regulation Across the IndustryWith revenues of more than $25 billion annually, over 95,000 employees, 155 destinations, 249 wide-bodied aircrafts and 39,000 ULDs, Emirates is one of the premier airlines in the world and a strong supporter of the IATA strategy to ensure safe ULD operations.

Emirates’ team accepted to tell us more about their vision about the necessity to have harmonized ULD handling procedures and regulations across their global network.

“Our priority is to ensure safe aircraft operations, and the same applies to ULD operations,” said Clive Clemson, Vice-President, Emirates Airport Services (Operations), a 28-year veteran at the airline. Mr. Clemson, who is responsible for the delivery of Emirates’ integrated ground operations at Dubai International Airport, explains ULDs are much more than just a container for air cargo. “ULDs are an aircraft’s first line of defense to ensure a safe and balanced load,” he stated. International Regulators agree: ULDs are considered aircraft parts and, as such, are subject to airworthiness requirements.

Still, no civil aviation authority specifically regulates ULDs; they are covered by the general rules governing aircraft ‘parts’ or ‘appliances’ as well as in aircraft weight & balance manuals. The challenge for the industry is two-fold: operators need not only to track a multitude of international and national standards, but also to identify which regulations implicitly apply to ULDs.

To ensure effective ULD management, simplification was needed! This is why IATA developed the first edition of the ULD Regulations (ULDR) manual in 2013. This publication, now in its 4rd edition, consolidates all ULD related regulatory requirements and clarifies responsibilities for stakeholders.

Clive Clemson

“ULDs are an aircraft’s first line of defense to ensure a safe and balanced load”

Safety through compliance“One of the industry’s main challenges is its lack of awareness of the importance of ULDs to the safety of aircraft operations”, explained Manoj Menon, Emirates Network ULD Manager, an airline ground operations professional for the past 23 years, 18 of which have been at Emirates. Incorrectly loaded, unloaded, handled and stored ULDs continue to impose unnecessary risks and costs on the industry. According to Mr. Menon, improper use of a forklift to move a ULD can puncture it, rendering it unable to contain its cargo. Or, not securing a ULD correctly might allow it to shift during flight. Both these scenarios could impact an aircraft’s weight and balance, causing the aircraft to lose control. At a minimum, a damaged ULD must be taken out of service and repaired, leading to unnecessary costs and loss of efficiency.

At Emirates, ULD management strategy revolves around three central pillars:

1. Safety – ULDs are aircraft parts and, as experience has shown, damaged or improperly handled or secured ULDs can cause catastrophic accidents

2. Cost – Handling ULDs in compliance with best practices lowers maintenance/repair costs and increases the life of ULDs

3. Availability – Ensuring ULDs are handled properly leads to fewer damaged ULDs, increasing their availability and return on investment

“Our safety objective, of course, trumps all other considerations. Compliance with the ULDR assists our efforts to ensure safe aircraft operations.” added Mr. Menon.

The Middle East airline has been one of the early adopters of the new ULDR. In 2015, recognizing the simplicity and enhanced safety ULDR could bring to its global cargo operations, Emirates deployed ULDR across its network, by providing a copy of ULDR to each of its stations.

With standardized industry guidelines at hand, it was easier for Emirates to implement consistent policies and procedures across its worldwide network.

Working with partners to improve ULD handlingFlight safety in the air begins with safe ULD operations on the ground. While airlines are ultimately responsible for ensuring safe ULD operations, most of today’s activities are carried out by non-airline parties such as independent ground handling agents (GHAs), cargo terminal operators and freight forwarders. Proper ULD handling is important not just at airports and on aircraft, but also on trucks in transit and at warehouses and terminals.

Emirates is working with its GHAs to raise the profile of ULD handling standards and encourage them to adhere to ULDR. They plan to increase GHA engagement by adapting the Standard Ground Handling Agreement in the IATA Airport Handing Manual (AHM) to include specific GHA operating and training requirements as stipulated in ULDR.

Emirates advocates the need for proper training and pushes for the adoption of the global ULDR standards and procedures by all parties involved in ULD operations, including GHAs, freight forwarders, trucking companies and shippers. “We encourage IATA to further promote the industry-wide adoption of ULDR by replacing ineffective on-the-job training with reliable, comprehensive ULD training made available to local markets”, urged Mr. Menon. In addition, Emirates’ team supports IATA’s efforts to:

1. Make ULDR binding for all IATA Member airlines through the adoption of a Resolution by the Cargo Services Conference (CSC).

2. Include ULDR in the IATA Safety Audit for Ground Operations (ISAGO) Standards Manual.

Emirates is a strong supporter of a global standard for ULD regulations and endorses harmonized, safe ULD handling practices across the industry. The Middle East airline relies on IATA to help them and the industry with its ULDR portfolio (manuals, training, consulting services) and is committed to support IATA in its standardization, simplification and industry engagement activities.

Manoj Menon

“Compliance with the ULDR assists our efforts to ensure safe aircraft operations.

For more information, please contact us at uld@iata.org or visit www.iata.org/uld

ULD Regulations Are you ready to save money?Recognizing the need to simplify ULD management for operators, IATA consulted broadly with the industry to develop a comprehensive set of global standards. The result of this proactive consultative process was the IATA ULD Regulations (ULDR), published in 2013. Now in its 4th edition and conforming to all legally applicable regulations, ULDR provides an effective means of ensuring harmonized regulatory compliance across the worldwide ULD supply chain.

Complying with ULDR could save the industry millionsThere are over 800,000 ULDs in service throughout the world, with a total replacement value of more than $1 billion. IATA has estimated that full implementation of ULDR’s operational procedures and handling guidelines could save the entire aviation industry an additional $300 million per year with an initial investment of only $12 million. The industry could save an additional $300 million and one million tons of CO2 by investing $20 million in lightweight ULDs.

Annual Costs Related to ULD

Annual Savings from Implementing ULDR

Repairs to ULDs $300 million $240 million

Repairs to aircraft holds and cargo loading systems $100 million $75 million

ULDR implementation $12 million* $315 million

Lightweight ULDs** $20 million $300 million in fuel and 1 million tons in CO2

* Estimated training and documentation costs ** The use of lightweight ULDs would eliminate at least 20% of tare weight

IATA’s ULD Regulations manualToday, IATA is the only organization to consolidate all ULD-related regulatory requirements and clarify responsibilities for stakeholders. ULDR includes:

• Common requirements from ICAO and national CAAs as well as Weight & Balance Manual rules applicable to ULD

• Minimum design and manufacturing specifications from such engineering standards groups as the International Organization for Standardization (ISO) and SAE International

• Essential and detailed guidelines for all aspects of ULD handling and operation

• IATA standards such as the ULD Identification Code Format, ULD Operational Damage Limits Notice, and ULD Control Receipt

• Training requirements and standards

• Supporting material for organizations creating their own ULD-related content

A full range of ULDR supportULDR must become part of an organization’s safety culture to be effective. IATA offers the following support for any party involved in the ULD supply chain:

• A three-day classroom or in-company ULDR course that includes a copy of the ULDR manual.

• An entry-level ULD Handling Awareness eLearning course for new or existing staff.

• A number of more general manuals that include the basics on ULD handling: the IATA Airport Handling Manual (AHM), the IATA Ground Operations Manual (IGOM) and the ISAGO Standards Manual. These publications are supported by their own IATA Training programs.

• Support from IATA’s airport consulting group for any member of the ULD supply chain who wishes to implement the requirements of ULDR. Airport Consulting will ensure ULDR becomes an integral part of the organization’s safety culture.

Compliance made affordableThe print and web-download versions of the ULDR manual* are offered at a very low price to encourage wide-spread adoption.

• IATA members benefit from a 30% discount: $298

• IATA Strategic Partners receive a 15% discount: $361

• List price: $425

* A software application on CD-ROM is also available at an extra cost.

For more information, please contact us at uld@iata.org or visit www.iata.org/uld