ULD Regulations Workshop - · PDF file↗Liaise with ICAO, EASA and CAAs ... WCS 2013 ULD workshop / 17 Presented by: Jean-Jacques Machon. ULD manufacturers can:

ULD Regulations Workshop Doha 11 March 2013

Welcome and Introduction

LIAO, Zhi Yong 廖志勇

IATA Cargo

Sponsored by:

ULD Panel and Subgroups

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Un-regulated Un-regulated

Regulated

Today’s ULD Operations

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Next Steps↗ Create ULD Training Task Force↗ Establish IATA ULD standard training programs↗ Integrate ULDR requirements into IOSA/ISAGO/IGOM↗ Liaise with ICAO, EASA and CAAs↗ Cooperate with ISO/SAE↗ Create the ULD control receipt (UCR/LUC) in XML format↗ Promote the use of IATA standard ULD ID Codes↗ Your wish list?

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ULD in the air

An introduction to ULD Regulations workshop

WCS 2013 ULD workshop / 1 Presented by: Jean-Jacques Machon

Accidents caused by ULDs do occurand severe damage to aircraft much more often

Primary concern: restraintThe essential function of all ULDs in the air is: cargo restraint!


Nearly as important: contour

Maintaining the maximum contour throughout flightalso is essential


The too often overlooked reality is :ULDs in flight are part of the aircraft

Aircraft flight safety regulations also apply, as for any other aircraft part, and are defined in: ICAO Annex 6, Operation of aircraftICAO Annex 8, Airworthiness of aircraftand the derived national CAA regulations


Examples of applicable national CAA regulations:

State / Authority

Area concerned

ChinaCAAC

EuropeEASA

JapanJCAB

USAFAA

Aircraft airworthiness CCAR-25 CS-25 Airworthiness Standard Part 3 14 CFR Part 25

ULD design / testsand approval CTSO C90 ETSO C90 JTSO C90 TSO C90

Carrier certification and operations CCAR-121 EU-OPS 1 Civil Aeronautics Act

Chap VI & VII 14 CFR Part 121

Maintenance of approved equipment

CCAR-43CCAR-145

EASA Part MEASA Part 145

Civil Aeronautics Act Art 20

14 CFR Part 4314 CFR Part 145

(technical requirements of regulations in most cases identical)


ULDs specific guidanceAll these are applicable but general regulationsThe only regulatory guidance material specific to ULDs is:

FAA Advisory Circular AC 120-85 of 2005Air cargo operations

developed after a major accident where cargo operations and ULDs were instrumental.

WCS 2013 Regulation track – ULD / 5 Presented by: Jean-Jacques Machon

Excerpts from AC 120-85220. TYPES OF ULDS AND OTHER RESTRAINT DEVICES. a. Certified ULDs. Certified ULDs should meet the requirements of TSO-C90, Cargo Pallets, Nets, and

Containers; STC requirements, if applicable; or other FAA-approved certification requirements. The air carrier should have on file an FAA approval letter, certificate, or other certifying document, such as a conformance certificate provided by the ULD equipment manufacturer, for all of its certified ULDs.

b. Uncertified ULDs. The air carrier should have documentation from the ULD equipment manufacturer stating to which design criteria the ULD is manufactured. These design criteria may be industry standards such as Society of Automotive Engineers (SAE) Aerospace Standard (AS) 1677, General Requirements for Uncertified Cargo/Baggage Containers; International Standards Organization (ISO) publication no. 4118, Non-certified Lower-deck Containers for Air Transport; International Air Transport Association (IATA) ULD Technical Manual (UTM) 50/7; or other FAA-accepted standard.

c. Cargo Nets. Most air carrier weight and balance manuals recognize a TSO cargo pallet/net as a primary restraint for unitized cargo. A cargo net is the only restraint device that conforms to the shape of the cargo while providing restraint in all directions so that the load is spread to the net fittings and pallet edge rails. Deviation from the use of approved cargo pallet/net as a primary restraint may require the cargo to be airplane compartment restrained, if loaded in a compartment certified for compartment restraint, or restrained by cargo straps or other approved devices as provided in the airplane’s weight and balance manual or STC supplemental weight and balance manual. The air carrier manual should have policies and procedures in place to address this issue.

Excerpts from AC 120-85 (contd)221. DETERMINING IF A ULD IS COMPATIBLE WITH THE AIRPLANE IT IS TO BE LOADED ON. It is critical

to the safety of flight for the air carrier to have procedures in place to confirm that each ULD loaded aboard an airplane is compatible with the airplane regardless of whether the air carrier or a vendor of the air carrier owns the ULD. Not all ULDs are FAA-approved as compatible with all airplanes. Therefore, an air carrier should have procedures to:

a. Ensure certified and uncertified ULDs are compatible with the airplane and do not present a hazard to the airplane.

b. Ensure uncertified ULDs meet either UTM 50/7, AS 1677, or ISO 4118, or another FAA-accepted standard.

c. Inform employees and vendors loading airplanes converted from passenger to all-cargo by an STC that it could be subject to ULD requirements that differ from other STC conversions or production airplane configurations in the air carrier fleet.

f. Ensure approved ULD limitations are maintained in the manual. An air carrier should base these limitations on data from applicable airplane weight and balance manuals, STC supplemental weight and balance manuals, or other FAA-approved sources. The limitations should identify which ULDs arecompatible with specific airplanes and should be easily accessible by all affected persons.

223. PURCHASE OF AN UNCERTIFIED ULD. When purchasing new or used uncertified ULDs, the air carrier should:

a. Obtain the manufacturer’s current CMMs and illustrated parts list, subsequent manual revisions, service letters, or SBs.

b. Verify that the manufacturer establishes clearly defined and tested serviceability limits in accordance with IATA, SAE, or ISO standards.

Excerpts from AC 120-85 (contd)227. PROCEDURES FOR MAINTAINING AND REPAIRING ULDs. An air carrier should have procedures for

the maintenance and repair of certified and uncertified ULDs. The procedures should be the same for both types of ULDs, except for establishing appropriate damage limits and specific repair procedures.

230. RETURNING A ULD TO SERVICE. An air carrier should have procedures for repairing unserviceable ULDs and approving them for return to service. As required by part 43, only appropriately trained and FAA-certificated airmen are authorized to return a ULD to service. The airmen should return ULD equipment to service under the requirements of the applicable CMM or air carrier instructions. FAA-approved repair stations operating under 14 CFR part 145 should return ULDs to service in accordance with air carrier procedures.

237. PERFORMING CHECKS BEFORE USING ULDS OR OTHER CARGO RESTRAINT DEVICES. An air carrier should perform an operational check for damage before using ULDs (that is, movement or buildup) and other restraint devices, and a final serviceability check before loading cargo aboard the airplane.

238. PURPOSE OF OPERATIONAL CHECKS. Operational checks are not intended to determine a ULD’sairworthiness. Instead, they are performed to ensure the ULD or other restraint devices do not have obvious damage greater than their damage limits. An air carrier should not use ULDs or other restraint devices with damage greater than damage limits specified.

239. INDIVIDUALS WHO MAY PERFORM OPERATIONAL CHECKS. FAA-certificated airmen do not have to perform operational checks. Air carriers should train, qualify, and authorize personnel to perform serviceability checks. The air carrier procedures should identify who performs these checks and when.

(and much more …)

Four main regulated fields

Aircraft type approval(Type Certificate, Weight & Balance Manual = W&BM)

Airline / carrier approval (Air Operator Certificate = AOC)

ULD design approval (TSO authorization or STC)

Continued airworthiness (inspection, maintenance)


1. Aircraft type approval

Each aircraft is certified (Type Certificate, STC) by one or several authoritiesThis includes approval of its Weight & Balance Manual, that defines what is allowable or not as regards aircraft loadingThe W&BM forms the basis for carriers to develop the required Operating Instructions


2. Carrier approval

Each carrier’s operation is approved and controlled by its CAA under an Air Operator Certificate (AOC)The AOC and regulations require the carrier to maintain appropriate Operating InstructionsThe AOC holds the carrier responsible even when its operations are sub-contracted

WCS 2013 Regulation track – ULD /8 Presented by: Jean-Jacques Machon

3. ULD approval

Certified ULDs design and airworthiness are approved by the CAA under Technical Standard Order (TSO) C90, or more seldom a Supplemental Type Certificate (STC), marked on the unitContrary to frequent misconceptions, «Non-certified»containers also need approval, but indirectly, by meeting requirements of the approved W&BM, under carrier responsibility


4. Continued airworthiness (ICA)The ULD manufacturer must provide an approved Component Maintenance Manual (CMM)The ULD must be inspected prior to loading, and may be loaded only if it is in a condition meeting CMM (ODLN) minimum requirementsIf not, it must be repaired by an authorized agent and re-approved prior to return to service


How does it all fit together ?

WCS 2013 ULD workshop / 11 Presented by: Jean‐Jacques Machon

Who is responsible / liable ?The manufacturer, for demonstrating to the Authority that the ULD meets the applicable requirements, and justifying the contents of the CMM, including damage limitsThe operator/carrier, for … everything else ! Its mandatory Operating Manual and quality control are the keys.


The industry’s problemBut can the operator/carrier do everything ?In today’s world, most ULD activities are performed by other parties: shippers, cargo terminal operators, ground services providers, forwarders, brokers, sales agents, ground transportation providers …All are supposed to work under the carrier’s Operating Instructions, but how many carriers ?


Industry’s solution:a single set of regulationsfor all parties involved conforming to all legally applicable regulations


Who can the ULDR help ?All industry stakeholders:

CarriersAirport cargo & ramp handling organizationsForwarders & cargo agentsShippers & consignees who handle ULDsULD manufacturers & repair agenciesand … the Authorities themselves !

WCS 2013 ULD workshop /15 Presented by: Jean-Jacques Machon

Carriers will be able to:Reduce their Operations Manual to specific data, W&BM derived and other if neededSatisfy sub-contractors training requirements through IATA approved training programsSatisfy their sub-contractors quality control obligations through ULDR compliance checks that can be mutualized


Cargo terminal and ground handlers:Can have a single ULD operating requirements set instead of as many as customer airlines, except for specific data derived from W&BMCan use a single IATA endorsed training and qualification program for all their customersCan improve quality and develop systematic quality control on known bases


ULD manufacturers can:

Refer for design to more precise ULD technical requirements common to all customer airlinesUse industry approved operating conditionsEase Component Maintenance Manual (CMM) development and definition of intended use where legally required

Overall, benefit from better defined liability

WCS 2013 ULD workshop / 18 Presented by: Jean-Jacques Machonn

What’s new in the ULDR ?The ULDR are much more than revamping the former IATA ULD Technical Manual. Additions include :

List of the applicable airworthiness regulationsOperators & others regulatory responsibilitiesTraining requirements for all parties concerned

(contd)


Aircraft limitationsProcedures for repairsRevised ULD general technical requirementsRevised and new Technical SpecificationsOperating Specifications intended to be used by carriers to develop their own Operations Manual, or by handlers who do not have any

Handling guidelines


And what is to come ?

Enhanced 2nd edition will include:

New Technical SpecificationsNew Operating SpecificationsImproved more user friendly layouts

All improvement suggestions are welcome

WCS 2013 Regulation track – ULD / 21 Presented by: Jean-Jacques Machon

Last but not least: trainingTraining is the essential component. To support the ULDR, IATA plans to develop for 2014 :

ULD training programs in modules fitting the various functions and jobs

including « Train the trainer » for instructorsaccreditations / endorsements for training schools

and carriers courses


Some suggested workshop discussionsFeedback on ULDR 1st edition’s sectionsCan ULDR Operating Specifications be directly used for carriers Operations Manuals ?Which additional OS would be priorities ?What about a standard format for aircraft or carrier specific data, e.g. W&BM ?

(contd)


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Is some form of ULD registration needed to keep SS 40/1 Appendix A updated, and how ?Would one-page factsheets for most common ULD types be a help ?What relationship is sought between ULDR and training material ?


Thank you for your patience,and have a safe flight home !


ULD on the Ground- Ensuring Continued Airworthiness

IATA ULD Regulations WorkshopDoha March 11 2013

Part 1-Background for the IATA ULD RegulationsPart 2- Features of the IATA ULD RegulationsPart 3- Applying the IATA ULD Regulations - Ensuring Continued Airworthiness

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Part 1.Background of the IATA ULD Regulations

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ULD and Risk

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Part 2.Features of the IATA ULD Regulations

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Airworthiness & Flight Safety Regulations

Air Operator CertificateAirlines shall comply with civil aviation regulations to ensure safety operations.

Any party involved in ULD operations shall comply with civil aviation regulations.

Bridging the Gap

CAAs The Air Cargo Industry*

* Shipper, Cargo Sales Agent, Freight Forwarder, Ground Transportation Service Provider, Ground Service Provider, Cargo Terminal Operator, Airport, Consignee, ULD OEMs, ULD Repair Station, ULD Pooling/ Leasing Provider, Post Office, CAA, etc.

Airlines ULD Regulations

Force for Change

OUT INTribal KnowledgeMake DoGet ByGood enoughUnpredictability

ClarityDefinitionsReliabilityStandardsRepeatability

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Deliverables

BACK OFFICE BENEFITSULD airworthiness complianceReady made standard for reference in:

Procedures manualsHandling and other contractual agreements

Global training standard and content. ULD Regulations integrated into other IATA documents and processes

ISAGOIGOMIOSA

OPERATIONAL BENEFITSControl of damage/injury to

PersonnelULDAircraftCargo

Enhanced reliability in ULD operationsSeamless asset control

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Section 8-DocumentationOperational documentation (

Transfer of ULD)Documentation supplied with

new ULD and Spare PartsULD Repair station

documentationRequirement for Operating

Instructions to be contained in CMM

Section 9- HandlingGeneralContinuing AirworthinessStorage of ULDTransport and Movement in ULD

Operations areaTransport and Movement of

ULD- On AirportTransport and Movement of

ULD-Off AirportTransfer of ULDBuildup and Breakdown of ULDRequirements for special

purpose ULD

New Material Sections 1-Applicability

Operator’s ResponsibilitiesOther Parties’ ResponsibilitiesTraining Requirements

Section 2-LimitationsBuild up and loading limitationsOther limitations

Section 3-ClassificationCertified ULDNon Certified ULDULD accessories

Section 7-ULD Operating SpecificationsULD acceptance standardsAircraft containers operationULD weighingULD C of G controlULD protection wrapping

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Structure follows IATA Dangerous Goods layoutIATA ULD Regulations

Section 1- ApplicabilitySection 2- LimitationsSection 3- ClassificationSection 4- ULD IdentificationSection 5-Technical specificationsSection 6-ULD Operating specificationsSection 7- ULD MarkingSection 8 – Documentation and Message specificationsSection 9- HandlingSection 10-Technical recommendations

IATA Dangerous Goods RegulationsSection 1- ApplicabilitySection 2- LimitationsSection 3- ClassificationSection 4- IdentificationSection 5-Packing

Section 6-Packaging specifications and performance testsSection 7- Marking and labelingSection 8 – Documentation

Section 9- HandlingSection 10-Radioactive material

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Part 3.Applying the IATA ULD Regulations - Ensuring Continued Airworthiness

1. Training2. Responsibility3. Handling4. Others

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1.6Training

KEY

1. Operating staff employed by such organizations but not directly involved in any ULDhandling;

2. Operating staff involved in ULD handling; 3. Staff employed in a supervisory and/or administrative position; 4. Staff responsible for management of ULD operations; 5. As applicable to the responsibilities of the staff in accordance with 1.6.2.

Notes: 1) Training requirements apply to wholly employed or contracted personnel.

2) The organizations and categories of personnel identified in Table 1.6.A are not all encompassing. Personnel employed by or interacting with the aviation industry in areassuch as General Sales Agent (GSA) and General Sales and Service Agent (GSSA),except when acting in a capacity identified in Table 1.6.A, should be provided with ULD training in accordance with 1.6.2.

3) See hereafter for training levels required and summarized description of contents of the ULD Regulations Sections.

4) A subjects based minimum training syllabus is provided in Table 1.6.B for application.

1.Training

Level Description. Staff category

ULD Awareness Awareness training for persons working around ULD 1, 5

ULD Basic Basic training for persons working with ULD 2

ULD Intermediate Comprehensive training of all operational aspects of ULD 3

ULD Management Complete training of all Regulations 4

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Organizations directly involved in ULD operations

Organizations owning ULD

Organizations indirectly involved in

ULD operations

ULD Regulations sections

Applicability

1) 2) 3)

Operators, Ground Handlers, Freight forwarders, Post Offices, Shippers & consignees,

Ground transportation services providers, etc...

Operators, ULD Leasing / Rental

service providers, ULD Outsourcing service

providers, etc...

Airport Authorities, Customs Authorities,

Aircraft manufacturers, CLS manufacturers,ULD manufacturers, ULD Repair stations,

etc...

See KEY 1 2 3 4 51. Applicability of

ULD Regulations

X X X X X

2..Limitations X X X X

3. Classification X X X X X

4. Identification X X X X5. Technical

Specifications X X

6. Operating Specifications X X X X

7. Marking and labelling X X X

8. Documentation X X X

9. Handling X X X X X

10. Unitization X X

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Operators ( Airlines)

2. ResponsibilitiesOperators

1.4.2 Specific ResponsibilitiesSTATE VARIATIONS: none.OPERATOR VARIATIONS: none.

As specifically regards Unit Load Devices, carriers (operators) responsibilities include ensuring that:(a) all Unit Load Devices to be loaded aboard aircraft are Authority approved or conform to alternate specific rules stated in the aircraft's Weight & Balance Manual;(b)new units are subjected to a First Article Inspection (FAI) prior to being put in service in order to verify their conformity with airworthiness approval and industry

specifications;( c) where a pallet and net are used, they are compatible with each other;(d) each Unit Load Device is inspected prior to and after build-up, and a Unit Load Device in a non-airworthy condition is not loaded aboard an aircraft;(e) all applicable limitations and restrictions are met, including nature of contents, weight and load distribution, maximum allowable damage, and any aircraft specific

rules;(f) any special load items are identified and dealt with in accordance with the Rules. Any dangerous goods shall be accepted and loaded in full compliance with the IATA

Dangerous Goods Regulations;(g) the maximum Unit Load Device centre of gravity offset limits are not exceeded;(h) all items of load are adequately restrained inside / on the Unit Load Device;(i) the applicable Security and Customs control requirements are met;(j) the Unit Load Device is weighed with the required accuracy prior to being loaded on an aircraft, and the weight is transmitted to Load Control in order to be taken into

account in the flight's loading documents;(k) the Unit Load Device tag is signed after closure and weighing by a qualified responsible agent;(l) the Unit Load Device is handled and stored during ground handling and transportation on appropriate equipment and with appropriate methods so that no damage

occurs;(m) the Unit Load Device is loaded on a compatible aircraft position and meets all limitations and restrictions applicable to that position;(n) Unit Load Device repairs are performed by qualified staff in accordance with applicable general civil aviation rules and repair procedures defined through its Authority

approval, and a release certificate is delivered and filed to confirm the unit is airworthy again;(o) all personnel and supervising personnel in charge of any of the above receives appropriate training;

(p) the necessary instructions are provided to all sub-contractors or other parties that either handle, transport or build-up the Unit Load Devices of the carrier (operator);(q) an operational Quality Control system is maintained by the carrier (operator) to monitor the effectiveness of the above, and performs regular audits at the locations concerned.

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Other Parties’ ResponsibilitiesA. Top Level Authorities

Civil Aviation AuthoritiesAirportsCustoms

Responsible for providing an operating environment for ULD that recognizes and supports compliance and best operating

practices for ULD across the entire airline and air cargo industry

563/17/2013

B. Manufacturers and Support ProvidersAircraft/Cargo Loading System ManufacturersUnit Load Devices ManufacturersUnit Load Devices Repair StationsUnit Load Devices Services ProvidersResponsible for providing products and services

for ULD that enable compliance and best operating practices for ULD across the entire

airline and air cargo industry

573/17/2013

C. Participants in Air Cargo Operations Cargo Terminal ProvidersGround Service ProvidersFreight Forwarders/ Customs BrokersCargo Sales AgentsPost officesShippersConsigneesGround Transportation Service Providers

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Operational responsibilitiesFulfill specified operators responsibilities where contracted and required to do so by the operator Meet the training requirements of the ULD RegulationsMeet the ULD storage requirements of the ULD RegulationsProvide access to their operations for audit by operators.Additionally recommended to have ISO 9001 or equivalent

* Do not apply to all functions, see ULD Regulations for specific requirements

593/17/2013

1.4 Responsibilities

Simplified chart of Operator and Other Parties Responsibilities extracted from the IATA ULD Regulations

Operator

Cargo Terminal

Operators

Ground

Handlers

Freight forw

arders / Custom

s Brokers

Cargo Sales Agents

Post Offices

Shippers

Consignees

Ground

Transportation Service Providers

The table below contains a condensed version of IATA ULD Regulations Section 1.4 Operator’s Responsibilities and 1.5 Other Parties’Responsibilities. For the purpose of this presentation the contents is condensed and is for illustration purposes only, refer to the actual publication for the full contents of Operator and Other Parties’ responsibilities. Responsibilities for Civil Aviation Authorities, Aircraft/Cargo Loading Systems Manufacturers, Unit Load Device Manufacturers, Unit Load Devices Repair Station, Unit Load Device Services Providers are not shown for sake of brevity. Airport responsibilities are shown separately.

a All ULD to be loaded aboard aircraft are Authority Approved or conform to the alternate specific rules stated in the aircraft WBM

X

b New units are subject to an FAI before entering service Xc Where a pallet and net are used they are compatible with each

other X X X X

d Each ULD is inspected prior to and after build up and any ULD in non‐ airworthy condition is not loaded aboard an aircraft

X X X X X X

e All applicable limitations and restrictions are met including nature of contents, weight and load distribution, maximum allowable damage and any aircraft specific rules

X X X X X X

f Any special load items are identified and dealt with in accordance with the regulations

X X X X X X

g The maximum ULD centre of gravity offset limits are not exceeded X X X X X Xh All units of load are adequately restrained inside/on the ULD X X X X X Xj The ULD is weighed with the required accuracy before being

loaded on an aircraft and the weight is transmitted to load control.

X X X X X X X

k The ULD tag is signed after closure and weighing by a qualified responsible agent

X X X X X X

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Operator

Cargo Term

inal

Ground

Handlers

Freight forw

arders / Custom

s

Cargo Sales Agents

Post Offices

Shippers

Consignees

Ground

Transportation Service

l The ULD is handled and stored during ground handling and transportation on appropriate equipment and with appropriate methods so that no damage occurs

X X X X X X X X

m The ULD is loaded on a compatible aircraft position and meets all limitations and restrictions applicable to that position

X X

n ULD Repairs are performed by qualified staff in accordance with applicable general civil aviation rules and a release certificate is delivered and filed to confirm the unit is airworthy again

X

o All personnel and supervising personnel in charge of any of the above receives appropriate training

X

p The necessary instructions are provided to all sub‐contractors and any other party that either handle, transport or build‐up the ULD of the carrier( operator)

X

q An operational QC system is maintained by the carrier ( operator) to monitor the effectiveness of the above and performs regular audits at the locations concerned.

X

The Operators instructions received from the carrier are filed, available and updated

X

All personnel and supervising personnel receives training appropriate to the tasks performed.

X X X X X X

Full access is guaranteed to enquiries or audits from the carriers QC dept

X X X X X X

Sufficient and proper ULD storage capacity is available X X X X X X

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3. HandlingPoor handling of ULD will almost certainly lead to damageDamage to ULD will almost certainly lead to non airworthinessA Non airworthy ULD is not acceptable for flight

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Section 9 HandlingContinuing AirworthinessStorageTransport & Movement in ULD Operations AreaTransport and Movement of ULD-On AirportTransport and Movement of ULD-Off AirportTransfer of ULDBuildup and BreakdownRequirements for Special Purpose ULD

Each Section split into:GeneralTraining RequirementsFacilities and EquipmentProcedures and PracticesExceptionsOthers

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4. OthersOEM DocumentationAHM 911 (Appendix C)

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IATA ULD RegulationsComprehensive coverage of all aspects of ULD management and operations in a single manual.Applicable to all air and ground ULD related activityA common design and operating standard for the entire air cargo industryA vehicle for handling new developments

653/17/2013

Global, Industry Wide, Consistent Airworthiness and Operational Serviceability

TRAINING

SPECIFICATIONS

PROCEEDURES

ONLYSERVICEABLE & AIRWORTHY ULD ON THE

AIRCRAFT

IATA

ULD

REG

ULA

TION

S

RESPONSIBILITIES

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Because ULD Hold up Half the Sky !

Thank You

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Documents

ULD Regulations Workshop - · PDF file↗Liaise with ICAO, EASA and CAAs ... WCS 2013 ULD workshop / 17 Presented by: Jean-Jacques Machon. ULD manufacturers can: