ALPA takes its case for One Level of Safety
for
cargo pilots to a very public national forum.
By Jan W. Steenblik, Technical Editor
Air Line Pilot, March 2004, p.18
ALPA members who fly for
all-cargo airlines are bringing their long-sought goal of One Level of Safety
into the spotlight. Thanks in large measure to ALPA’s
participation as a full party member in the National Transportation Safety
Board’s investigations of some recent cargo airline accidents—most notably that
involving Emery World Airlines Flight 17 in
ALPA representatives will
play key roles in presenting issues during the upcoming NTSB Air Cargo Safety
Forum, to be held March 30–31 at the
The Association has been
fighting on many fronts to achieve "One Level of Safety" in the cargo
airline industry—i.e., to bring that industry up to the standards of the
passenger airline industry.
What follows is a summary
of the many issues that ALPA will present during the air cargo safety forum.
Regulatory
issues—operating rules
Unlike passenger
airlines, cargo airlines operate under a variety of regulations. Many cargo
airlines, defined as "supplemental" operations in Federal Aviation
Regulations Part 119 (in general, all-cargo operations or those in which the
departure and arrival times and locations are negotiated with a customer), are
governed by a different set of
For example, FedEx, Ryan,
and Emery World Airlines (now out of business) are/were supplemental carriers.
Northwest is a "flag" carrier, but ASTAR (formerly DHL) falls in the
category of "flag with exemptions." Atlas, on the other hand, is both
a flag and a domestic carrier.
In addition, certain FAR
Part 121 regulations do not apply to cargo airlines. These differences—for
example, differences in flight- and duty-time limits, in requirements to
provide weather information and alternate airports, in operational control, and
in the lack of a requirement to require flight dispatchers—create a smaller
margin of safety for cargo airlines.
Moreover, FAR Part 139
(Airport Certification) permits scheduled cargo flights (often loaded with
hazardous materials, or "hazmat") to fly into and out of airports
with no requirement for airport rescue and firefighting (ARFF) services. The
FAA says
Cargo airplanes can fly
in the same airspace at the same time with passenger airplanes of the same
type, but significant differences remain in the safety equipment they are
required by law to carry.
For example, the FAA
mandated that passenger airliners be equipped with the traffic alert and
collision avoidance system (TCAS II) beginning in 1990, with 100 percent fleet
equipage mandated by 1993. TCAS will not be required on freighters until 2005,
and cargo aircraft weighing less than 33,000 pounds maximum gross takeoff
weight are exempt.
Regulatory
issues—equipment/certification rules
Equipment requirements
for cargo airplanes differ in certain regards from those for passenger
airliners. In addition, many cargo airlines operate older airplanes that were
certified under different, and sometimes less stringent, regulations or methods
than current passenger airliners. These differences result in lower minimum
levels or margins of safety for cargo airlines.
For example, the
The average age of the
freighter fleet is about twice that of the passenger fleet. Some of the
certification standards that applied to the older airplanes have been
superceded. As a result, the older airplanes do not meet the safety standards
set by newer regulations.
These newer, more
stringent requirements include dual locking for rotating joints, split
controls, crashworthiness and flammability standards, component and system
design architecture and reliability, avionics capability, autoflight
capability, and aircraft performance (i.e., different calculation methods are
approved for determining accelerate-stop data for takeoff).
Regulatory issues—FAA
oversight
FAA oversight is one
means to maintain adequate safety in the
The organizational,
logistical, and regulatory characteristics of many cargo airlines compound the
difficulty of the FAA’s providing adequate and effective surveillance and
oversight.
NTSB accident reports
contain numerous references (for both passenger and cargo events) that show
that inadequate FAA oversight is a continuing problem. Recent NTSB reports
citing FAA oversight as a contributing cause include those on the accidents
involving Fine Air Flight 101, ValuJet Flight 592, and Alaska Airlines Flight
261.
The NTSB has issued many
recommendations concerning FAA oversight. A recent study by the General
Accounting Office, the investigative arm of the U.S. Congress, also highlighted
FAA oversight as an issue.
Certain factors make
surveillance of cargo operations more difficult. For one thing, more than half
of all air cargo flights are conducted at night, versus approximately 20
percent for passenger airline flights. These night-oriented operating schedules
compound the logistical difficulties of obtaining adequate FAA oversight of the
Moreover, the widespread
distribution of airports served by cargo airlines, plus the fact that passenger
airlines do not serve many of these airports, further compounds the FAA’s
logistical problems in overseeing cargo airlines. In addition, the fact that a
number of cargo carriers subcontract their loading and maintenance to many different organizations only complicates the FAA’s
oversight of these carriers.
ALPA has seen evidence
that, without FAA intervention, some cargo airlines consistently fail to comply
with the
These data were provided
to the FAA and the NTSB and were compared to the FAA’s Regional Aviation Safety
Inspection Plan (RASIP) reports. Emery pilots also reported most items in the
RASIP, but the RASIP process never captured a large number of additional events
that pilots reported. RASIP reports of U.S.-certificated cargo airlines show
that FAA oversight has failed to prevent maintenance, loading, and flight
operations that do not comply with established procedures and regulations.
Some cargo airline owners
and operators with a history of past and continuing safety problems continue to
operate multiple companies under
Cargo issues
The potential for cargo
to be mishandled and loaded incorrectly on airplanes is greater for all-cargo
airline operations than for passenger airline operations. This is a result of
greater exposure, the heavier weights involved, the various sizes and types of
cargo, and different containers available to the cargo airline.
Misloaded cargo may be heavier or lighter
than thought. Center-of-gravity (CG) calculations for a specific flight may be
incorrect even if the flight crew is given the correct weight of the cargo.
Mishandled cargo can
cause damage to the airframe and aircraft components. This damage may or may
not be visible.
Improperly secured cargo
can result when loaders use inadequate restraint systems, or improper straps or
tie-down devices. Poorly maintained restraint equipment can fail.
ALPA has been involved in
recent efforts to develop an FAA advisory circular (AC) on air cargo operations
that would, among other things, establish standards for specific tolerances and
accuracy of weigh scales. However, to date, no such standards exist.
Another cargo handling
issue is that flightcrew members usually are not able
to observe the loading process. Loading crews frequently have not been trained
to appreciate the effect on aircraft operations of various loading difficulties
or errors. As a result, the likelihood of operationally significant problems
with loading processes, procedures, and events occurring is increased.
Adding to all these
problems is the lack of commonality and standards for forms and procedures
among loading contractors and facilities. In fact, the procedures, training,
and supervision of ground personnel who have the responsibility to handle and
load airplanes has been shown to be inadequate. ALPA
believes this situation is most likely a result of poor training programs, high
rates of staff turnover, and inadequate knowledge of specific aircraft and
company procedures. This situation is particularly worrisome when the ground
personnel are not the airline’s employees and are at an outstation. Moreover,
the FAA has not set duty-time limits for loadmasters.
Hazardous materials
regulations pertaining strictly to classifying, packaging, and labeling hazmat
are adequate. However, operationally related procedures and
practices involving shipment of hazmat pose potential risks.
Undeclared hazmat
continues to be a safety concern. Cargo shipments containing hazmat are not always
presented as hazmat shipments; in those cases, they are carried without proper
procedures and precautions being used. The higher cost to ship declared hazmat
provides an economic incentive for shippers to not properly declare hazmat.
More often it’s the lack of public awareness of what a hazmat item is that
results
in them unknowingly being offered undeclared.
The Research and Special
Programs Administration (RSPA), not the FAA, is responsible for developing
regulations for classifying, packaging, labeling, loading, and segregating
hazmat. However, the FAA is responsible for enforcing the regulations and for
surveillance. This situation can lead to varying interpretations of regulations
and differences in applying them.
The U.S. Postal Service
is responsible for, and has control over, the hazmat it accepts; however, many
sealed mail bags have had undeclared hazmat leak out. In those cases, the cargo
airline is not able to participate in the investigation or to begin the proper
clean-up.
Flight crews still find
that they are not always properly informed of the existence of hazmat on their
aircraft. "Properly informed" here has three vital
components—timeliness of notification, accuracy of notification, and
"compatibility" of the hazmat with other cargo aboard the airplane.
Company materials (COMAT)
containing hazmat continue to be shipped as regular cargo, resulting in the
pilot-in-command not being informed of their presence or their location on the
airplane. Maintenance and stores personnel often need additional training to
prevent this situation from occurring.
Loaders are responsible
for ensuring that the required hazmat shipments are properly loaded to conform
to the accessibility-while-in-flight requirement and any segregation
requirements. Flightcrew members that receive and
sign the notice to the pilot-in-command only acknowledge the receipt of the
document. They do not normally have the opportunity to inspect the hazmat cargo
to determine if has been loaded correctly in an accessible location. There is
no way to verify the accuracy of the notice to the pilot-in-command.
No standards exist for
certified hazmat training programs for flightcrew
members. Current regulations mandate that the training program include a list
of required subject matter but do not require a minimum number of hours of
training. These are left to the individual airline and its FAA flight standards
district office to negotiate. ALPA feels that a greater degree of
standardization in these areas, particularly when subcontractors are involved,
would reduce the potential for errors.
Since
Maintenance issues
Older aircraft issues,
while not unique to the cargo fleet, are more prevalent there, because many
cargo operators buy used airplanes that have already flown for many years as
passenger airliners. Typically, the airplane first flew in the service of a
larger domestic U.S. airline, then moved to a "second tier" passenger
carrier—perhaps outside the United States (and thus beyond FAA
surveillance)—and then finally to a cargo carrier. Such aircraft usually are
less capable in performance, dispatch reliability, and automation.
Older aircraft and their
subsystems typically require more maintenance. Many components of these older
airplanes are no longer being produced and are no longer widely used. This
reduced availability can provide an economic incentive for substandard repairs.
The operator’s decreased
ability to repair or replace failed components results in many
aircraft repeatedly being flown with multiple inoperative equipment items.
Although repairs of inoperative equipment can be deferred legally via the
minimum equipment list (MEL), having multiple items inoperative can have
adverse ramifications for safety.
Another outcome of the
age and ownership history of much of the cargo fleet is that limited
maintenance support is available from the original manufacturer. Many cargo
airplanes undergo numerous modifications through the supplemental type
certificate (STC) process.
Many cargo airplanes in
use are no longer being produced. Some were built by manufacturers that are now
out of business. Therefore expertise and information regarding these aircraft
may not be available to maintenance personnel. Even if the original manufacturer
is still in business, the communication and business ties between current cargo
operators and the manufacturer often are weak. Limited parts availability often
leads to excessive prices and provides an incentive for a market in bogus
parts.
The condition and
configuration of cargo airplanes can differ significantly from when the
airplane was new. In addition, cargo fleets often include a number of
configuration differences among aircraft; this reduced standardization can
increase the possibility of maintenance and operational errors.
STCs can further complicate
maintenance: STC companies often go out of business. The FAA may possess some
relevant technical documentation of the specific STC, but it tends to be
sparse.
Many cargo airlines
outsource both their scheduled and unscheduled maintenance and servicing. This
leads to loss of strong operational control and thorough familiarity with the
fleet among maintenance and service personnel. These personnel also may have
limited experience with specific aircraft models.
Human factors issues
Two human factors issues
are flight and duty time and human physiology.
Flight- and duty-time
limitations for cargo carriers operating as supplemental operations do not
adequately deal with accumulated fatigue—
especially for night operations.
For one thing, no
specific rest period is required for flight crews involved in these operations
when they are scheduled for 8 hours (or less) flying in any 24-hour period.
Moreover, flight-time limitations for these flightcrew
members are based on scheduled flight time—though operational or
maintenance circumstances can extend actual flight time to an unreasonable
extent.
Duty limits are entirely
inadequate for flight crews in supplemental operations—16 hours during any 24
consecutive hours for a two-pilot crew; 18 hours for a flight crew of three;
and 20 hours for four pilots.
Finally, these
regulations neither recognize nor accommodate the effects of flying on
"the back side of the clock." Night operations are prevalent in the
cargo airline industry, and night-oriented fatigue can affect not only flight
crews but also ground crew members (loaders and maintenance personnel).
Night operations result
in lower human performance in general, including an increased risk of making
errors and not detecting or correcting them. NASA research supports the
commonly held belief that sleep during the day is inferior to sleep during the
night.
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