Wcs2015 ULD Regulations Workshop Presentation

ULD Regulations Workshop
Sponsored by
Welcome & Introduction
Urs Wiesendanger
Manager, Cargo Network Control, Air Canada;
Chairman, IATA ULD Panel
World Cargo Symposium 2015

IATA ULD Regulations
A Means of Compliance
LIAO, Zhi Yong

Manager, Business Process & Standards
IATA Cargo
Agenda
ULDP Governance Structure
What is ULD
Regulatory Framework around ULD
ULD Operations Reality
Purposes of ULD Regulations
FAA Advisory Circular 120-85 Update

CSC STRUCTURE
ULD Governance Structure

Cargo Procedures
CARGO SERVICES CONFERENCE Conferences
Management
(CSC) Group (CPCMG)
Airmail Panel Cargo Business IATA/FIATA

Dangerous Goods Live Animals and ULD Panel
(AMP) Processes Panel Consultative
Board Perishables Board (ULDP)
(CBPP) Council (IFCC)
(DGB) (LAPB)
IATA/FIATA
Customs
Working
Group
Dangerous Time and ULD ULD Cargo Data Cargo XML (IFCWG)
Goods Training Temperature Technical Operational Interchange Task Force
Task Force Task Force Advisory Advisory Task Force (CXMLTF)
(DGTTF) (TTTF) Group Group (CDITF)
(ULDTAG) (ULDOAG)
Cargo Wireless Technology
Advisory Group (CWTAG)
IATA Airlines members only IATA Airlines members and other industry supply chain stakeholders

ULD Panel Membership

What is ULD?

Aircraft Unit Load Devices (ULD)

Special Purpose ULDs/ Accessories

But dont take it for granted!
11
Purposes of ULD
Eliminate loose loading and unloading of aircraft holds
Protect the contents
Maximize the use of aircraft contour
Allow fast and easy transfer from one aircraft to another
Special purposes ULD
The most important purpose is to secure the loads during flight

ULD = Aircraft Part
ULDs are aircraft parts subject to CAAs airworthiness
requirements.
Aircraft flight safety regulations apply and are defined in:
ICAO Annex 6, Operation of Aircraft;
ICAO Annex 8, Airworthiness of Aircraft; and
The derived national CAA regulations

CAA Regulations Applicable to ULD
State / Authority China Europe Japan USA
CAAC EASA JCAB FAA
Area concerned
Aircraft Airworthiness
CCAR-25 CS-25 14 CFR Part 25
airworthiness Standard Part 3
ULD design / tests

CTSO C90 ETSO C90 JTSO C90 TSO C90
and approval
Carrier certification Civil Aeronautics Act

CCAR-121 EU-OPS 1 14 CFR Part 121
and operations Chpt VI & VII
AC 120 85
Operations, Cargo --------- --------- ------
Air Cargo Operations
Maintenance of CCAR-43 EASA Part M Civil Aeronautics Act 14 CFR Part 43

approved equipment CCAR-145 EASA Part 145 Art 20 14 CFR Part 145

Typical ULD Operational Chain
Airline Airline
Shipper Consignee
Origin
Freight Forwarder
ULD Service Provider
Ground Service Provider Ground Service Provider

at Origin at Destination Destination
Freight Forwarder

ULD Operations Reality (1 of 3)


Ground Damage Database Report
250
191
Known GSE
Number of reports
200
142
150
92 95
100
54 64
50 38 33 28 20 14 10 14 13
7 9 7 5 2 3 3
0
2014 International Air Transport Association (IATA). All Rights Reserved. No part of this graph may be reproduced, recast, reformatted or transmitted in any form by any
means, electronic or mechanical, including photocopying, recording or any information storage and retrieval system, without the prior written consent of IATA, Senior Vice
President, Safety and Flight Operations; provided that IATA GDDB Participants may use this graph for their internal business purposes without the necessity of obtaining
such consent.

ULD Area of Damage

ULD Location of Damage

ULD Type

ULD Found vs Reported
Found Reported
44.5% (85) 55.5% (106)


ULD Regulations Industrys Solution
one means of compliance containing a single set of
regulations for all parties involved conforming to all legally
applicable regulations
Airworthiness & Flight Safety Regulations
Airline Compliance Air Cargo Industry Compliance

IATA ULDR as an Application of ICAO Annexes
ICAO Annexes
National Regulations
Aircraft Appliances Operators Maintenance

Certification Certification Certification Certification
Airworthiness Operations Continuing

ICAO Annex 8 Annex 6 airworthiness
Aircraft Appliances Operators Maintenance

Certification Certification Certification Certification
aircraft Weight & TSO* C90** air carrier Part 145

Balance Manual approval AOC repair stations
* or CTSO / JTSO / ETSO, etc.

** other TSOs for accessories: C172 (straps), C203 (FCC), etc.
ICAO Annexes
National regulations
Operational inputs Technical standards

IATA ULDR
Carriers manuals Audit manuals Training programs

Structure Aligns with IATA Dangerous Goods Regulations
IATA ULD Regulations IATA Dangerous Goods Regulations
Section 1- Applicability Section 1- Applicability

Section 2- Limitations Section 2- Limitations
Section 3- Classification Section 3- Classification
Section 4- ULD Identification Section 4- Identification
Section 5-Technical Section 5-Packing
Specifications
Section 6-ULD Operating Section 6-Packaging specifications
Specifications and performance tests
Section 7- ULD Marking Section 7- Marking and labeling
Section 8 Documentation and Section 8 Documentation
Messaging Specifications
Section 9- Handling Section 9- Handling
Section 10-Technical Section 10-Radioactive material
Recommendations
FAA Advisory Circular (AC) 120-85
Cargo Operations Revision Update
Background
The AC was developed in 2005, after an accident involving a
McDonnell Douglas DC-8 aircraft, in response to National
Transportation Safety Board (NTSB) safety recommendations.
In April 2013, a Dubai-bound Boeing 747-400 crashed just after
takeoff from Bagram Air Base, Afghanistan. Following that
accident, the AC was revised after evaluating special cargo
operations, load planning, restraint calculations, restraint
methods, freight staging, freight forwarding, and interlining of
cargo.

Highlights of Changes
It enhances the safety of flight operations by clearly identifying
responsibilities of multiple entities involved in cargo operations
It enhances guidance concerning the operators Weight & Balance
control program and procedures for cargo restraint and aircraft
loading; ULD and restraint devices; and the transport of special loads
It provides clarity regarding cargo handling including ULD training
requirements
It emphasizes that It is critical to safety of flight for the operator to
have procedures confirming that ULDs onboard an aircraft are
compatible with the aircraft and are serviceable regardless of who
owns the ULD., and the operator is ultimately responsible for the
security of the cargo and safety of flight

Highlights of Changes

Publication of FAA AC 120-85A
Public comment period
ended 31 July 2014
Current status: Internal

formal coordination
Anticipate February
2015 release???

Safe ULD operations on the ground
are essential to flight safety in the air!

Thank you!
LIAO, Zhi Yong

Manager, Business Process & Standards
Tel: + 41 (0) 22 770 2637
liaozy@iata.org | www.iata.org
Safe ULD Operations from Chinese
Carriers Perspective
Ruilin Li
Safety Inspector, Air China Cargo; Member, IATA ULD Panel

Safe ULD Operations
from Chinese Carriers Perspective
-- IATA ULD Regulations, an essential tool to facilitate
airline compliance
LI, Ruilin
Safety Inspector, Air China Cargo
Member of IATA ULD Panel
ULD Regulatory Requirements
in P. R. China
Responsibilities and Tasks
The Chinese Civil Aviation Law and Chinese

Civil Aircraft Airworthiness Regulation assign
the CAAC to be responsible for civil aircraft
airworthiness administration in P. R. China.
The aircraft airworthiness is one of the key elements
contribute to the civil aviation safety.
The ULD is definitely an aircraft part.
The airworthiness of ULD is also necessary for the
civil aviation operational safety.
42

The CAAC conducts aircraft airworthiness
administration including Initial Airworthiness
Administration and Continuing Airworthiness
Administration:
The CAAC Aircraft Airworthiness Certification Department is
in charge of Initial Airworthiness Administration, including all
certification, approval and surveillance activities for aircraft,
as well as onboard equipment (including ULDs), type design
and production.
The CAAC Flight Standard Department is in charge of
Continuing Airworthiness Administration, including all
certification, approval and surveillance activities for aircraft
operations and maintenance, as well as onboard equipment
(including ULDs) maintenance and repair.
ULD Initial Airworthiness Administration
Person who designs and manufactures ULDs, or
equips the aircraft with ULDs shall apply for CAAC
approval.
For ULD type design and production, the CAAC certifies the
ULDs and the manufacturer by issuing TSO article
Authorization (CTSOA) per Chinese TSO C90c.
For aircraft ULD installation design, the CAAC certifies the
ULDs installed in aircraft by issuing the aircraft Type
Certificate (TC), Supplement Type Certificate (STC), or
Modification Design Approval (MDA) per Chinese
Airworthiness Standards, such as CCAR25.
The CAAC will oversee ULD CTSOA and relevant
aircraft TC, STC, or MDA holders to ensure all
produced and installed certified ULDs are airworthy
and in safe condition for operations.
When necessary, an Airworthiness Directive (AD) will be
issued to correct existing or potential unsafe condition.
ULD Continuing Airworthiness Administration
Person who operates aircraft where ULDs are
installed or maintain and repair ULDs shall apply
CAAC approval.
For aircraft operations where ULDs are installed/loaded, the
CAAC certifies the Operator (air carrier) by issuing Operation
Certificate and Specification per Chinese Civil Aviation
Regulation, such as CCAR91, CCAR135 and CCAR121 as well
as CCAR129 for foreign airlines.
For ULD maintenance and repair, the CAAC certifies the
maintenance organization or repair station by issuing
Maintenance Organization and Repair Station Certificate per
Chinese Civil Aviation Regulation, such as CCAR43, CCAR145.
Requirements and Operating Specifications
The CAAC will oversee all operators aircraft
where ULDs are loaded as well as maintenance
organization and repair station certificate
holders to ensure their operations or
maintenance and repair activities are following
approved procedures and airworthiness of
aircraft/ULDs are properly maintained.
ULD Operating Specifications
The ULDs shall be maintained and repaired in
accordance with the CAAC approved data.
CAAC guidance, national standards, and industry
standards apply to aircraft ULD operations, such as:
Requirements and Operating Specifications
CAAC Advisor Circular for Air cargo
operations, including baggage, mail and
EIC/Equipment In Compartment.
Aircraft Lower deck containers, pallets, nets
specification and testing (National Standard)
Wide body aircraft main and lower deck
container/pallet loader Functional
requirements (National Standard)
Basic requirements for aircraft loading
equipment (National Standard)
Acceptance standards for the interchange of
transferred ULDs (industry Standard)
Air cargo Handling systems for ULDs
Symbols for pictorial representation.
(Industry standards)
Airworthy ULD Import and Export
New ULDs
Import: the CAAC accepts all imported new ULDs
attached with airworthiness release tag issued by
foreign authority under the condition that the design
of ULDs or its installations are approved or validated
by the CAAC.
Export: the CAAC will issue the airworthiness release
tag for export ULDs stating the ULDs conform with
the design data approved or validated by the
importing state authority.
Used ULDs
The CAAC accepts all ULDs maintained, repaired and
airworthy released by the CAAC Certified
maintenance and repair stations.
Challenges to Safe ULD Operations
/
Loading & Load Control
Staff assembly of load in ULDs and

loading/off-loading of aircraft are Aircraft
Handling Personnel

Loading quality directly affect flight safety

and economic benefits

Laws, Regulations & Technical Standards
747

Loading Instruction NOTOC-notice to captain

ULD is aircraft part to carry cargo, mail and baggage

Subject to airworthiness requirements from design, testing,
production, operations to maintenance
ULD Installation is part of Aircraft Loading
direct impact on flight safety & benefits

Airworthiness check
/Incidents & Accidents
Challenges from Airlines Perspective
Lack of CAAC guidance on ground operations oversight
Lack of regulations, standards and specifications for special
purpose ULDs, e.g. initial certification requirements for
Temperature Controlled Active Containers, ULDs for Live
Animals, oversight on leasing firm & shippers ULDs, etc.
Unclear safety requirements for non-certified ULDs
Insufficient requirements for ULDs Operational Damage
Limits Notice (ODLN) to support continuing airworthiness
administration
Lack of pre-checking A/C loading system and cooperation
between loading supervisor and maintenance engineer
Lack of standards and specifications for ULD operations
and logistics management across the ULD logistic chain
including parties such as shipper, freight forwarder, trucker,
ground service provider, pooling/leasing provider, repair
station, manufacturer, and any organization having
involvement in ULD activities
Solutions & Cooperation
The new IATA ULD Regulations (ULDR) is milestone for
industry standardization management as well as
guidance for safety compliance, training, oversight and
audit!
The ULDR clarifies the regulatory requirements from
CAAs and ICAO Annexes and also aligns with ISO
standards. Harmonization between CAACs ULD
operations administration and IATAs global industry
standards should be maintained.
Lobby CAAC to adopt the international standards
including IATA ULDR into national standards, domestic
industry standards and regulatory requirements.
Lobby CAAC to update various specifications to ensure
alignment with major CAAs such as FAA and EASA.
Suggestions and Comments
Development of new standards/specifications
Heavy and oversized cargo palletizing on ULDs and
aircraft loading are complicated, and require a team of
specialists with palletizing, load control, loading
supervising, aircraft performance, engineers and loader
etc. to pre-plan and evaluate the safety risks. Such
requirement should be established as a standard.
Besides Weight & Balance Manual, Authoritys
certification for operator can be extended to include
Cargo Manual which contains palletizing as well as
management for sub-contractors (ground handling
agent, cargo agent, ground transportation service
provider), shipper and consignee. Training is important
for them, incl. awareness for baggage and EIC handler
and senior management such as CEO of the company.
Non-certified ULDs, e.g. DPE, DQF and FQA, which made
airlines management and CAAs ULD administration
complicated and have risks of operational safety.
Suggestions and Comments
Development of new standards/specifications
The steel cable specification should be created due to
shortcoming of nylon strap for heavy & oversized cargo
securing on/in ULDs and in aircraft.
Its important to unify standards and follow ICAO Annex 9
to simplify procedures. China being the Contracting State,
CAAC shall introduce ICAO SMS (so called ICAO Annex
19) into regulatory requirements like CAAC has done,
industry standards, manuals, etc. such as the Safety
Information Management of CCAR396 by CAAC, UK
CAAs Mandatory Occurrence Reporting (MOR) and
carriers manual.
Through CAAC to urge ICAO operations panel to
establish legislation / standards incorporating the ACs
from FAA and CAAC, the Mandatory Occurrence
Reporting Scheme for Ground Safety Events from the UK
CAA as well as the industry standards and specifications
from NGOs like IATA and ISO.
More and more wide-body aircraft have
been introduced into China, and without
airworthy ULDs, Cargo, baggage, mail and
EIC can not be carried and flight safety will
be at risk. Therefore, the IATA ULD
Regulations is an important tool. Just like
a Chinese proverb says without good
tools, things can not be done well.
Thank you!
COFFEE BREAK

Taking Responsibility for ULD
Operations in the Air Cargo
Environment in China
Bob Rogers
Vice President, Industry Affairs, Nordisk Aviation Products
Facilitator, IATA ULD Operational Advisory Group

Regulated Unregulated
Design and Ramp handling
Manufacture Transport
Minimum Performance Storage
standards Cargo Terminal
Operation Handling
Continuing Buildup
airworthiness
Forwarder
Correct buildup
Handling
Buildup
Fine Air 101 August 1997

Abstract: This report explains the accident
involving Fine Airlines flight 101, a
Douglas DC-8-61, which crashed after
takeoff from runway 27R at Miami
International Airport, Miami, Florida, on
August 7, 1997.
Safety issues in the report include the
effects of improper cargo loading on
airplane performance and handling,
operator oversight of cargo loading and
training of cargo loading personnel, the
loss of critical flight data recorder
information, and FAA surveillance of
cargo carrier operations.

Proper cargo loading is essential for safe flight
operations. The air carrier must have procedures
in place to ensure that employees and vendors are
properly trained in the process, the loading is
properly completed, and that cargo restraints and
loading devices are properly maintained. The
loading personnel, flightcrew, and flight engineer
must all take responsibility to ensure that the
process is completed correctly.
This advisory circular (AC) responds to safety
recommendations made by the National
Transportation Safety Board after an accident in
which basic steps were not followed during the
loading of the accident flight. Adhering to the
recommendations in this AC is one means (but
not the only means) for air carriers to better
manage their air cargo operations

Cargo loading operations and
ULD have always been regulated,
FAA AC 120-85 simply translates
the general language of the FARs
into cargo/ULD specific actions
and requirements
While the rest of the air cargo chain
carries on like nothing happened

Airlines No real
continue to change in
spend $$$ ULD handling
practices
Regulators
Cargo
ratcheting up
operations
their
expanding
expectations
Increased Economic
outsourcing pressures


Published since Jan 2013
Now 3rd Edition
Impact on the industry- mixed !
Some airlines moving to widespread adoption
Others find obstacles
Lack of management support
Lack of industry interest
Turnover in ULD management positions
All of the above

What is meant by regulations?
Airline industry relies on self policing
No IATA sanctions for non compliance
Even breaches of the all powerful DG are not subject to
legal action

SOS ULD requires access to YouTube. Where not available
please contact louise.ladouceur@uldcare.com f or alternatives
1. ULD are an essential component of air cargo
2. ULD are a safety device
3. Value of IATA ULD Regulations
4. Costs- Visible and hidden
5. Impact of sub standard ground ops.
6. Downside of insufficient training
7. Role of the aviation regulations and regulators
8. Conflict between Airlines & Ground based operations
9. Value of consistency -a single weak link can break the safety chain
10. Risks of locally dreamt up practices

1. Airline top management
2. Airline cargo management
3. Airline contracts/purchasing management
4. Airline ground safety management
5. Ground handling company management
6. Cargo terminal management
7. Freight forwarder management
8. Transport provider management
9. Airports
10. Training providers
You !!

Interline Station
Truckers
partners managers
Ground
Handlers
You ! Cargo
Terminals
Industry Forwarders
Airports
bodies

SOS ULD ULD Regulations
A communications tool A comprehensive
to communicate, reference document
inform and motivate for anyone and
the entire industry to everyone in the air
pay more attention to cargo and airline
ULD industry on how to
work with ULD

ULD initiatives in PRC by ULD CARE and IATA
Increased collaboration with PRC bodies CAAC, CAST
etc.
Engagement with trade bodies/associations

PRC has generally large, recently built airports that do
not suffer from lack of space as often found in Europe
and US
PRC airlines are generally young and growing- can more
easily adapt to new practices

PRC Air Cargo industry developed very rapidly, ULD
operations generally just happened
PRC Air Cargo operations developed at a time when
there was very little external guidance material anyway
And the challenges are increasing
Move away from the few initial airports
More complex challenges e.g. Fire Covers
More airlines/players

Case study #1 Use SOS ULD to
support training
Training is a critical part of ULD operations
SOS ULD can be used to
Inform management/decision makers that ULD are important and
do need training
Can be used as introduction to any ULD training course content

Case study # 2. Use ULD SOS to
educate airports about the importance
of ULD
Support of airport management is invaluable to good
ULD operations-
Importance of suitable storage facilities
Ramp operations discipline
SOS ULD can be used as a communications tool to
inform and educate airport management throughout
PRC

Case study #3 Inform your colleagues
about the value of ULD
ULD management should come out of the back office
shadows
Tendency to undervalue ULD operations
Lack of support by contracts, cargo sales, airport operations
teams
SOS ULD is an information age, effective, zero cost tool
to communicate across multi departmental airline
organizations

Is it possible for the PRC air cargo
industry to take responsibility for
ULD Operations In the Air Cargo
Environment in China

Interactive Session
Industry Solutions for Industry Challenges
Thank you
For more information
Visit our website
www.iata.org/cargo
Subscribe to Cargo Tracker

www.iata.org/optin
Follow us on Twitter
http://twitter.com/iata

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ULD Regulations Workshop

Chairman, IATA ULD Panel

World Cargo Symposium 2015

LIAO, Zhi Yong

World Cargo Symposium 2015

ULD Governance Structure

Airmail Panel Cargo Business IATA/FIATA

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

Protect the contents

Maximize the use of aircraft contour

Allow fast and easy transfer from one aircraft to another

Special purposes ULD

The most important purpose is to secure the loads during flight

World Cargo Symposium 2015

World Cargo Symposium 2015

ULD design / tests

Carrier certification Civil Aeronautics Act

Maintenance of CCAR-43 EASA Part M Civil Aeronautics Act 14 CFR Part 43

World Cargo Symposium 2015

ULD Service Provider

Ground Service Provider Ground Service Provider

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

Airline Compliance Air Cargo Industry Compliance

World Cargo Symposium 2015

Aircraft Appliances Operators Maintenance

Airworthiness Operations Continuing

Aircraft Appliances Operators Maintenance

aircraft Weight & TSO* C90** air carrier Part 145

* or CTSO / JTSO / ETSO, etc.

Operational inputs Technical standards

Carriers manuals Audit manuals Training programs

Section 1- Applicability Section 1- Applicability

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

Current status: Internal

World Cargo Symposium 2015

World Cargo Symposium 2015

LIAO, Zhi Yong

World Cargo Symposium 2015

The Chinese Civil Aviation Law and Chinese

Responsibilities and Tasks

Staff assembly of load in ULDs and

Loading quality directly affect flight safety

ULD is aircraft part to carry cargo, mail and baggage

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015

World Cargo Symposium 2015