Addressing Cargo Safety and Security

Many of the safety and security layers working to protect our passenger airline industry are absent from all-cargo operations. Cargo airlines fly the same aircraft, take off from the same airports, utilize the same airspace, and fly over the same cities as passenger aircraft. From a safety and security standpoint, there is every reason to hold cargo operations to the same standards as passenger operations. Cargo airline operations currently experience an accident rate that is seven times higher than passenger airline operations worldwide.

Security Standards Should Be Equal

Perimeter security is one of the largest differences between passenger and cargo security practices. Employees at passenger airlines and around passenger terminals must go through an extensive security process as well as security screening in many instances to be granted authority to enter security identification display areas (SIDA) unescorted. Flight ramps and gates for passenger operations all fall within the SIDA. In contrast, ramp areas used by cargo aircraft may not be required to be included in an airport operator’s SIDA, and they are more easily accessible. In some cases, they are protected solely by a locked door or a chain-link fence, neither of which may be monitored. All Part 121 all-cargo operations should be conducted within the SIDA and protected in the same manner as passenger airline operations.

Anti-hijacking procedures referred to as the “common strategy” were created in the early 1970s by the FBI, the FAA, airlines, and ALPA, and revised after 9/11. It is intended to address all types of security threats encountered during passenger and all-cargo operations, and is based on the premise that there will be aircraft equipped with intrusion-resistant cockpit doors, properly trained people, and procedures for handling direct security incidents and threats.

This approach is sound and provides for needed layers of security, if all three measures are available. Unfortunately, for cargo aircraft not equipped with these intrusion-resistant cockpit doors, the tactics, techniques, and procedures designed to provide crews with sufficient time to react to threats to the cockpit are meaningless. In addition, all-cargo flight crews are not required to be trained in the common strategy to the same degree as passenger crews, which defeats the purpose of the common strategy, which is intended to be used by crews during line operations. If the crew is not properly trained and required to utilize the strategy, there is no way it can be implemented effectively.

All-cargo operations face security threats that aren’t always immediately apparent. For example, all-cargo aircraft often carry live animals, and animal handlers accompany them on the flight. In many circumstances these handlers carry tranquilizing drugs for use on the animals during flight. Most of the animal handlers are not airline employees, and many are foreign nationals, which limits the ability to conduct a criminal history records check on these individuals. This creates a significant risk to the cargo flight and crew when they are not protected from these potential threats by a cockpit door. We believe that any individual traveling on an all-cargo flight should be subject to the same level of security vetting and screening as flightcrew members.

Safety Gaps Must Be Addressed

While many of the same regulations are used for both commercial passenger and cargo airlines, there are lesser requirements placed on all-cargo operations in several very important areas, which results in unnecessary safety risk.

One example of this safety double standard between cargo and passenger operations is pilot flight, duty, and rest regulations. While new flight- and duty-time regulations for passenger operations were issued in 2011 and implemented in 2014, those rules apply only to flightcrew members at passenger airlines and do not include all-cargo pilots. The FAA’s original rule included all pilots, passenger, and cargo operations, but the cargo sector was removed by the Office of Management and Budget due to a flawed cost-benefit methodology. We believe that science-based flight, duty, and rest regulations must be developed for flightcrew members of all-cargo operations.

Another example of a safety gap is that all-cargo operations are exempted from Aircraft Rescue and Fire Fighting (ARFF) requirements contained in 14 Code of Federal Regulations (CFR) Part 139. This means that ARFF is not required to be staffed or even present at airports during operations of cargo aircraft.

Further, cargo aircraft carry some very dangerous cargo such as blood-borne pathogen, chemical, and even radioactive material. Not only should ARFF be staffed during cargo operations, but ARFF personnel must be trained for dealing with fires on cargo airliners. Measures need to be developed and implemented that will properly prepare firefighters for dealing with a cargo aircraft fire. There is a lack of proper ARFF equipment needed to fight all-cargo aircraft fires at some airports, including nozzle tips designed for penetrating cargo airliner hulls, and a lack of funding, because the exemption of cargo from 14 CFR Part 139 requirements interferes with fire departments’ ability to get the money they need for staffing, equipment, training, and developing strategy for cargo-specific events.

Action

  • Cargo operations should be required to be conducted within a SIDA.
  • Congress should require all-cargo airlines to implement all-cargo common strategy training and procedures.
  • The FAA should mandate the installation of intrusion-resistant flight deck doors on Part 121 all-cargo aircraft manufactured after January 1, 2018, or the date of an FAA bill’s enactment.
  • All animal handlers, escorts, or couriers traveling on all-cargo aircraft must be subject to the same screening and security procedures as flight deck crewmembers, including a criminal history records check, or be restricted to aircraft equipped with intrusion-resistant doors.
  • Ensure one level of safety and security for all cargo and passenger airline operations.

Download ALPA's Position Paper