ALPA Helps to Promote Cargo Airline Safety
By Mark Phaneuf, ALPA Senior Staff Engineer
On April 29, 2013, we lost seven professionals in a crash that could easily have been prevented. On that day, their B-747-400 converted freighter operated by National Airlines crashed almost immediately after takeoff from Bagram Air Base in Bagram, Afghanistan (see “Listening to That Little Voice,” page XX).
The flight was operated as an FAR Part 121 supplemental cargo flight and was destined for Dubai World Central Al Maktoum International Airport in the United Arab Emirates. The airplane’s cargo included five mine-resistant ambush-protected (MRAP) vehicles secured onto pallets. Two were 12-ton MRAP all-terrain vehicles, and three were 18-ton Cougars. These vehicles were categorized as special cargo because they couldn’t be placed in unit load devices (ULDs) and restrained using the locking capabilities of the airplane’s main deck cargo-handling system. Instead, the vehicles were secured to floating pallets and restrained to the airplane’s main deck using tie-down straps.
Shortly after rotation, the airplane continued to an unsustainable steep climb, reversed course, and descended quickly into the ground. The NTSB accident investigation determined that at least one of the MRAP vehicles moved aft into the tail section of the airplane, damaging hydraulic systems and horizontal stabilizer components, which made it impossible for the flight crew to maintain control of the airplane.
The NTSB determined that the probable cause of this accident was “the air carrier’s inadequate procedures for restraining special cargo loads, which resulted in the loadmaster’s improper restraint of the cargo, which moved aft and damaged hydraulic systems Numbers 1 and 2 and horizontal stabilizer drive mechanism components, rendering the airplane uncontrollable.”
As a result of the accident, the NTSB issued Safety Recommendation A-15-014, which recommended that the FAA “create a certification for personnel responsible for the loading, restraint, and documentation of special cargo loads on transport-category airplanes, and ensure that the certification includes procedures, training, and duty-hour limitations and rest requirements consistent with other safety-sensitive, certificated positions.”
These requirements are especially critical for loading special cargo, which is defined in FAA Advisory Circular 120-85A, Appendix c.30, as cargo not contained in a ULD certified for the airplane cargo-loading system and not enclosed in a cargo compartment certified for bulk loading. This type of cargo requires special handling and securing/restraining procedures.
Currently, no certificated position identified in the regulations has the responsibility discussed in the NTSB recommendation. Consequently, no specific individual standards or training requirements are in place to ensure that operational limitations are adhered to or that loadmasters are supervised.
To address the NTSB recommendations, in May 2016 the FAA tasked an Aviation Rulemaking Advisory Committee (ARAC) with addressing cargo loadmaster certification for special cargo operations. ALPA, along with other airline industry stakeholders, was invited to participate on the ARAC’s Loadmaster Certification Working Group. As ALPA’s representative, I’m chairman of the working group, and Capt. Rich Hughey (FedEx Express), ALPA’s chairman for the President’s Committee for Cargo, is an observer to the group and a subject-matter expert on cargo aircraft operations. The working group, which is next slated to meet in early November, is charged with
- providing advice and recommendations to the ARAC on whether safety would be enhanced if individuals engaged in loading and supervising the loading of special cargo, including the preparation and accuracy of special cargo load plans, be certificated. If the working group recommends certification of these individuals, it will provide recommendations regarding which specific operations should require the use of these certificated persons. Additionally, it will recommend appropriate knowledge, experience, and skill requirements for issuing certificates and appropriate privileges and limitations.
- determining the effect of its recommendations on affected parties.
- developing a report containing recommendations based upon the group’s analysis and findings to be submitted to the FAA by May 2017.
As a member of the Loadmaster Certification Working Group, ALPA will continue to strongly advocate that training and testing standards be put in place for those individuals engaged in handling special cargo so that these types of operations are conducted as safely and securely as any other airline operation.
(Editor’s note: Mark Phaneuf spent 22 years as a loadmaster [instructor/evaluator] in the U.S. Air Force/Air National Guard and served three combat deployments in Iraq and Afghanistan between October 2002 and October 2004 before retiring in December 2004. He’s currently a senior staff engineer and accident investigator in ALPA’s Engineering & Air Safety Department.)
