All-Cargo Conversation Focused on Safety, Security, and Flight/Duty Time

By Christopher Freeze, Senior Aviation Technical Writer
Capt. Joe DePete, ALPA’s president, opens the all-cargo symposium.

Pilots from around the United States and Canada gathered at ALPA’s Conference Center in Herndon, Va., on April 2–3 to discuss issues specific to all-cargo flight operations. The two-day meeting consisted of presentations from subject-matter experts and moderated discussions on advancing all-cargo safety, security, and flight time/duty time.

In addition to representatives from ALPA’s all-cargo pilot groups, members of the Independent Pilots Association, which represents UPS pilots, and the Airline Professionals Association/Teamsters Local Union No. 1224, which represents ABX Air, Atlas Air, Omni Air International, and Southern Air pilots, were also in attendance.

Capt. Joe DePete, ALPA’s president, opened the meeting with a moment of silence in remembrance of the crewmembers lost in the Atlas Air Flight 3591 accident. Afterward, he reminded participants that “based on statistics, if the accident rate of all-cargo operations was applied to passenger operations, there would be an aircraft accident every two weeks. We have to improve this mark.”

Safety

Capt. Rich Hughey (FedEx Express), ALPA’s President’s Committee for Cargo chair, provided the group with an overview of the safety differences between passenger operations and all-cargo operations, pointing out that “although all-cargo operations make up only 7 percent of all Part 121 operations, they account for a disproportionately greater number of major accidents. In fact, research from the International Air Transport Association shows that the worldwide hull-loss rate for all-cargo carriers is roughly 10 times higher than that of passenger airlines.

“This number is very similar to the U.S. Part 121 fatal accident statistics from 2003 to 2016 when the all-cargo carrier accident rate was eight to 12 times higher than the passenger carrier rate,” Hughey noted. “If the FAA’s Commercial Aviation Safety Team wants to reduce the accident rate by 50 percent by 2025, it will have to address all-cargo operations. And that will require rethinking the role of the cost/benefit methodology that’s been applied.”

Hughey stressed the many differences in risk management that all-cargo pilots face versus passenger-carrying pilots. “All-cargo pilots are more likely to fly at night, carry hazardous materials, or operate into or out of an uncontrolled airfield that may or may not have adequate rescue and firefighting coverage or taxiways,” he observed. “In addition, the current industry trend tends to be that some all-cargo carriers are operating older widebody aircraft to international airports or smaller domestic airports and hiring pilots who have less total experience and training, similar to the situation at some regional carriers. Add all of these factors together, and the risk is significantly greater than that of passenger airliners.”

Capt. Steve Jangelis (Delta), ALPA’s Aviation Safety chair, moderated a discussion on all-cargo safety topics, including recent successes in reducing the carriage of undeclared dangerous goods by educating shippers on how and when to properly identify hazardous materials in packages. “The ‘Check the Box’ safety education campaign, developed in partnership with the Pipeline and Hazardous Materials Safety Administration, is a major step in the right direction toward reducing and—one day, hopefully—eliminating undeclared dangerous goods from all-cargo flights.”

Security

Capt. Preston Greene (FedEx Express), ALPA’s President’s Committee for Cargo vice chair, emphasized the unique security challenges facing all-cargo operations: the regulatory disparities and the allowance of alternate means of compliance.

“That, in this environment, there are still loopholes to the requirement of intrusion-resistant cockpit doors [IRCDs] and access to the flight deck by nonpilot personnel is shocking,” acknowledged Greene. “While background checks for security identification display area access and employee badging are better than nothing, they do little to determine a person’s intent.”

Of particular concern to attendees were the risks presented by supernumeraries, including animal handlers assisting in the transport of racehorses. “Sometimes, the only vetting these handlers have is a driver’s license or a foreign passport, and at times they just show up to the aircraft, allowing no means to challenge their credentials,” said Greene.

Capt. Rich Odbert (FedEx Express), ALPA’s Aviation Jumpseat chair, added, “They carry large needles and tranquilizers with them, and there’s no barrier between these handlers and the flight crew, which presents an unreasonable risk.” He also noted the large disparity that exists in cargo operations due to sporadic deviations by the FAA that allow individuals to access the flight deck. “One airline will be approved by a certain FAA Certificate Management Office [CMO] while another will be denied by a different CMO,” Odbert observed. “In some cases, these deviations are in sharp contrast and completely contrary to the intent of the regulations crafted after 9/11. This is another example of unreasonable risk.”

Capt. Wolfgang Koch (Delta), ALPA’s Aviation Security chair, echoed these concerns, citing, “There’ve been more attacks on the air cargo transportation chain in recent years, and there are lobbying efforts against our initiatives by big billion-dollar companies. As pilots, we know the threat is real. These security loopholes must be closed now before a more serious attack occurs.”

Discussing potential solutions to air cargo security matters, participants suggested that IRCDs be required for all-cargo aircraft and that animal handlers only be allowed to ride on aircraft with installed IRCDs. They also recommended that a working group be created to explore the development of an all-cargo common security strategy and to expand “Vision 100” training to include all-cargo flight crews.

Flight time/duty time

“One of the first things ALPA worked to achieve on behalf of pilots was sensible flight-time/duty-time limits,” said Capt. Brian Noyes (United), ALPA’s Flight Time/Duty Time Committee chair. Jay Wells, a senior attorney in ALPA’s Legal Department, noted, “In the 1930s, doctors recommended an 85-hour monthly limit for pilots, but the Commerce Department adopted different standards—some of which we still use today.”

“In the wake of the Colgan 3407 accident, Part 117 was created to apply science to improve flight- and duty-time rules,” noted Dr. Peter Dimitry, a fatigue consultant. “However, the rulemaking process required a cost/benefit analysis, and, on that basis, all-cargo operations were ‘carved out’ of the final rule. After the final rule was published, the NTSB justifiably observed, “A tired pilot is a tired pilot, whether there are 10 paying customers on board or 100, whether the payload is passengers or pallets.”

The consensus among pilot representatives was that changes are needed to address the scheduling and fatigue issues unique to all-cargo flight operations.

Kevin Psutka, ALPA’s safety and security representative, discussed the recent publication of revised flight-time/duty-time rules in Canada, noting, “They’re a step in the right direction, and all air carriers, including cargo, will be covered by them.”

Given the importance of the topic, ALPA was slated to hold an additional meeting focusing exclusively on all-cargo flight time/duty time in early May.

A unified voice

“It’s vital that we work collectively on these issues to bring about needed change,” observed DePete in closing remarks.

Capt. Daniel Wells (Atlas Air), Airline Professionals Association/Teamsters Local Union No. 1224 president, echoed DePete’s sentiments, saying, “The stronger the labor movement is, the more power we have to advocate for the issues that we hold dear. Our union is happy to work with ALPA on these issues, in whatever way we can.”

Capt. Steve Whyte (UPS), the Independent Pilots Association vice president, agreed. “The most important takeaway from this meeting is that we all need to stand together and speak in one voice and relay a consistent message that there is only one level of safety for airline pilots, regardless of their payload.”

This article was originally published in the May 2019 issue of Air Line Pilot.

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