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NTSB · Safety Recommendation

Safety Recommendation A-15-014

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: 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.

Safety Issue and Context

On April 29, 2013, about 1527 local time, a Boeing 747-400 BCF, N949CA, operated by National Air Cargo, Inc., dba National Airlines, crashed shortly after takeoff from Bagram Air Base, Bagram, Afghanistan. All seven crewmembers—the captain, first officer, loadmaster, augmented captain and first officer, and two mechanics—died, and the airplane was destroyed from impact forces and postcrash fire. The 14 Code of Federal Regulations Part 121 supplemental cargo flight, which was operated under a multimodal contract with the US Transportation Command, was destined for Dubai World Central - Al Maktoum International Airport, Dubai, United Arab Emirates.

The airplane’s cargo included five mine-resistant ambush-protected (MRAP) vehicles secured onto pallets and shoring. Two vehicles were 12-ton MRAP all-terrain vehicles (M-ATVs) and three were 18-ton Cougars. The cargo represented the first time that National Airlines had attempted to transport five MRAP vehicles. These vehicles were considered a special cargo load because they could not be placed in unit load devices (ULDs) and restrained in the airplane using the locking capabilities of the airplane’s main deck cargo handling system. Instead, the vehicles were secured to centerline-loaded floating pallets and restrained to the airplane’s main deck using tie-down straps.

During takeoff, the airplane immediately climbed steeply then descended in a manner consistent with an aerodynamic stall. The National Transportation Safety Board’s (NTSB) investigation found strong evidence that at least one of the MRAP vehicles (the rear M-ATV) moved aft into the tail section of the airplane, damaging hydraulic systems and horizontal stabilizer components such that it was impossible for the flight crew to regain pitch control of the airplane. The likely reason for the aft movement of the cargo was that it was not properly restrained.

National Airlines’ procedures in its cargo operations manual not only omitted required, safety-critical restraint information from the airplane manufacturer (Boeing) and the manufacturer of the main deck cargo handling system (Telair, which held a supplemental type certificate [STC] for the system) but also contained incorrect and unsafe methods for restraining cargo that cannot be contained in ULDs.

The procedures did not correctly specify which components in the cargo system (such as available seat tracks) were available for use as tie-down attach points, did not define individual tie-down allowable loads, and did not describe the effect of measured strap angle on the capability of the attach fittings.

Response History

February 23, 2022 · NTSB Correspondence · FAA

We do not agree that asking air carriers to develop an FAA-approved special cargo program is responsive to this recommendation. Without creating a certification for loadmasters, we are unsure how you would ensure that air carriers’ programs include the procedures, training, and duty-hour limitations and rest requirements consistent with other safety-sensitive, certificated positions. We also do not believe the guidance referenced in your letter replaces the need for creating a certification for loadmasters.

Although Advisory Circular 120-85A, Appendix C, describes the duties of a load supervisor or loadmaster, we remain concerned that you have not defined the qualifications needed for this safety-critical position.

We continue to believe that personnel responsible for ensuring special cargo loads are properly loaded, restrained, and documented should be certified, and that their certification should include procedures, training, and duty-time and hour limitations consistent with other safety-sensitive, certificated positions. Such certification would help ensure that these personnel properly perform their safety-critical duties. However, because you have no intention of addressing this important safety issue, Safety Recommendation A-15-14 is classified CLOSED-- UNACCEPTABLE ACTION.

August 13, 2021 · Recipient Response · FAA

-From Steve Dickson, Administrator: In response to the Board’s letter dated September 29, 2020, the Federal Aviation Administration (FAA) reevaluated the Aviation Rulemaking Advisory Committee’s Loadmaster Certification Working Group’s final report and again determined that FAA certification of aircraft cargo handling personnel is not warranted at this time. As previously stated, under part 121, air carrier operators are responsible for the airworthiness of the aircraft during all phases of operations.

The aircraft load manifest must contain evidence that the aircraft is loaded according to approved schedules that ensure that the aircraft’s center of gravity is within approved limits before its planned flight.

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Recommendation Facts

Status
Closed - Unacceptable Action
Issued
July 29, 2015
Priority
CLASS II
Recipient
FAA
Adopted
July 24, 2015
Closed
February 23, 2022
Related Investigation
DCA13MA081
Related Report
AAR-15-01

Rather than initiate rulemaking, the FAA has issued and implemented numerous agency risk mitigations since the accident, including: Advisory Circular (AC) • AC 120-85A, Air Cargo Operations, provides guidance for developing a cargo operations program as part of the weight and balance control program. o Appendix C, defines load supervisor – An operator-determined name, such as loadmaster or load lead, identifying the job function of the person with overall responsibility for supervising the loading of the aircraft. This person is responsible for signing the load manifest. FAA Aviation Safety Inspector Guidance

• FAA Order 8900.1, Flight Standards Information Management System (FSIMS), Volume 3, Chapter 47: o Section 1, Safety Assurance System: Evaluating a Certificate Holder’s/Applicant’s Weight and Balance Control Program; o Section 2, Safety Assurance System; Evaluating a Certificate Holder’s/Applicant’s Weight and Balance Program (Operations); and o Section 3, Safety Assurance System; Evaluating a Certificate Holder’s/Applicant’s Weight and Balance Program (Airworthiness).

• FSIMS, Volume 6, Chapter 2: o Section 4, Safety Assurance System: Ramp and Random (Ramp) Inspections for Part 91K, 125, 141 Operators and Part 121 and 135 Air Carriers; and o Section 5, Safety Assurance System; Conduct a Ramp Inspection on Cargo Loading (including Part 125). In addition, the FAA revised its air cargo training class for aviation safety inspectors that now emphasizes the inspection procedures and loading activities of cargo carriers. Information for Operators (InFO) • InFO 13012, FAA-approved Boeing 747 Sample Weight and Balance Manual (WBM); and • InFO 15010, Approved Weight and Balance Manual (WBM) Supplements for Certain Boeing Aircraft (B-747, B-767, B-777).

Notices (N) • N 8900.317, Accepting/Revising Manuals for All Parts 91K, 121, 125, and 135 Certificate Holders/Operators Transporting Cargo on Transport Category Aircraft; and • N 8900.262 Review of Weight and Balance Control Programs Including Special Cargo Operations. Safety Alerts for Operators (SAFO) • SAFO 13005, Title 14 of the Code of Federal Regulations (14 CFR) Part 121 Air Carriers Transporting Heavy Vehicle Special Cargo Loads; • SAFO 13008, Part 121 Air Carriers Performing Special Cargo Loads Operations; • SAFO 17003, Non-compliance with a Manufacturer’s Federal Aviation Administration (FAA)-approved Aircraft Weight and Balance Manual (WBM); and

• SAFO 17004, Cargo Retention Methods Using Pallets Straps. Safety Assurance System Element Design Assessments • SAS Element 6.3.1, Carriage of Cargo (Operations), purpose is to safely handle and carry cargo; • SAS Element 6.3.3, Cargo Equipment and Appliances (Airworthiness); purpose is to maintain cargo handling equipment, systems, and appliances that support a safe operation; and • SAS Element 6.3.4, Carriage of Cargo (Airworthiness), purpose is to ensure cargo is loaded appropriately for safe operation.

Operator Responsibilities With the guidance mentioned above and an increased level of awareness among the major air cargo carriers, especially the Boeing 747 operators, the aircraft loading of special cargo for transport is being accomplished in a more compliant manner. Two active air cargo carriers initiated their own special load departments within their company, so that they do not have to outsource the aircraft load activities. The National Air Carrier Association also provides cargo carrying information to its members, explaining the proper way to position and strap cargo into aircraft when loading.

Under current Title 14, CFR Part 91 and Part 121 regulations, the air carrier is responsible for the airworthiness of the aircraft during all phases of operations by authorized personnel, as described below: • § 91.7, Civil Aircraft Airworthiness; • § 91.9, Civil Aircraft Flight Manual, Markings, and Placard Requirements; • § 121.141(b), Airplane Flight Manual; • § 121.665, Load Manifest; and • § 121.693(d), Load Manifest: All Certificate Holders.

Additionally, air carriers’ Safety Risk Management (SRM) programs should identify potential operational hazards, analyze the risks identified, perform a risk assessment, and establish effective risk mitigations for the hazards that are found to be unacceptable. All air carrier operators should apply their SRM program whenever they implement a new system, revise an existing system, develop new operational procedures, or identify ineffective risk mitigation controls. An effective SRM program applies to all personnel responsible for ensuring the proper loading, restraint, and documentation of special cargo loads. The FAA believes this responsibility resides with the air carrier.

I believe that the FAA has effectively addressed this safety recommendation and consider our actions complete.

September 29, 2020 · NTSB Correspondence · FAA

We note that, in June 2018, your aviation rulemaking advisory committee, acting on recommendations by its loadmaster certification working group, proposed that air carriers conducting special cargo operations under Part 121 be required to have an FAA-approved Special Cargo Program. You reported that, because an air carrier is responsible for an aircraft’s airworthiness during all phases of operations and its personnel must be competent, trained, and authorized to perform or supervise aircraft loading, air carriers are responsible for developing an FAA-approved Special Cargo Program.

We further note that FAA Order 8900.1 was revised to include guidance for inspectors that addresses ramp inspections for cargo loading as well as the delineation of the differences in duties between operations and airworthiness inspectors.

We do not agree that asking air carriers to develop an FAA-approved Special Cargo Program is responsive to this recommendation. In addition, although the revisions to Order 8900.1 are responsive to A-15-16, we do not believe they are responsive to A-15-14, which asks you to create a certification for loadmasters.

We point out that Safety Alert for Operators 13005 advises cargo operators to “use at least a qualified loadmaster” and ensure that employees and vendors are properly trained, loading is properly completed, and cargo restraints and loading devices meet the requirements of the operator’s FAA-approved program. Although we agree with this guidance, we are concerned that the FAA does not define the position of “loadmaster” and has not established training requirements that would set qualification standards for cargo-handling personnel. FAA-certificated positions, like pilots, dispatchers, and mechanics, are subject to specific requirements for initial and recurrent training and experience.

However, because a loadmaster is not an FAA-certificated position, there are no FAA requirements for the procedures and training programs for personnel who oversee cargo-loading plans and implementation of those plans. Also, unlike flight crewmembers, cargo-handling personnel are not subject to duty-time limitations or rest requirements.

We continue to believe that the certification of personnel responsible for ensuring the proper loading, restraint, and documentation of special cargo loads, including requirements for their procedures, training, and duty-time and hour limitations, would help ensure that these personnel properly perform their safety-critical duties. Pending our review of a plan for creating the recommended certification, Safety Recommendation A-15-14 is classified OPEN--UNACCEPTABLE RESPONSE.

April 13, 2020 · Recipient Response · FAA

-From Steve Dickson, Administrator: As discussed in our two previous letters to the Board, the FAA published a Notice on May 12, 2016, establishing a new ARAC subgroup, the Loadmaster Certification Working Group (LCWG), to provide advice and recommendations on this issue. The LCWG began meeting in August 2016. The ARAC received the LCWG recommendations on June 22, 2018. The ARAC recommended the FAA require air carriers conducting special cargo operations under 14 CFR Part 121 to have an FAA-Approved Special Cargo Program. Under current regulations, the air carrier is responsible for the airworthiness of the aircraft during all phases of operations.

The air carrier’s personnel must be competent, trained, and authorized to perform or supervise aircraft loading. The FAA asserts this responsibility fully resides with the air carrier, thus additional rule making is not required.

To address this recommendation, the FAA has revised FAA Order 8900.1, Inspector Handbook Volume 3, Chapter 47 and Volume 6, Chapter 2 to include new guidance specifically addressing ramp inspections for cargo loading as well as the delineation of the differences in duties between operations and airworthiness inspectors.

August 31, 2017 · NTSB Correspondence · FAA

We note that the loadmaster certification working group (LCWG) held its first meeting in August 2016. The LCWG was created by your aviation rulemaking advisory committee to consider creating a certification for personnel involved in loading special cargo. We also note that the LCWG anticipates completing its report sometime in 2018. Pending completion of the LCWG’s activities and action that will satisfy Safety Recommendation A-15-14, it remains classified OPEN--ACCEPTABLE RESPONSE.

May 31, 2017 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA), as we reported in our September 8. 2016, letter to the Board, convened a new subgroup of the Aviation Rulemaking Advisory Committee (ARAC), the Loadmaster Certification Working Group (LCWG). The LCWG first met in August 2016. The LCWG will provide advice and recommendations to the ARAC on whether "safety would be enhanced .. by creating a certification for .. persons engaged in the loading and supervision of the loading of special cargo." Once the LCWG completes its assigned tasks, the ARAC submits a recommendation report to the FAA. The final report from the LCWP is due to the ARAC by August 2018.

October 12, 2016 · NTSB Correspondence · FAA

We note that, rather than your original plan of holding a public forum to address this recommendation, you tasked your aviation rulemaking advisory committee (ARAC) with examining the issue of creating a certification for personnel involved in loading special cargo. The ARAC created the loadmaster certification working group (LCWG), which will develop potential revisions to satisfy this recommendation. Pending completion of the LCWG activities and action that will satisfy Safety Recommendation A-15-014, it remains classified OPEN—ACCEPTABLE RESPONSE.

September 8, 2016 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) decided to revise our original plan of holding a public forum and replace it with an Aviation Rulemaking Advisory Committee (ARAC) proposal. The FAA believes this action is closer to meeting the intent of the recommendation. The FAA's Rulemaking Management Counci l approved the ARAC proposal on March 23, 2016. A new ARAC subgroup, the Loadmaster Certification Working Group (LCWG). will provide advice and recommendations to the ARAC on whether '·safety would be enhanced'' by creating a certification for --persons engaged in the loading and supervision of the loading of special cargo."

The notice for the LCWG published in the Federal Register on May 12, 20 16 (81 FR 29609).

January 27, 2016 · NTSB Correspondence · FAA

We note that the Cargo Focus Team (CFT), which was developed to provide technical support for inspectors, is organizing a public forum on certification for personnel responsible for the loading, restraint, and documentation of special cargo loads on transport category airplanes. We look forward to reviewing the CFT’s findings from the forum and its plan for creating the new certification. Pending our review of this information and completion of the recommended action, Safety Recommendation A-15-14 is classified OPEN—ACCEPTABLE RESPONSE.

October 27, 2015 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: The FAA has established a Cargo Focus Team (CFT) to provide technical support for inspectors. The CFT intends to provide direct support to field office personnel on subjects that require specialized expertise not often available to the field. The CFT, with industry involvement, plans to organize a public forum on the need to create a certification for personnel responsible for the loading, restraint, and documentation of special cargo loads on transport category airplanes, and how this goal can be achieved. The FAA expects the forum to occur in the second half of 2016.