What is Cargo Safety?
Since 2018, the FAA has been a critical leader for a global initiative to establish a systems approach that connects the hazards of aircraft cargo to the capability of aircraft and aircraft safety systems to mitigate potential safety hazards and reduce risk. Lithium batteries are a clear example of aircraft cargo that can pose a fire hazard that can exceed aircraft capabilities to mitigate the fire. Through Cargo Safety, the FAA is evolving how the aviation industry and supply chain identify and mitigate cargo hazards at the aircraft level. On September 9, 2021, the FAA published Advisory Circular (AC) 120-121 – Safety Risk Management Involving Items in Aircraft Cargo Compartments. The AC is a significant milestone for U.S. aviation safety and the cornerstone for a unified FAA approach to promote a safety management culture across the entire aviation cargo supply chain. Read more on the FAA’s cargo safety initiative below.
Two dedicated websites support AC 120-121:
- https://www.fire.tc.faa.gov/CargoSafety/
This website was directly related to the AC and assisting operators in conducting appropriate risk assessments on items carried in aircraft cargo compartments. - https://www.faa.gov/aircraft/safety/CargoSafety
This website was built as a high-level aircraft safety initiative around Aircraft Cargo Safety.
Aircraft operators must comply with Title 49 of the Code of Federal Regulations (49 CFR) Parts 171 through 180, Hazardous Materials Regulations (HMR), when accepting hazardous materials (dangerous goods) for transportation by aircraft. However, the aircraft-level risk presented by these items is dependent on additional factors, such as the total quantity and type, potential interactions, and existing risk mitigation measures, including fire resistant containers and fire containment covers.
Certain dangerous goods can introduce hazards that might exceed the capabilities of a certificated aircraft when carried in an aircraft cargo compartment, thus resulting in an incident or accident. Furthermore, the segregation requirements in 49 CFR Part 175 are a basic minimum standard to segregate explosives; flammable gases, solids, liquids; and oxidizers, from lithium batteries. The segregation requirements do not address any limits or concerns that lithium batteries pose in the aircraft cargo compartment at the aircraft systems level.
Most notably, United Parcel Service Flight 006 caught fire and crashed in the United Arab Emirates on September 3, 2010, resulting in a loss of the aircraft along with its flight crew. A catastrophic, uncontained fire originated from a pallet that contained 81,000 lithium batteries and other combustible materials stored in the main deck of the Boeing 747-400F. Numerous other catastrophic accidents have occurred since 1980 potentially due to hazards associated with dangerous goods in aircraft cargo compartments.
In response to lithium battery incidents, aircraft manufacturers (PDF) advised the aviation industry that cargo compartments were not designed to contain lithium battery fires. In light of this information, the FAA Technical Center tested the ability of various fire extinguishing agents and fire resistant packaging to control fires involving lithium batteries. The FAA testing concluded neither oxygen starvation through depressurization in the case of cargo aircraft, common shipping containers (e.g., unit load devices), or aircraft fire suppression systems are effective in containing or suppressing a lithium cell or battery fire.
To address these hazards at the aircraft-systems level, FAA published Advisory Circular (AC) 120-121, Safety Risk Management Involving Items in Aircraft Cargo Compartments. This AC provides guidance to assist aircraft operators to analyze hazards, perform risk assessments on items carried in aircraft cargo compartments, and develop/implement appropriate risk mitigation measures specific to their aircraft types and operations as part of their 14 CFR Part 5, Safety Management System (SMS).
Operators can significantly enhance safety by identifying hazards associated with items carried in aircraft cargo compartments and managing the risks that those hazards pose to the safe operation of the aircraft. The operator should incorporate a safety risk assessment based on identified hazards related to cargo into their organization-wide approach to managing safety risk and assuring the effectiveness of its operational safety risk controls.
Although the specific hazards that potentially impact an aircraft operator can vary, the FAA anticipates that many operators will identify these hazards, conduct safety risk management on them, and elect to incorporate mitigation measures discussed in the AC and the dedicated websites created to support the AC, whose links are provided above, into their operations. This information will be helpful for operators in conducting a risk assessment on items carried in their aircraft cargo compartments to mitigate the risks found unacceptable through Safety Risk Management (SRM).
