Common Cargo Hazards
As defined in 14 CFR part 5, a hazard is a condition that could foreseeably cause or contribute to an aircraft accident. Operators should analyze their cargo system design and organizational processes and procedures to identify safety hazards and control or mitigate safety risks.
When performing Safety Risk Management (SRM) on cargo operations, there are many areas to consider, including but not limited to:
- Cargo supply chain
- Cargo acceptance
- Inherent hazardous properties of the items carried
- Cargo loading (both ground and air cargo operations)
- Training and procedural gaps
Please review the following tabs for information about common cargo hazards.
The FAA Technical Center issued a series of test reports in 2004, 2006, 2010, and 2014 that characterized the hazards posed by lithium cells and batteries transported as air cargo on aircraft and the effectiveness of certain aircraft fire suppression agents and packaging configurations in mitigating the associated risks. Research report Summary of FAA Studies Related to the Hazards Produced by Lithium Cells in Thermal Runaway in Aircraft Cargo Compartments (PDF) compiles 12 years of research to assist with hazard identification and risk mitigations applicable to the carriage of lithium batteries.
The FAA testing concluded neither oxygen starvation through depressurization nor current installed aircraft fire suppression systems are effective in containing or suppressing many lithium cell or battery fires. The Federal Aviation Administration Cargo Fire Safety website highlights the risks relative to certain items carried in aircraft cargo compartments, the hazardous cargo conditions and associated consequences that may exceed the capability of the aircraft, and available risk controls.
Cargo may contain battery-powered devices, such as tracking devices placed inside of packages or attached to cargo pallets, nets and containers. These devices monitor and record environmental conditions such as location, temperature and humidity. A subset of these devices are designed to remain active when on board an aircraft, while others remain passive until they are near a receiver upon landing.
An operator should assess the capabilities, characteristics, energy density, and hazards of these devices before introducing the carriage of these devices into their operations in accordance with their Safety Management System.
It is essential that powered devices:
- Are protected from damage;
- Are placed in a safe location on the aircraft, away from heat sources, aerosols, and flammable liquids;
- Utilize batteries that have been safety tested to a standard; and
- Will not interfere with aircraft. See 14 CFR § 91.21
- Meet Hazardous Materials Regulations (HMR) 49 CFR 173.185(c) and 173.21(c) when shipped as part of a consignment
There is increasing demand to carry and use specialty containers with integrated powered equipment. This equipment is often designed using batteries, hazardous fluids, and electrical wiring. The design may include fans that emit airflow and tracking devices that emit electro-magnetic waves. Manufacturers provide component maintenance manuals and instructions to assist an operator in integrating the containers into their operations. Temperature Controlled Containers (TCC) may attain an FAA 21.8d design approval as outlined in Order 8150.4. If the container includes a tracking device, an operator authorizes the use of the device.
Containers and Palletized Cargo with Integrated Powered Devices Resources
The total amount of dry ice to be safely carried on an aircraft is calculated by considering dry ice sublimation rates, aircraft system capabilities, airline procedures and risk controls. Packaging design can also influence the sublimation rate of dry ice and enable an increase in this total. Packaging manufacturers should provide sublimation rates and testing data for an operator to consider in their cargo SRM.
Operators should take steps to improve the safety of the supply chain, given this is a common area where hazards are introduced. Items carried in aircraft cargo compartments travel by varying modes of transportation and might be handled by a complex and vast global network of operators, manufacturers, freight forwarders, e-commerce, businesses, postal operators, online retailers, and aircraft repair and maintenance stations. The more knowledgeable the operator is about the supply chain of the cargo they carry, the more proactive they can be in analyzing system data to identify emerging safety hazards, and mitigate risks.
Hazard considerations could include, but are not limited to:
- Damage to items through any part of the supply chain;
- Undeclared or improperly prepared dangerous goods;
- Quality of items in the supply chain, such as untested lithium batteries or other dangerous goods items recalled for safety reasons;
- Freight forwarders unknowingly accepting undeclared dangerous goods from shippers;
- Dangerous goods prohibited in the mail; and
- Passengers carrying prohibited dangerous goods in baggage.
Passenger baggage might contain hazardous materials such as batteries and common household toiletries. These products seem harmless; however, they can be dangerous when stowed in certain combinations. External environmental conditions such as vibrations, static electricity, temperature and pressure variations can cause items to leak, generate toxic fumes, start a fire, or even explode. Special considerations should be given to baggage checked at the gate that was intended to remain in the passenger cabin to ensure it does not contain items restricted to the passenger cabin.
The hazards associated with mis-loaded cargo are cargo shifts and cargo loaded in a manner that causes the aircraft to be outside of center of gravity or weight limits. The outcomes associated with these hazards include loss of control of the aircraft and damage to the aircraft.
These outcomes are preventable when an operator meets regulatory requirements and follows their type-certificated Airplane Flight Manual (AFM)/Rotorcraft Flight Manual (RFM). The AFM/RFM defines where, how and what cargo can be loaded on an aircraft. The manufacturer uses these limitations to design a safe and compliant airplane. FAA regulations address weight and balance, operations, configurations, load manifest, hazardous materials, and many other topics related to air cargo. See 14 CFR 91.9(a) , which states:
Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.
To comply with 14 CFR 91.9, the operator must operate within the limitations specified in the approved AFM/RFM. This includes weight and balance information and limitations. Weight and balance limitations and loading instructions can be a part of the AFM or in a separate Weight and Balance Manual (WBM).