Standard procedure

posted on 7th June 2018
IATA is publishing the first edition of its ULD Regulations manual, covering operational and technical standards for ULDs and their handling. So what does this mean in practice, and will it significantly improve regulatory compliance, handling standards, and the treatment of ULDs? Will Waters investigates

The IATA ULD Panel (ULDP) is in the process of publishing the first edition of its ULD Regulations (ULDR) manu al, which aims to improve regulatory compliance and handling standards across the entire ULD handling chain. The ULDR manual will replace IATA’s ULD Technical Manual, which as its name suggests mainly focused on technical issues rather than operational standards and best practice. The ULDR contains both technical and operational standards and regulatory requirements, as well as carrier requirements applicable to overall ULD operations.

Based on the requirements of Annexes 6 and 8 to the ‘Chicago Convention’, the ULDR is intended to be “an industry standard for the airlines and a technical and operational reference for airlines, Unit Load Device (ULD) manufacturers and associated service providers, providing them with means of compliance with the applicable Civil Aviation Authorities (CAA) regulations and recommendations or guidance material”.

While the ULDR applies to both passenger and cargo ULDs, the process of creating the manual has been driven and coordinated by IATA’s cargo department, a process that it says “has involved extensive consultation and collaboration with all segments of the air cargo industry”. The intention is for the ULDR to serve as a bridge between all parties across the ULD operational chain including airlines, ground service providers, cargo terminal operators, freight forwarders, shippers, consignees, ground transport providers, airports, ULD OEMs, ULD repair stations, ULD pooling and leasing companies, “and provide an effective means to ensure regulatory compliance across the ULD operational chain”.

One of the aims is to reduce the high levels of expensive and safety-threatening damage inflicted on containers, pallets and pallet nets, caused by mishandling across the ULD handling chain – which now often extends well beyond the airport environment and the direct control of airlines. The total cost of both repair and loss of ULDs in the air transport industry is estimated at about $300 million annually, and that excludes the costs of flight delays and cancellations due to the unavailability of ULDs.

In a world where air cargo operations are, to a great extent, outsourced to and performed by third-party ground-service providers, cargo terminal operators, trucking companies and freight forwarders, most ULD operations are conducted almost entirely outside the airline’s direct control and supervision. In that context, not all of the individuals and companies now handling ULDs understand that most ULDs are technically aircraft parts and are required to perform a critical safety function during flight – “and even fewer are aware that when it comes to regulatory compliance, the airline is required to ensure that only airworthy ULDs are to be loaded onto an aircraft, and that governing civil aviation authorities will hold the airline responsible”.

IATA also argues that it is “a very challenging task” for each individual airline to ensure the proper ULD handling instructions are made available to, and implemented by, all the ULD operating staff across the ULD operational chain. “The creation of the IATA ULDR provides worldwide acceptable means of compliance for all parties across the ULD operational chain to work towards a common objective of ensuring regulatory compliance,” IATA says.

Liao Zhi Yong, manager for business process and standards at IATA Cargo, says the ULDR is intended to be a document that puts ULD handling on a par with Dangerous Goods and Live Animal transport, each of which has its own IATA manual that serves as the global standard and essential guide to their transport by air.

He says one of the priorities for IATA’s ULD Panel this year is to use the ULD Regulations manual to create training courses in ULD handling that can serve as an industry standard and that can be extended across the ULD handling chain beyond the airlines themselves. Its intention is also to make appropriate training in ULD handling a part of IOSA and ISAGO audit requirements.

Practical implications

So what does all this mean in practice, and will it significantly improve regulatory compliance and handling standards?

While some in the industry have reservations about how quickly changes and improvements will come, generally the publication of the ULDR has been welcomed.

Charles Drummond, director of global operations and asset control at Chep Aerospace Solutions, comments: “Yes, we believe the introduction of the new ULD regulations is a welcome change for the industry.  The manual will provide a single reference point bringing together all aspects of ULD management for all participants in the aviation supply chain. From a pooling-company perspective, the regulation addresses important areas such as handling and messaging – two factors which greatly impact serviceability and visibility of ULDs in the supply chain.”

He believes the ULDR “will certainly increase awareness of the importance of ULDs, placing them on par with the likes of Dangerous Goods and Live Animal Transport” as important aviation topics. “The regulations will also ensure that issues with compliance are continually greatly improved,” he adds. “The collaborative and consultative approach taken in developing the regulations will greatly assist in the acceptance of the regulations, which will also be supported through a new training programme.”
Martin Kraemer, head of marketing at Jettainer, appreciates the shift from technical towards a more operational approach that also focuses on handling. “Mishandled units cause costs, time delays and complications that impact not only our business, but also the airline’s quality towards its customers,” he says. “On the other hand, it will certainly shift some responsibility towards handling agents and other players within the operational chain, which is in our favour, as it will lead to ‘better treatment’ of ULDs. Everybody has to take their responsibility very seriously.”

Matthias Huettner, head of operations processes and services for
Swissport Group Services, also highlights the messaging exchange and ULD handling elements as being “very important” to Swissport, and says the company supports initiatives to increase the standardisation of processes and procedures. “The more common processes and procedures there are across our customer base and across our stations around the world, the more efficient the services we can offer,” Huettner says. Swissport is already rolling out a programme – the ‘Swissport Formula’ – to standardise its processes around the world, and Huettner says ULD handling will also benefit from this “as, for example, investments into improved equipment are taking place at many stations as part of the programme”.

He points out that incorrect handling of ULDs has a negative impact on both safety and the quality of the process chain. “Substantial damage to the load, to ground handling equipment and to aircraft can occur,” he says. “The ULDR specifies many topics that are beneficial for more-consistent handling. Swissport strongly believes that a more-consistent process can also more easily be taught to employees, thus resulting in improved handling quality. The ULDR is not reinventing the wheel, but it is aligning processes and setting standards.”

Huettner says Swissport’s own processes and training are reviewed at regular intervals, or whenever new information becomes available or new regulations are released. “The ULD training material was recently updated and aligned with ISAGO and IGOM requirements and recommendations, so we do not expect many major changes, but will nevertheless carefully incorporate even the smallest detail,” he adds.

Andy Davies, product line manager responsible for the cargo business at AmSafe Bridport, “very much welcomes” the ULDR. A contributor to a number of ULD technical standards groups, he says that the IATA Panels have had a much more operational focus over the last few years “following the realisation that it was insufficient to just address the technical equipment standards”. He says that while the ULDR “does provide a bit more enforcement”, it more importantly increases the level of commitment and standardisation. “Half the unnecessary confusion and resulting problems in our industry are because of a lack of awareness, non-commitment or non-enforcement of standards – in that order,” he says. “Yes, aspects are complicated because ULDs are highly engineered, safety-critical aircraft equipment,  but for engineers it can be viewed much more simply – it is the safe transfer of some fairly tough standard-sized boxes, or netted packages, from one party to another without damaging them. That is something that could not be previously achieved while all involved in the operation are isolated and doing it their own way.”

Frode Eriksen, head of engineering at Nordisk Aviation Products, comments: “As an OEM, any initiative that improves the operating environment for our products is a huge improvement. It is frustrating that a ULD, designed as a lightweight structure for use on an aircraft, is treated so badly in the general environment that it cannot uphold its airworthiness and perform its function, of safely restraining cargo and baggage on an aircraft during flight, correctly. Furthermore, we believe we can take more weight out of ULDs, saving the airlines fuel, money and emissions, were there to be a more stable operating environment.”

Davies believes that the need for lighter-weight and ‘enhanced role’ ULDs has been a key driver for this initiative. “ULDs featuring advanced composites and technologies are available today that provides significant weight savings or enhanced roles in thermal cargo protection and cargo fire containment, but much greater care must be taken of these valuable assets, as damage tolerances can be less, and the cost of repair much higher,”

Nicholas Martin, director for R&D and quality assurance at temperature-controlled container specialist Envirotainer, says: “We are a strong supporter of this manual since there is a need to raise the general knowledge and competence requirement for those who handle ULDs, which is a vital part for air safety. Its successor, ULD Technical Manual, focused more on the technical specification of ULDs, while the new manual embraces everything concerning ULDs, such as design, operation guidance and training requirements.”

Martin doesn’t believe it will make much difference in the short term to the handling of ULDs or the ULD operational chain. “But for sure in the long term it will have a positive effect as it increases awareness and, as a result, damage costs will go down,” he says.

Eriksen says those handling ULDs for the most part see them as a box, not a piece of aircraft equipment. “That, combined with constant pressure on the operators to be quick and not ‘waste’ valuable area on the airport, results in very rough and unsafe handling of ULDs,” he observes. “It is estimated that around 90% of damages to containers are caused by forklifts, which in theory should not be near a ULD, but which are extensively used today due to lack of proper ground handling equipment, space, training, etc. The implementation of IATA ULD Regulations will hopefully change this over time.”

This is also an area where Envirotainer’s Nicholas Martin would like to see improvements. “ULDs that do not have a ‘forklift-able’ base are repeatedly lifted, when fully loaded, as are pallets without the use of slave pallets,” he observes. “This is not an acceptable way of handling ULDs, as it simply destroys them and is unsafe.”

Damage to ULDs is certainly an issue for third-party ULD-management and pooling companies such as Chep and Jettainer.  Drummond says: “We see a wide range of handling practices − some handlers have exceptional handling equipment, systems, training and processes while others are fairly rudimentary.” He says Chep pro-actively monitors and measures the types of damage and locations where it is occurring, and works with airlines and handlers to train staff and improve these practices to minimise damage and mishandling.

“With the entire aviation supply chain aware of the importance of ULDs and the associated handling requirements, supported by a robust compliance framework, we would expect to see a reduction in the damage and loss of ULDs,” he adds. “This will also translate into less ULD-related flight delays and overall lower the cost of ULD management across the industry.”

Kraemer says one of the big challenges currently is being able to assign damage or mishandling to any particular party. He hopes that the ULDR will create more transparency along the logistics chain, helping to identify “who had a ULD at what time and in what condition”.

Joe Ashton, commercial sales manager for AmSafe Bridport’s Cargo Product Group, says that until four or five years ago, awareness of ULDs and their importance within IATA was very low, generally speaking, “and there has been some great work done by IATA and the various supporting boards that has pushed the awareness of ULDs generally. I think this is another stepping stone in raising the awareness.”

However, the question of whether the ULDR will lead to greater enforcement of regulations is less clear. “I think what the manual will do is provide a common standard for regulatory compliance, so that there will be a common understanding wherever a unit is inspected,” he says. “There is a regulatory compliance framework now that is common, which is the first step, and I think that other areas of the industry now need to step up and enforce them.”

Davies adds: “This is not replacing or in any way going over the top of the FAA, EASA and CAAC airworthiness authority regulations. The ULDR is really user regulations that are filling the gaps in the details. The regulatory authorities are giving the overall performance requirements and system, and now the ULDR is providing everyone with a common book of reference that they can refer to when they are taking other people’s ULD equipment or buying and using their own. It is definitely a second-tier regulation; it is not an airworthiness regulation.”

But Eriksen believes the ULDR will empower airlines that outsource their ULD operations to gain some control over the way their assets are treated. “The ULD Regulations make it easier for airlines to refer to an industry recognised standard when dealing with their service providers, similar to the way airlines have referred to the previous ULD Manual when dealing with ULD suppliers in the past. Airlines carry the responsibility to carry only airworthy ULDs, and failure to comply with this requirement can lead to them putting their AOC at risk – and in some jurisdictions collecting fines.

“Without the IATA ULD Regulations they have to try their best to enforce proper practices, which is hard to do as a single airline. Having an industry standard puts a common standard in place. Of course, the ULD Regulations also put some obligations onto airlines; everyone needs to play a part to ensure compliance and reduce waste.”

Drummond concludes: “The publication of the manual in itself will not bring about the required change − it has to be supported by extensive awareness programmes and training for the whole aviation supply chain. Only then will the true objectives of this initiative be achieved.”