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General Aviation Safety
ON FEBRUARY 16, 1980, A BRITISH REDCOAT AIR CARGO, LTD., BRISTOL BRITANNIA, 253F, CRASHED IN A WOODED AREA NEAR BILLERICA, MASSACHUSETTS, ABOUT 7 MINUTES AFTER TAKEOFF FROM LOGAN INTERNATIONAL AIRPORT IN BOSTON. OF THE SIX CREWMEMBERS AND TWO PASSENGERS ABOARD, ONLY THE FLIGHT ENGINEER SURVIVED. ALTHOUGH WEIGHT AND BALANCE AND CENTER OF GRAVITY PROBLEMS DID NOT CONTRIBUTE TO THE CAUSE OF THIS ACCIDENT, THE NATIONAL TRANSPORTATION SAFETY BOARD'S INVESTIGATION REVEALED APPARENT LAX PRACTICES IN DETERMINING THE WEIGHT OF INDIVIDUAL PIECES IN BULK CARGO SHIPMENTS. THESE PRACTICES APPEAR TO INVOLVE MANUFACTURER/ SHIPPERS AND FREIGHT FORWARDERS, AS WELL AS AIR CARRIERS AND FLIGHTCREWS. THE SAFETY BOARD BELIEVES THAT THIS LAXNESS IS PERPETUATED BY THE ABSENCE OF REGULATORY GUIDELINES.
THE NTSB RECOMMENDS THAT THE FEDERAL AVIATION ADMINISTRATION: PROMULGATE REGULATIONS TO REQUIRE THAT UNIT PIECES IN BULK LOAD AIR CARGOES ARE LABELED AS TO ACTUAL WEIGHT.
Original recommendation transmittal letter:
Closed - Unacceptable Action
Clarksburg, WV, United States
Allegheny Airlines, Inc., Nord 262 Mohawk/Frakes 298, N29824
Addressee(s) and Addressee Status:
FAA (Closed - Unacceptable Action)
Safety Recommendation History
This is in regard to the National Transportation Safety Board's Safety Recommendation A-81-18, concerning responsibilities of shippers, freight forwarders and air carriers in determining unit weights in bulk cargo shipments. The Safety Board continues to believe that the elimination of certification of air freight forwarders associated with the phase-out of the Civil Aeronautics Board (CAB) and the absence of regulations governing air freight forwarders, specifically in the area of a requirement to determine the weight of individual pieces in bulk load cargoes, and the subsequent indiscriminate loading of those unknown weights in relation to an aircraft's center of gravity, pose potential safety hazards. In your response dated April 2, 1982, you state that the FAA considers the present aircraft weight and balance program and the requirement for spot checking of declared cargo weights adequate and safe for all U.S. certificated carriers. However, as we indicated previously, we are concerned primarily about the operations of supplemental air carriers and commercial operators who do not have the personnel and equipment to determine the accuracy of declared weights, and who, therefore, have to rely on declarations by freight brokers, freight forwarders, or shippers. It is that "itinerant" type of operation that frequently receives shipments, each containing many individual pieces of varying weights. The pieces are usually not weight identified, nor are the pallets weight identified when several unlabeled pieces are placed on a pallet. As stated in our original letter, there is no regulation that requires freight forwarders to have a scale. In many cases the bulk load cargoes are loaded by guesswork and experience. While in most cases the weight and balance computations are mathematically accurate, the data upon which the computations are based may be erroneous. Therefore, the spot checking of weight and balance forms calculated under these conditions is not of any real value in determining the overall adequacy and safety of any operation. Without scales, a spot check becomes a comparatively meaningless mathematical exercise. Enclosed is a copy of a Coroner's Jury Verdict, forwarded to us by the Chief Coroner of the Province of Ontario, Canada. The jury determined that the cause of the accident was the improper distribution of cargo in relation to the center of gravity, and made findings and recommendations similar to those made by the Safety Board. While this Canadian case certainly does not constitute statistical support for the Board's position, it does indicate that an investigative body of another country has encountered the same problem that caused Safety Recommendation A-81-18 to be issued. The Safety Board is gratified to learn that the FAA is continuing to inspect the freight forwarders' function by maintaining control of the air carriers' weight and balance program through program approval and on-scene inspections; however, the Data Source: NTSB Recommendations to FAA and FAA Responses Board believes the potential for disaster to be greater than the economic burden which would be imposed by the recommended regulations and, safety-wise, to be in the public interest. Because the FAA has advised it does not intend to take additional action, Safety Recommendation A-81-18 is now classified in a "Closed--Unacceptable Action" status.
FAA LTR: WE DO NOT BELIEVE THAT REQUIRING EACH PACKAGE OF A BULK SHIPMENT TO BE INDIVIDUALLY WEIGHT-MARKED IN A PRESCRIBED MANNER WILL PROVIDE A MORE ACCURATE WEIGHT THAN WEIGHING A CARGO-FILLED CONTAINER OR PALLET. THE CHANCE FOR ERROR IS GREATER WHEN TALLYING INDIVIDUAL FIGURES THAN RECORDING AND DISTRIBUTING ONE BULK WEIGHT. FOR THOSE SMALL AIRCRAFT NOT ACCEPTING UNITIZED LOADS, THE PACKAGES ARE PRESENTLY BEING INDIVIDUALLY MARKED OR INDIVIDUALLY RECORDED ON A TOTAL SHIPMENT MANIFEST. THOSE PACKAGES ARE THEN HAND LOADED INTO MARKED BINS OR SELECTION STATIONS. THEREFORE, WE BELIEVE THE PRESENT METHOD OF HANDLING, WEIGHING, AND MARKING AIR CARGO IS ADEQUATE AND CONSISTENT WITH THE HIGH SAFETY STANDARD ESTABLISHED BY THE FAA. ANY UNWARRANTED ADDITIONAL ECONOMIC BURDEN IMPOSED WITH NO SUPPORTING DATA WOULD NOT BE IN THE PUBLIC'S INTEREST.
The Safety Board does not believe that the FAA program of required operations specifications for weight and balance determination by air carriers deal adequately with the more general problem that there is no current requirement for labeling the weight of individual pieces in bulk load cargoes. In actual practice, loading procedures and spot checking are being loosely applied, especially in the case of itinerant operations. At best, the spot checking of large bulk shipments containing Data Source: NTSB Recommendations to FAA and FAA Responses many individual pieces is difficult and time consuming. Spot checking is a futile task when there are no "spots" to check. When individual pieces are not labeled according to weight, the whole shipment must be weighed - a task that is not enthusiastically undertaken. If, however, individual pieces were weight labeled, spot checking would become practicable. In the case of the Redcoat Britannia accident, there were no declared weights of individual pieces furnished by the air freight forwarder. Only the total weight of the entire shipment was furnished by the shipper to the forwarder, who in turn passed it to the aircraft operator. As mentioned in our recommendation letter, the total shipment weight was in error. Had an FAA inspector been on the scene, it would have been impossible for him to determine the total weight, much less if accurate weights had been used for individual pieces, short of weighing the entire load. For these reasons, the provision of Operations Bulletin No. 8-76-3, Declaration of Erroneous Cargo Weights, that principal inspectors are to review their assigned operator's manuals to ensure that adequate procedures are established for the spot checking of declared cargo weights furnished by air freight forwarders in order to assure the use of accurate load manifests and weight-and-balance computations does not resolve the problem. Manual procedures may be sufficient, or at least partly so, for air carriers and large supplementals. But it is clear that they are not so for the small itinerant operator such as Redcoat, who must rely on the integrity and efficiency of the shipper and freight forwarder, because he would find procedures such as those required for air carrier manuals economically unfeasible. With the Civil Aeronautics Board no longer policing freight forwarders, the FAA must increase its surveillance on the airport side of the fence, especially of itinerant type operations, and we firmly believe that the labeling of individual pieces would make the FAA's inspectors surveillance practicable and enhance safety in cargo operations. We, therefore, request the FAA to reconsider this recommendation which we are maintaining in an "Open--Unacceptable Action" status.
FAA LTR: THERE ARE REGULATORY FACTORS THAT CONTROL THE TOTAL WEIGHT AND BALANCE PROGRAMS. THIS CONTROL IS THROUGH OPERATIONS SPECIFICATIONS THAT REQUIRE EACH CARRIER TO HAVE AN FAA-APPROVED METHOD FOR ACCURATELY DETERMINING THE WEIGHT AND BALANCE OF EACH AIRCRAFT. IN THIS APPROVED PROGRAM, THE PROCEDURE MUST BE SPELLED OUT IN THE CARRIER'S MANUAL, WHICH, THROUGH THE OPERATIONS SPECIFICATIONS, THEN BECOMES REGULATORY. THE MANUAL MUST PROVIDE FOR WEIGHING WHEN SPECIFIC WEIGHTS ARE NOT DISPLAYED AND IT MUST ALSO CONTAIN PROCEDURES FOR SPOT CHECKING THE ACCURACY OF THE ALREADY LABELLED ITEMS. ADVISORY CIRCULAR 120-27A, AIRCRAFT WEIGHT AND BALANCE CONTROL, PROVIDES THE CARRIER WITH METHODS AND PROCEDURES FOR DEVELOPING AN APPROVED WEIGHT AND BALANCE CONTROL SYSTEM. IN ADDITION TO THE APPROVED WEIGHT AND BALANCE PROGRAM, AIR CARRIER OPERATIONS BULLETIN NO. 8-76-3, DECLARATION OF ERRONEOUS CARGO WEIGHTS, STATES THAT PRINCIPAL INSPECTION ARE TO REVIEW THEIR ASSIGNED OPERATOR'S MANUAL TO ENSURE THAT ADEQUATE PROCEDURES ARE ESTABLISHED FOR THE SPOT CHECKING OF DECLARED CARGO WEIGHTS FURNISHED BY AIR FREIGHT FORWARDERS IN ORDER TO ASSURE THE USE OF ACCURATE LOAD MANIFESTS AND WEIGHT AND BALANCE COMPUTATIONS.
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