It is a pretty safe expectation that anyone reading this article has spent many hours of their life undertaking various types of education and training. We attend school and college, we are trained in skills and procedures in a never ending process, indeed we are expected to upgrade our training and education throughout life.
Aviation is no exception to this, the opposite is true, flight crews, cabin crews, engineers and mechanics, air traffic controllers, ramp operators – the list goes on and on – are expected to be highly trained. So why, we ask, is ULD an exception? A trained workforce is an essential part of any organization. Staff are trained to flip burgers efficiently in fast food chains, yet for whatever reason there is a generally accepted belief in the air cargo industry that you don’t need to be trained to work with ULDs? Wow, you need to train to flip a burger but don’t need to be trained to work with a piece of aircraft equipment that may be required restraining many tons of cargo during flight? Where is the logic here?
There is none, and the absence of training has simply become accepted as “normal”. Acceptable? Well, the FAA don’t seem to share that opinion, as evidenced by AC120-85 containing 4 ½ pages on the subject of training requirements related to cargo operations. Specifically the document states:
268. INDIVIDUALS WHO SHOULD RECEIVE ULD TRAINING. All air carrier and vendor personnel involved in the loading of cargo should receive ULD training.
269. ELEMENTS THE ULD TRAINING PROGRAM SHOULD CONTAIN. The air carrier should develop a training program that:
a. Ensures all loading personnel are aware that each ULD has set damage limits and are aware of individual ULD damage limits.
How much clearer can the FAA be in this regard? Section #268 even makes very clear that training shall extend to vendor personnel, not just be for airline staff.
AC120-85 has been around for 8 years now, so the industry can hardly say “ this is new, give us some time” , OK they may argue that the FAA only had direct control over US airlines, so arguably any non US airline can choose to ignore this advice, but is that being responsible or just short sighted?
To the layman a ULD may look like just some cheap piece of handling equipment that really doesn’t need any particular attention to its operation or handling. How wrong can they be? First of all, ULD are not cheap, a typical container will cost around US$ 1000, some types many times more. Second a damaged ULD may cost many hundreds of dollars to repair, and can easily do damage costing many thousands of dollars to the aircraft. This is not to mention the possible delays to flights, damage or offloading of cargo and baggage and the other implications that using a damaged ULD may trigger.
BUT, far more important is that a damaged ULD loaded into an aircraft may very well present a flight safety risk, as often damage reduces the strength of the ULD to such an extent that it is no longer able to meet its minimum required strength requirements.
Was the operator who used sticky tape to cover up this damage to an AKE container aware that he was committing a serious safety breach by concealing the damage instead of declaring the ULD unserviceable?
Probably not, more likely that not he had not been given any training, and had no idea that using a ULD with this kind of damage was not allowed.
Lack of training is often at the heart of ULD related issues:
- Lack of formal training is a significant contributor to ULD damage, particularly when coupled with poor support infrastructure such as racking etc. Indeed low quality ULD handling, transport and storage infrastructure together with a lack of training is a formula for disaster.
- Lack of formal training is a significant contributor to damage and delays to aircraft, damage to cargo and baggage and injury to operators, all caused when ULD that are unsuitable for flight, due to either damage or poor loading or both arrive at the aircraft, often with minutes left before departure, placing the last man in the chain, the aircraft loader, with very difficult choices.
- Lack of formal training leads to informal “tribal knowledge” being passed from person to person, building in inaccuracies along the way.
- Lack of formal training in ULD operations puts flight safety at risk, leads to operational inefficiencies and costs the industry millions of dollars annually.
So, what does it take to convince the air cargo industry that operating ULD without training is simply unacceptable?
The IATA ULD Regulations now brings to the industry some very specific requirements for training, drawing a line under what has gone before and establishing a set of training and competence standards for any person who will have anything to do with ULD
Following a similar system of levels as is found in the IATA Dangerous Goods Regulations, the ULD Regulations training requirements ( see Section 1.6) start with “ULD Awareness “which suits any person whose function brings them into any kind of proximity of ULD and progress through to “ULD Management” which suits a typical ULD manager.
IATA has done its bit, putting out in the air cargo industry very clear guidelines for training requirements, and at this time work is going on to create a range of IATA standard training courses that will be available throughout the industry alongside other IATA training products. But the world does not need to sit and wait for IATA to design training. The industry needs to take some actions.
As we all know adding something new into an annual budget needs time, so start now estimating how many people in your organization need training, start to plan how best to achieve this and start to get this into your budgets. Tackle decisions such as: Will it be distance learning or classroom training? At your site or off site? etc. These are questions to be considered and initiatives to be taken now, engaging your organization’s training department and your cargo management in the process from day one.
Training and aviation go hand in hand, and the widespread misunderstanding that ULD are not really part of aviation and are just a piece of packing material to be kicked around needs to be urgently and comprehensively addressed through the whole industry adopting the training standards of the IATA ULD Regulations. ULD CARE rates education as one of its 4 core foundations and will use its best efforts to promote the widespread adoption of consistent and adequate training standards across the entire air cargo industry, in publishing this article we take one small step in this direction.