Ground Support Worldwide - 15

INDUSTRY EXPERT
COLUMN:

GROUND HANDLING

787s carry more ULDs than the first generation
747 in all holds. This "stealth growth" in the
number of ULDs arriving and departing on
each aircraft places an ever-increasing challenge on the ground.
Outcome 4: It is also no secret that the
handling and cargo industries face enormous
challenges to hire and retain staff, meaning that
all too often that person building up or moving
a ULD that is about to transport maybe 10,000
kilometers on a $200 million (USD) aircraft
has a negligible understanding that this container or pallet they are working with is about
to perform a flight safety function.
Airlines have, to a greater or lesser extent,
wrestled with these outcomes for 15 years now.
Probably the first "wake up" call came in 2005
when the Federal Aviation Administration
(FAA) in the U.S. published their AC 120-85
"Air Cargo Operations" as a result of the Fine
Air Flight 101 in 1997. Spelling out in plain
language and considerable detail, this Advisory
Circular provides one, but not the only, manner
in which airlines can conduct compliant cargo
operations. ULDs are mentioned more than
150 times, reflecting the regulatory expectations, at least of the FAA, for ULD operations.
The AC 120-85 was a "cold bath" for a
number of airlines who found themselves
on the wrong end of spot audits across the
U.S., with the FAA having the authority to
carry out checks on any aircraft landing on
U.S. soil. ULD managers scrambled to ensure
that only serviceable, properly built up ULDs
were loaded to the aircraft, but with one
hand tied behind their backs as these safety
critical functions are almost entirely carried
out by outsourced vendors. However, much
money was thrown at buying new ULDs and
cargo nets, and repairing both time and time
again real-life operational standards of ULDs
remained unacceptably below par.
While individual airlines did their best
to address this, there is little one airline can
do to change the culture at a service provider
handling multiple airlines. Perhaps it was possible to make a difference at home base, but at
locations half way around the world, driving
change was close to impossible.
In 2010, IATA picked up some slack with
an enhanced focus on ULDs, leading to the
publication of the IATA ULD Regulations in
January 2013, and providing for the first time
a comprehensive reference guide to ULDs for

the industry. Enhanced training courses and
other support materials followed.
Meanwhile over at ULD CARE, the "club"
for ULD owners, operators and providers, a
10-minute video "SOS ULD" communicating
the flight safety function of ULD was produced
as a vehicle to reach out to the entire industry, and this was followed a couple of years
later by the publication of ULD CARE's "ULD
Explained" - an easy-to-read "how to" on ULDs.
Enter stage left the ULD CARE ULD Code
of Conduct. Search "code of conduct" online
and you will get 776 million hits. Codes of conduct are widely used across many industries as
a means of establishing a set of expectations
for any particular activity. Codes of conduct,
however, are not so common in aviation, where
the level of external regulation by the International Civil Aviation Organization (ICAO)
and the national aviation authorities is more
than sufficient to police the industry. So why
a code of conduct for ULDs?
As laid out earlier in this column, the
actual handling of ULDs is rarely performed
by highly regulated airlines, falling instead to
generally unregulated service providers. The
ULD Code of Conduct crystallizes the key
aspects of ULD operations.
A code of conduct coming from a community organization such as ULD CARE carries
a greater weight than the action of any one
airline - however large they may be.
While being both voluntary and non-binding, the ULD Code of Conduct sets a founda-

tion for both airlines and service providers to
aim for. Nobody has expectations of a perfect
world where each and every ULD is always
stored, transported and operated perfectly. Of
course, bad stuff will happen, but with a code
of conduct in place, there is a chance to review
such failings in an objective manner.
The code itself comprises of 1+10 specific
expectations. The "one" is that airlines/ULD
providers shall provide ULDs that are "fit for
purpose," while the "10" are the requirements
for those organizations doing the day-to-day
ULD operations. All are based on the content
of the IATA ULD Regulations, and "behind"
each line on the website are links to extensive
supporting material. Online sign-up by any
related organization is free and there are no
audits or other checks - as with many codes of
conduct, compliance is the sole responsibility
of the participant.

Following a soft launch in 2017 and a hard
launch in 2018, the list of sign-ups is growing
- recent additions being Menzies Aviation and
Hactl, with others are in the pipeline.
These are exciting times for the ULD
community, with some really interesting
technology innovations coming into play that
can finally provide ULD owners and operators
with a far closer visibility of both the location
and condition of their ULD assets.
Fifty years on these are very welcome
developments, which if they live up to expectations will drive an increase in attributable
responsibility for the condition of ULD assets,
putting the ULD CARE ULD Code of Conduct
firmly in the spotlight.

ABOUT THE AUTHOR:

Bob Rogers has spent most of his working life in Asia Pacific, a resident in Hong Kong
and for many years running the Asia-Pacific operation of Nordisk Aviation Products.
Mostly retired from a demanding "day job," these days he remains actively involved
in promoting and supporting a wider understanding of ULD through his involvement
with IATA and ULD CARE.

FEBRUARY 2020

AviationPros.com

http://www.AviationPros.com

Ground Support Worldwide

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