Transport of Cargo in Passenger Compartment - Civil Aviation Safety Alert (CASA) No. 2020-04

Attention:

Canadian air operators transporting cargo on passenger seats in an aircraft passenger compartment certified to carry only passengers, as well as to the transport of cargo in passenger compartments where the passenger seats have been removed for this purpose.

File Classification No.:	Z 5000-35
RDIMS No.:	17293954
Document No.:	CASA 2020-04
Issue No.:	04
Effective Date:	2021-09-21

Purpose:

The purpose of this Civil Aviation Safety Alert (CASA) is to provide guidelines to Canadian air operators during the current COVID-19 pandemic for transporting cargo in a passenger compartment certified to carry only passengers, while complying with section 602.86 of the Canadian Aviation Regulations (CARs).

This document also provides guidelines for the transport of cargo on passenger seats as well as the transport of cargo in passenger compartments where the passenger seats have been removed for this purpose.

For airworthiness aspects regarding transport of cargo on seats in the passenger compartment, or transport of cargo in the passenger compartment where seats have been removed, this document provides air operators with technical information to comply with applicable regulatory requirements when no approved design change exists or related technical investigations are on-going.

Background:

Air cargo services are vital for the economy and for fighting COVID-19, and Canadians and global supply chains depend on them operating unhindered. Air cargo should therefore be able to continuously deliver critical products such as food, medical supplies and personal protective equipment (PPE), as well as other products which are vital for the functioning of sensitive supply chains. Following this more and more operators are required to fly cargo using passenger aircraft.

Air operators may also refer to guidelines published by the aircraft manufacturers.

The type certification of the relevant large aeroplanes certified for passenger transport does not approve the passenger compartment as a cargo compartment. Therefore, the passenger compartment does not meet the applicable standards for the transportation of cargo. The transport of cargo in the passenger compartment beyond already approved stowage areas is neither covered by the approval of the aeroplane nor by the approval of the seats.

Recommended action:

1. Operational Aspects for Transport of Cargo in Passenger Compartments

• a) Cargo shall only be transported by air operators holding valid Part VII approval.
• b) Cargo operations in support of COVID-19 requests where cargo is to be carried in passenger compartments must be operated with a NO Passengers limitation.
• c) Required crew members only that are directly related to the operation of such cargo flights will be permitted, including aircraft maintenance engineers (AMEs), acting as additional crew members. They will be required to be trained (e.g. 705.124(2)(e) of the CARs) with respect to their duties and have training records.
• d) These operations are to be allowed only on a temporary basis and as necessary given the current COVID-19 situation. The transport of cargo on passenger seats, or, in the passenger compartment, will require adequate restraint systems/means which must address the ground, flight, turbulence, take-off, landing, and emergency landing conditions.

1.1. Crew composition

• a) Operations without passengers shall require two or more crew members to survey and access all areas of the passenger compartment during all phases of flight. Any fire that occurs must be discovered and extinguished immediately utilizing emergency equipment. These crew members are considered additional crew members with specific duties assigned during the flight and would be in addition to the required flight crew members. The operator’s risk assessment shall be used to determine the total number of additional crew members needed for the operation and must include the type and volume of cargo, the size of the aeroplane, the length of the flight, and the availability of alternate airports.
• b) The additional crew members must be provided appropriate seats that are not located near the cargo (i.e. first rows). These seats must be certified for use during taxi, take-off, landing, flight, and for emergency landing conditions. The additional crew members seating location must be provided with a means of two-way communication with the flight crew members.
• c) If there are three or more employees on board an aircraft, at least one of whom is not a flight crew member, one of them shall be a first aid attendant and have received the training set out in section 9.5 of the Aviation Occupational Health and Safety Regulations.
• d) The additional crew members shall have received the following emergency procedures training:
  • I. instruction in the location and operation of all emergency equipment;
  • II. recognition and suppression of fire in the air and on the ground;
  • III. use of hand-held fire extinguishers, including practical training;
  • IV. use of protective breathing equipment, including practical training;
  • V. operation and use of emergency exits;
  • VI. emergency evacuation procedures;
  • VII. donning and inflation of life preservers (when equipped); and
  • VIII. removal from stowage, deployment, inflation and boarding of life rafts/slide rafts (when equipped).

1.2. Procedures

• a) A risk assessment shall be performed by the operator in order to identify hazards related to operating cargo flights using passenger compartment configurations which have been approved for transporting only passengers. The risk assessment shall be submitted to Transport Canada Civil Aviation (TCCA) through the operator’s principal operations inspector (POI). This risk assessment needs to address the specific configuration of the aircraft to be utilized for the transport of cargo in the passenger compartment whether, or not, passenger seats remain installed.
• b) The pilot-in-command of an aircraft shall ensure that, prior to each flight or series of flight segments, the crew members of the aircraft are given a pre-flight briefing to address the type of operation being conducted and any additional information necessary for the flight, including information respecting unserviceable equipment or abnormalities.
• c) The air operator must develop procedures to ensure cargo is properly located, stowed, and secured before each flight, during the flight, and prior to landing based on the TCCA recommendations contained in this CASA. These procedures may be performed by the flight crew and/or the additional crew members. Once completed there shall be a means to record that the air operator’s procedures have been complied with and that this information is shared with the pilot-in-command, which becomes part of the final verification procedure.
• d) Operators shall establish procedures to manage emergencies in the passenger compartment; existing procedures may need to be amended to address this type of operation of the aircraft. The pilot-in-command is responsible to ensure that all crew members are appropriately briefed prior to departure.
• e) Operators may require temporary revisions to their applicable operating manuals to include the new type of operations and the related procedures. This includes, but is not limited to, flight, ground, cargo loading, company operations and maintenance control manuals.
• f) Operators shall establish procedures to address the required equipment that is to be operational for each flight considering the change to the aircraft configuration; consideration must also be given to emergency and other non-normal procedures when the aircraft is being operated to transport cargo in the passenger compartment.

1.3 Loading and Mitigations for transport of cargo in passenger compartment including on passenger seats

• a) Exact cargo weight and position in the passenger compartment and in the designated cargo hold(s) shall be reflected in the weight and balance documentation (load sheet) and weight and balance and loading control manuals, as applicable.
• b) The pilot-in-command shall be informed of the content of all the cargo using Notice to Captain (NOTOC) or other approved operator procedures.
• c) The operator shall load the aircraft considering the different levels of available fire protection in the loading areas.
• d) For the bulkheads, or other passenger compartment monuments, such as overhead bins or galleys or other stowage compartments, etc., that have a placard indicating maximum capacity, the cargo items stowed in these areas shall not exceed the maximum capacity indicated in the placard. Operators shall not load cargo in any of these stowage locations if that stowage location contains any emergency equipment, such as portable oxygen bottles, protective breathing equipment (PBE), fire extinguishers, equipment containing lithium batteries, etc. The operator’s procedures shall indicate this limitation.
• e) The maximum capacity limitations in the required safety placards (on or adjacent to the cargo approved stowage locations) shall not be exceeded. All stowage instructions specified in the placards apply.
• f) The weight of the cargo shall not exceed the structural loading limits of the floor, or seats, as published in the aircraft documentation (e.g. Limitation chapter of the Weight and Balance Manual, Seat Component Maintenance Manual Limitations, etc.). Compliance with certification standards, AWM 525.561, 525.562, 525.785, 525.789 is expected.
• g) The cargo placed in enclosed stowage areas shall not be of such size that it prevents latched doors from being closed properly and securely.
• h) The cargo items shall be stowed only in a location that is capable of restraining the cargo to accommodate ground, flight, take-off, landing, and emergency condition loads.
• i) The cargo stowage location shall be such that, in the event of an emergency evacuation, it will not hinder aisle access and egress.
• j) The cargo shall not be placed where it can impede access to emergency equipment.
• k) The cargo shall be checked to ensure proper stowage in the following instances (at the minimum): The additional crew members will be required to carry out these inspections/checks:
  • I. Before take-off,
  • II. Before landing,
  • III. At frequent intervals during the flight (not to exceed 30 minutes), and
  • IV. Under orders of the pilot-in-command.
• l) The aisles shall remain free of cargo to enable access to the cargo, and seats (if still installed), in case of smoke or fire. This includes the loading of all cargo in a manner that allows sufficient access to allow effective fire detection and fire-fighting. Refer to Appendix 1.
• m) Any smoke or fire within the passenger compartment must be easily detected and rapidly extinguished using the existing provided emergency equipment. Additional emergency equipment such as additional hand-held fire extinguishers and protective breathing equipment may be necessary to be installed to address the increased fire load of the cargo compared to passenger carriage. Thoroughly briefed additional crew members shall be on-board to survey and access all areas of the passenger compartment during all flight phases. There must be an adequate number of trained crew members acting as fire-fighters (not part of the flight crew) with a sufficient amount of firefighting equipment. This equipment may be stowed in the passenger compartment using existing stowage provisions (overhead bins, stowage’s) provided that the location is identifiable for the crew members. Specific details, including frequency of in-flight checks, must be coordinated with local regulatory authorities (i.e the operator’s POI).
• n) Additional crew members should utilize existing flight attendant seats unless other suitable seat locations are available and acceptable for this operation. They must not share seat rows with cargo. There must be a clear separation of areas occupied by occupants and those fitted with cargo during taxi, take-off, landing, and flight. At least one empty seat row between cargo and reserved occupant seats must be established. Any anticipated shifting of the cargo during flight must not interfere with the occupied seats.
• o) ‘Under seat stowage’ is allowed only if the seat is equipped with a restraint bar system and the cargo items can be placed fully underneath the seat. The loading of the cargo under each seat should not exceed the limitations identified in Appendix 1. This is allowed only if stowage of cargo in these areas will not impede visual inspection during flight.
• p) The cargo packaging shall be able to equalize the pressure so that it can handle the Delta Pressure (DP) during the flight, as applicable.
• q) All smoke and fire detectors shall be maintained as per the applicable Instructions for Continued Airworthiness (ICA) or Component Maintenance Manual (CMM). Any areas where existing smoke detectors are installed, such as in lavatories, must not be used for cargo stowage if the smoke detection system is not operational.
• r) The air conditioning and pressurization system shall be operational taking into account the nature of the cargo transported in the passenger compartment, the number and distribution of occupants, the need to minimize the potential for smoke to enter the flight deck, to maximize the ability of the additional crew members to detect and fight a fire, and any emergency procedure requiring their functionality.
• s) If seats remain installed, the load should be evenly distributed across the seat row. The cargo loading on each seat should not exceed that loading identified in Appendix 1.
• t) If seats remain installed, the vertical center of gravity (CG) of the cargo must be equal to or lower than the passenger CG of the seat, provided by the seat supplier.
• u) If seats remain installed, the cargo on the seats shall be adequately restrained and the restraint means must be attached to the existing seat, to the seat primary structure itself, or directly to the cabin floor seat tracks in accordance with structural load limitations. Seat primary structure – refer to Appendix 1. The restraint means shall address in particular upward, forward and sideward load cases. Seat backrests are typically not designed to hold emergency landing forward loads induced by cargo and are not to be used to restrain those loads.
• v) If seats do not remain installed, the cargo restraint means must be installed to attach directly to the seat tracks in the passenger compartment floor (or other structural attachment points) and must be able to accommodate the ground, flight, turbulence, take-off, landing, and emergency landing conditions. For individual cargo volume load restrictions refer to Appendix 3.
• w) The standard portable safety and emergency equipment from the passenger configuration shall be retained in the aircraft and is expected to be available to the additional crew members, such as protective breathing equipment (PBE), portable oxygen bottles with masks attached, fire extinguishers, etc. The need for additional emergency equipment must be evaluated by considering the cargo to be transported (e.g. expected class of fire), the existing equipment installed and the operation (e.g. ETOPS). For example, additional portable fire extinguishers may be required – refer to Appendix 2. In addition, if a passenger emergency oxygen system (such as a drop down overhead mask system) is installed, then the automatic activation of this system is to be disabled, or deactivated, for flight operations conducted under this CASA. Considering portable oxygen equipment for the crew members during flight operations, portable oxygen equipment meeting the standards of 525.1439(b)(1)(2) and (4) as well as 525.1443(e) must be provided.
• x) To prevent passenger compartment floor collapse during a cabin depressurization, the passenger compartment cargo loading procedures are to ensure depressurization panels are unobstructed by any cargo loaded and as per aircraft manufacturer instructions.
• y) To prevent overheating of passenger compartment systems adjacent to cargo, entertainment systems, seat power systems, unused galley systems and any other heat generating systems that are not required for the operation of the aircraft are to be turned off.
• z) When cargo is loaded into the passenger compartment, the cargo shall not include any live animals.

2. Transport of Dangerous Goods (TDG)

2.1 Dangerous goods (DG) shall only be transported by operators holding an approval

• a) Dangerous goods shall not be carried in the passenger compartment and must always be carried in the approved cargo compartments and shall be transported under the conditions established by the Transportation of Dangerous Goods Regulations.
• b) In the absence of passengers, the limits for the dangerous goods may be those established in the Technical Instructions for Cargo Aircraft, instead of Passenger Aircraft. The operator shall nevertheless include this aspect in the risk assessment performed.
• c) Additional training/briefing shall be given to the crew members, particularly letting them know whether the limits have been increased from those applicable to passengers to those applicable to cargo. This should, at least, include the following:
  • I. the risks and consequences of increasing the amount of DG in the hold;
  • II. any changes in the emergency procedures and the emergency equipment that may be on board.
• d) Relevant information on dangerous goods (e.g. affecting emergency procedures) shall be included in the briefing given to all aircraft occupants.
• e) Subject to Crew Composition in Section 1.1, nobody other than a crew member, an operator’s employee in an official capacity, a Transport Canada Civil Aviation Safety Inspector or an authorized person accompanying a consignment or other cargo may be present on board. Any other person will be considered a passenger and, therefore, the aircraft will no longer be operated under the provisions of this CASA or be able to use the provisions applicable to cargo aircraft in regards to the transport of dangerous goods.

3. Airworthiness Aspects for Transport of Cargo in the Passenger Compartments

3.1 Transport of medical supplies under a design change approval

In the context of the emergency situation created by the COVID-19 pandemic, properly authorized and delegated organizations such as DAO, DAR, or AEO, approved by Transport Canada, may approve such modifications under their delegated privileges, allowing for the use of passenger compartment seats or passenger compartments with the seats removed, when related to the transportation of medical supplies (e.g. masks, gloves, clothing, etc.) provided they are not classified as dangerous goods. This has to be indicated in the approval documents and AFM Supplement.

Since this kind of installation is a change in the scope of operation of the aircraft, and in the absence of dedicated operational requirements covering this kind of operation, the installation and the procedures for operation must be addressed taking into account the specific configuration of each aircraft model affected.

Further guidance can be found in the operational aspects of this document and should be taken into account.

3.2. Transport of other cargo under a design change approval

For transport of cargo other than medical supplies as well as in case removal of seats are necessary to allow fixation of cargo onto the aircraft structure for cargo operation, a design approval (e.g. TC, STC, LSTC) issued under CAR 521 application is required and will be processed by TCCA, or its delegates.

4. Return to Passenger Service

Before the aircraft is used for passenger service after being used to transport cargo in the passenger compartment, the operator should ensure the return of the cabin back to the configuration certified for passenger transportation. Operators are reminded that if the operator wishes to make these changes permanent, then a design change approval in compliance with the applicable certification basis of the aircraft is required.

General conditions

Canadian air operators utilizing these guidelines for the intended purpose must advise TCCA through their respective principal operations inspector (POI) and should expect to demonstrate their compliance with all requirements outlined in this document.

Air operators shall submit a compliance matrix to the POI demonstrating all elements identified in the “Recommended Action” have been met, as applicable.

The POI will consult with other specialists within TCCA to ensure that passenger compartment configuration changes (including any necessary approvals) and operational procedures are acceptable for the intended purpose of the operation.

Upon review, TCCA will issue an approval letter, if all elements identified in the “Recommended Action” have been met.

Air operators shall report to the POI, the total number of hours flown by all aeroplanes transporting cargo in the passenger compartment. This shall be done for each calendar month since the beginning of this type of operation.

Validity

This CASA is in effect from April 14, 2020 at 00:00 EDT and remains in effect until the earliest of the following:

• a) Until July 31, 2022 at 23h59 EDT;
• b) The date on which this CASA is cancelled in writing by TCCA, where in the opinion of the Minister that it is no longer in the public interest or is likely to adversely affect aviation safety or security.

Appendix 1 – Loading cargo on seats

Cargo loaded on a seat must not exceed 50 pounds per seat place, or 110 pounds in a single package per triple seat, and must not extend above the seatback height.

The operator may exceed the limits specified in this condition only upon receiving written approval prior to operation. Any request for such approval must be submitted to the operator’s principal operations inspector (POI) and include the following information:

• a) the requested cargo weight per seat place,
• b) the proposed method of restraint, and
• c) the substantiation data that supports the request.

Cargo stowed under seats must not exceed 20 pounds per seat place.

Operators must restrain all cargo loaded on each seat, using the primary load path of the seat so that each cargo installation is restrained to the load factors specified in section 525.561 of the AWM and complies with all other applicable structural retention requirements and as per the aircraft manufacturers recommendations.

Seat primary load path elements include:

• a) the seat belt;
• b) the seat beams (cross tubes); and
• c) the seat legs.

Due to variables in the type of seat / aircraft design, the cargo restraint system, and the restraint system to aircraft interface points, the operator’s proposed cargo restraint system must be submitted to the POI for approval. The operator’s proposal must include the requested cargo weight per seat place, the proposed method of restraint, and the substantiation data that supports the request.

If the proposed cargo restraint system uses cargo nets to restrain the cargo items, these cargo nets should be CAN-TSO approved (or equivalent) and any load limitations of these nets including their attachment means should be adhered to. Any deformation of the nets due to the weight of the cargo items restrained under emergency landing, flight or ground loads should be evaluated for contact to other objects in the cabin and be shown not to block cargo access aisles nor emergency evacuation paths nor access to emergency equipment.

Cargo loaded on seats must be located so as to provide access to crew members to inspect the cargo security during flight, to inspect for smoke or fire during flight, and to enable firefighting procedures to find and fully extinguish a fire in the cargo. This may require that typical access to seats in the passenger configuration is retained, or may require that adjacent seat rows provide the necessary access. The operator’s risk assessment must consider that rapid detection and extinguishment of an in-flight fire is critical to the safety of the flight.

If the aircraft is a twin aisle, wide body aeroplane, the existing twin longitudinal aisle configuration with passenger seats needs to be retained and adequate lateral cross aisle access needs to be included to enable crew member access to cargo locations in the passenger cabin.

Appendix 2 – Fire extinguisher requirements

Fire extinguisher requirements are based on research conducted by the FAA Technical Centre Fire Safety Research Branch in the 1990‘s for cargo fires.

The fire extinguishers are identified for the foreseeable cargo loads and, thus, the fire threat. They shall be provided in a convenient and readily accessible area of the passenger compartment for firefighting duties. The fire extinguishers should be located near the seats for the additional crew members or at locations that the operator determines, as part of their risk assessment, to be most effective in providing fire protection. The fire extinguisher types are as follows:

• a) two Underwriters Laboratory (UL 2A - 2 1/2 gallon) rated water portable fire extinguishers, or an equivalent amount of water carried in no more than 5 containers,
• b) at least two fire extinguishers with a minimum UL 4A-80B:C rating or equivalent (note - four UL 2A-10B:C fire extinguishers are equivalent to the two fire extinguishers with a UL 4A-80B;C rating), and
• c) additional types and/or quantities fire extinguishers may be required based on the individual operator’s risk assessment for the planned flight operations.

Appendix 3 – Cargo restraint limitations for cargo loaded onto the passenger compartment floor

For configurations where passenger seats have been removed from the passenger compartment to transport cargo in the passenger compartment and load the cargo directly on the passenger compartment floor, the following applies:

• a) It is not required to install an additional 9.0g barrier and a smoke barrier to protect the flight deck and the additional crew members. The cargo shall be restrained so that each cargo volume installation meets section 525.561 of the AWM and other applicable structural requirements.
• b) In each section of the passenger compartment where cargo is transported:
  • i. a longitudinal aisle meeting the minimum width dimensions of 51 centimeters (20 inches) is required. For wide body aeroplanes that have twin longitudinal aisles in the approved passenger configuration, every effort should be made to retain those existing longitudinal aisle configurations in the “passenger seats removed” configuration. For smaller narrow body aeroplanes, the longitudinal aisle width in the approved passenger configuration may be less than 51 centimeters (20 inches). However, in the “passenger seats removed” configuration the longitudinal aisle shall not be less than 38 centimeters (15 inches) to ensure adequate access for cargo inspection and firefighting activities
  • ii. a lateral aisle to allow access to the fore and aft of each cargo load volume shall be at least 38 centimeters (15 inches)
  • iii. cargo should be loaded so that, for each individual cargo load volume, there is sufficient access to the cargo to allow effective firefighting. Sufficient access is intended to mean that an aisle is to be provided on all sides of each individual cargo load volume to allow effective detection of smoke and fire fighting. Some exceptions may be acceptable where cargo is loaded adjacent to the sidewall or windscreen; however, access to that side of the cargo is still required to allow for inspections the height of each individual cargo load volume shall not exceed 127 centimeters (50 inches) (approximately the height of a typical economy class seat)
  • iv. each individual cargo load volume shall not exceed 3.54 cubic meters (125 cubic feet)
  • v. limitations applicable to the mass, distribution and method of restraint of the cargo must be established based on guidance from the aircraft manufacturer as deemed necessary by TCCA
  • vi. for wide body aeroplanes, there must be a means to cross from one longitudinal aisle to the other either by cross aisles that existed in the passenger configuration or by additional lateral access aisles between individual cargo load volumes
• c) If the proposed cargo restraint system uses cargo nets to restrain the cargo items, these cargo nets should be CAN-TSO approved (or equivalent) and any load limitations of these nets, including their attachment means, should be adhered to. Any deformation of the nets due to the weight of the cargo items restrained under emergency landing, flight or ground loads should be evaluated for contact with other objects in the cabin and be shown not to block cargo access aisles nor emergency evacuation paths nor access to emergency equipment.

Contact office:

For more information concerning this issue, contact your Transport Canada principal operations inspector (POI).

Original signed by
Andrew Larsen
For

Director
Standards branch