The 2nd revision of the Circular UOD-2020/2G (“the Circular”) regarding the transport of cargo in the passenger cabin of aircrafts is published on April 29, 2020, by the Directorate General of Civil Aviation (“DGCA”) as part of the measures taken against COVID-19 in Turkey. The purpose of the Circular is to enable the transportation of the medical equipment internationally and to protect the market place of Turkey with regards to the cargo transportation. By thus, the cargo transportation operations is permitted to be conducted without the approval of DGCA provided that the requirements specified in the Circular are met. Accordingly, the requirements for air operators conducting passenger transportation flights under SHY-6A Regulation and the requirements for cargo transportation in the passenger cabins are determined in the new Circular. Herein the new revisions will be provided respectively as follows;

Risk Analysis: The Circular brings forth requirements for air operators to conduct risk analysis as per the following specifications and monitor the compatibility of the foregoing within the management system of the air operator:

- Knowledge and experience of the air operator on cargo transportation,

- False or non declaration of confidential dangerous materials,

- Cargo leakage or spillage,

- Non fixed or incorrectly loaded cargo,

- False loading and unloading order,

- Operational weight and balance limit excess,

- The competence of ground personnel to prepare and load cargo,

- Improper packaging,

- Cargo Seat Bag (CSB) usage errors, if used.

Rules of Cargo Transportation:  Pursuant to article 5 of the Circular, new revisions were added to ensure flight safety by bringing prohibition of the transport of hazardous materials such as devices with Li-Ion batteries (computers, tablets, mobile phones, etc.) and cargo weigh limits and transportation rules.

- Cargo weight cannot exceed the structural loading limits of the plane floor or seats; 22.5 kg (50 lbs) per seat, 50 kg (110 lbs) single cargo per triple seat and 9 kg (20 lbs) per underseat.

- Cargo can be transported underseat provided that the underseat is designed to prevent the cargo from moving and the materials used to fix the load should not prevent visual inspection of the underseat cargo during flight. Further, cargoes loaded on the seats must be properly secured by restricting the cargoes from moving up, forward and sideways. Tools to be used for this purpose should be attached directly to the cabin floor seat rails while not distorting the main seat structure. In addition, fixing the cargo to the floor can be done using (E) TSO certified nets during the installation.  Any deformation that may occur in these nets due to the weight of the cargo during an emergency landing, during flight or on the ground, should be reviewed for contact with other objects in the cabin and it must be proven that the nets do not prevent emergency evacuation routes or access to emergency equipment.

- The responsible captain pilot should be informed of all cargo content using the cargo manifest or the Special Load Notification to Captain (NOTOC) or other relevant documentation. In addition, controls regarding pre-flight, during flight and pre-landing operating procedures within the scope of Article 13 of the Circular should be conducted and fulfilled by authorized personnel and cabin crew members and accordingly shared and recorded with the responsible captain pilot.

Operational Procedures: As per article 9 of the Circular, documents and checklists should be prepared by the air operator for ground and cargo personnel, flight and cabin crews that specify the rules and actions to be taken in case of emergency (especially firefighting) and entered into the handbook system by defining them as temporary revisions in the relevant manuals. The documents or checklists in question should include details of proper loading, positioning and fixing of the cargo before and during flight and before landing.

Equipment: As per article 10 of the Circular, additional oxygen systems (including portable oxygen cylinders and protective breathing equipment) and portable devices (including emergency locator transmitter, which are not required for aircraft occupants such as lithium batteries) in the cabin areas where the cargo is transported should be removed or disabled from the Passenger Service Unit without leaving any openings.

In addition, portable oxygen equipment must be provided for each cabin crew member. This equipment should be carried by cabin crew during on flight controls and appropriate protective clothing (eg fire gloves, etc.) should be stored adjacent to crew member stations. Standard safety and emergency equipment used in passenger configuration should be kept on board. The need for additional emergency equipment should be assessed by considering the cargo to be transported (eg estimated fire class), available equipment and type of operation, and their locations should be determined. And lastly, ventilation and pressurization systems should be adjusted by considering the nature of the load carried in the cabin, the number and distribution of the cabin crew and the emergency procedures that require the functionality of these systems.

Cabin Crew Responsibilities: Pursuant to article 12 of the Circular, before the flight or before the other flight series to be carried out, a pre-flight briefing for the type of operation and additional information required for the flight, including inactive equipment and abnormal situations should be given to the cabin crew by the responsible captain pilot.  Cabin crew should be familiar with the relevant procedures in the Quick Reference Manual on reducing the possibility of smoke entering the cockpit in the event of a smoke or fire in the cabin. Necessary controls must be carried out by the cabin crew at maximum 30 minutes intervals to ensure that the cargo is properly secured before the landing and whenever requested by the responsible captain pilot after the door is closed within the scope of the Article 5 of the Circular.

Reporting: Status reports regarding the operations carried out under the Circular will be submitted monthly to the e-mail address uodops@shgm.gov.tr indicating that the requirement under the Circular has been met.

 

Deniz Çelikkaya & Ezgi Aysima Kır