Copyright © 2015 Boeing. All rights reserved..The statements contained herein are based on good faith assumptionsare to be used for general information purposes only. Thesestatements do not constitute an offer, promise, warranty or guarantee of performance.BOEING1April 2015D. Noe| The Boeing CompanyCopyright © 2015 Boeing. All rights reserved.BOEING2OverviewIntermodal Container•Background Information•FAA Memorandum•Review of testing efforts•Next Steps•NPRM IssuedOther Special Cargo LoadsSummaryCopyright © 2015 Boeing. All rights reserved.BOEING3Intermodal Container TestingBackground Information•Following the National Airlines Flight 102 747-400BCF accident in Afghanistan, the FAAbecame more active in reviewing Special Cargo Loads, and are now reviewing all USairline Weight and Balance programs•FAA Senior Aerospace Engineer, Mr. SteveFox, was engaged internally by the FAA toprovide engineering review of the practices being utilized for Special Cargo Loads•Field Inspectors began questioning the practice of transporting 8.5 ft tall intermodalcontainers by offsetting them from theedge of a 20 ft. pallet base, and the resultingproximity of the intermodal container to the aircraft structure•Upon review of the offset Intermodal container, several questions and issues were raisedby the FAA regarding the ability of the TSO-C90 net to appropriately react loads back tothe pallet at the net attach point locations in accordance with NAS3610/AS36100•Without the proper tension the net is unable toreact loads in the outboard direction, potentiallyallowing the Intermodal containerto shift in the outboard direction•When using secondary restraint straps, how are the strap loads to the pallet transmitted to thecargo handling system•The FAA also questioned the frangibility of Intermodal containers (not related to net and strapconcern)•Based on these concerns the FAA released an internal memo outlining their conclusionsCopyright © 2015 Boeing. All rights reserved.BOEING4Intermodal Container TestingFAA Memorandum November 8, 20131. Sea-Land containers themselves are not a Unit LoadDevice (ULD), as defined in Technical Standard Order(TSO) c 90. When concentrically loaded on a pallet,properly shored and netted in accordance with the WBM,Sea-Land containers netted to pallets are ULDs notrequiring additional tie-down to the airplane.2. Sea-Land containers are not frangible cargo, as defined inthe Boeing 747 WBM Section1-00,001 which statesfrangible cargo consists of items "which will progressivelyconform to the airplane contour.“3. A Sea-Land container, placed on a ULD pallet, offset fromconcentric loading by up to9" laterally does not appear tomeet the requirements of TSOC-90, as it does not meetthe cg limitations of the freight/pallet combination, and thecargo net does not adequately restrain the container. Inaddition, when loaded in thisfashion Sea-Land containersare not an overhanging load, they are an offset load. Suchoffset placed Sea-Land containers are to be tied down tothe airplane in accordance with the Boeing 747 WBMsection l-68-901. We are working with Boeing andoperators on potential alternate approaches, and will notifyyou by memorandum should circumstances change.Copyright © 2015 Boeing. All rights reserved.BOEING5Intermodal Container TestingIndustry practice has been to use secondaryrestraint straps beneath the pallet net toprovide positional control of the intermodal container on the pallet base•FAA identified the following concerns with this practice:•Restraint strap is now providing primary restraint of intermodalcontainer in the lateral outboard direction, as the nethas insufficient tension to resist movementof the container in the outboard direction•How does restraint strap react load in the other load directions (even if onlyintended to provide lateral restraint)•Load application from secondary straps not part of TSO-C90Copyright © 2015 Boeing. All rights reserved.BOEING6Intermodal Container TestingFirst Test Efforts - January 2014•Boeing was invited to attend National Air Carrier Association (NACA) meeting’s starting inJune 2013 to support discussions regarding Special Cargo Loads on 747 freighter aircraft•Testing was suggested by airlines during the November 2013 NACA meeting as a meansof demonstrating the practices being used atthe time for transport of intermodalcontainers were acceptable.•Test development team consisted of engineering personnel from three 747 freighteroperators, the FAA and The Boeing Company•Test was run by an airline in consultation with other team members•Began with engineering tests to investigate restraint of the offset intermodal containerwith a net only, no secondarystraps used beneath the pallet net•Video of this testing showed that the netdid not restrain the intermodal container(validating the FAA’s predicted result), and that the container could move in the outboarddirection and potentially contact airplane cargo linings and frames•No test report was written for this engineering test•Based on this outcome, the net was eliminated from subsequent test configurations, andfuture testing focused on the use of restraintstraps as the primary means to restrain thecontainer to the palletCopyright © 2015 Boeing. All rights reserved.BOEING7Intermodal Container TestingSecond Test Effort - March 2014•Team worked together to refine the test planand establish pass/fail criteria for testing•Intent was to develop an approved methodto accomplish transport via offsetconfiguration•FAA goal was to validate the load path of the intermodal container: Restraint straps--topallet--to cargo handling system--to airplane floor structure; thereby, demonstrating underflight loads the container would not shift in a manner that would potentially damageaircraft structure•Test plan utilized Ultimate Load requirements from AS36100 (ULD Configuration G1)•Did not use AS36100 restraint conditions•Used restraint configuration applicable to 747 cargo handling system•Test was not intended to re-validate pallet base or cargo handling system restraints•Test was intended to validate overall load path as requested by FAA•Airlines developed test plan including test weight and strapping configuration•Airline engineering tests used to validate the test conditions of the test plan to ensureconfidence level for testing at maximum weights•Several meetings were held with theteam and FAA to ensure test readinessCopyright © 2015 Boeing. All rights reserved.BOEING8Intermodal Container TestingIssues Discovered during Second Test Effort•FAA inspection at the test site found that the test setup wasnot ready and that the strapping configuration was not perthe test plan•Strapping configuration had beenmodified from previouslytested configuration•No procedure to control lateral CG had been developed,resulting in LARGE lateral CG shifts being used for testing•Test set-up created issues that were not identified untiltesting began• Test bed was a body section of747 fuselage with the correctseat tracks and cargo hardware• Two cranes performing verticallift could not be synchronized todevelop uniform load• Test fixture was being rotatedto 90 degree position to developload•Results of previous engineering tests could not bereproduced•Container rotated on the pallet such that it would have contacted the interior frames of the airplanewhich was a test fail under previously agreed-to criteria•However, several discoveries were identified thatif addressed might lead to successful test result•No test report written since issues with testconfiguration and implementation provided inconclusiveresultsCopyright © 2015 Boeing. All rights reserved.BOEING9Intermodal Container TestingThird Test Effort - May 2014•Working from lessons learned during second test effort•A test fixture was designed by Boeing Tooling engineering which eliminated deflectionsthat were occurring within the testfixture used for first test effort•Airline developed a strapping plan that was designed to control the movement (rotation)of the intermodal container on the pallet. This resulted in many more straps than wouldbe necessary to restrain the pallet weight alone•Developed operational method for determining lateral CG of container (which side ofcontainer centerline) which allowed the container to be loaded with its CG excursion ina direction opposite the 9” offset•Boeing generated a new test plan based on discussions with theFAA•Secured FAA agreement that AS36100 allowsfor Forward, Aft and Side loads to becombined with down load equal to 2/3 of forward load•Developed incremental approach for test weightsTotal Lateral orLongitudinal TestWeight (LBS.)Longitudinalor LateralLoad (LBS.)Download(LBS)CorrespondingRequired VerticalUP Test Weight(LBS.)15000125088279 208472500020847 13798 347453500029186 19318 486434500037525 24837 62541CLISO1CCCLpallet9”offset9”offsetArrowindicateswhichsideofC/LCGislocatedCopyright © 2015 Boeing. All rights reserved.BOEING10Intermodal Container TestingThird Test Effort - May 2014•Test Results•Strapping plan was very sequence dependent and required an excessive amount of time to accomplish•Passed Longitudinal and Lateral loadcases (Ultimate load of 45000lb)•Passed Vertical test at 20847lb•Failed Vertical test at 62541lb• Restraint straps used tolimit deflections, concentrated loads on the inboard pallet edge rail, this loadconcentration resulted in failure ofcargo handling system restraint (centerguide) leading to a cascade failureof multiple cargo restraints•Post test review with airline concluded:• Strapping scheme was too complex, resulting in concernsabout repeatability and practicality in the field• Strap configuration concentrated loads at the end of thepallet—needed method to transfer load from end ofpallet to middle of pallet to keepfrom overloading cargo restraints• Decision made to not pursue a lowerweight using fewer straps as airlines wanted full weight capability•Based on airline input that this strapping configuration was unacceptable for field use, test effort wasceased and no test report generatedTotal Lateral orLongitudina--l TestWeight (LBS.)Longitudinalor LateralLoad (LBS.)Download(LBS)CorrespondingRequired VerticalUP Test Weight(LBS.)15000125088279 208472500020847 13798 347453500029186 19318 486434500037525 24837 62541Copyright © 2015 Boeing. All rights reserved.BOEING11Intermodal Container TestingNext Steps•Boeing is aware of additional testing being done by airlines and suppliers•One airline is continuing with developmentof an improved strapping arrangement that willmeet the test requirements and pass/fail criteriadeveloped for third test effort – Boeing hasbeen involved and is waiting invitation to witness test•Several airlines are developing SupplementalType Certification data packages for devicesthat would attach to the pallet and support carriage of the intermodal container in the offsetposition while also providing terminating locations for restraint strapsand support a strappingarrangement that will meet the test requirementsand pass/fail criteria developed for the thirdtest effort – Boeing has been involved in this development•One supplier is also developing a device thatwould attach to the pallet and support carriageof the intermodal container in the offset position while also providing terminating locations forrestraint straps – Boeing attended testing, but isnot actively involved in this development•Boeing continues to work with the FAA to determine how to use one or all of these methodsand to obtain FAA approvalCopyright © 2015 Boeing. All rights reserved.BOEING12Intermodal Container TestingNPRM Issued December 3, 2014Required ActionWithin 14 days after the effective date of this AD,revise the Operating Limitations section of the FAAapproved AFM to include the information in figure 1 to paragraph (g) of this AD. This may beaccomplished by inserting a copy of this AD into the Limitations section of the AFM.FIGURE 1 TO PARAGRAPH (G) OF THIS AD–AFM REVISIONUnless approved by the Manager of the Seattle AircraftCertification Office, the carriage of the followingpayloads is prohibited:1) Intermodal containers nominally sized at 20 feet long, 8 feet wide, and 8.5 feet tall that arenot concentrically loaded on a pallet and restrained to the aircraft in accordance with the FAAapproved Weight and Balance Manual or Supplement.2) ISO 668-1CC containers that are not concentrically loaded on a pallet and restrained to theaircraft in accordance with the FAA-approved Weight and Balance Manual or Supplement.Note: Both payloads 1 and 2 may be concentrically loaded on a pallet and netted inaccordance with theFAA-approved Weight and Balance Manual and then loaded in the center of the airplane and restrainedto the airplane by the approved center loaded cargorestraint system or restrained directly to theairplane, both as defined in the FAA-approved Weight and Balance Manual.Copyright © 2015 Boeing. All rights reserved.BOEING13Other Special Cargo LoadsIn addition to the ‘Offset’ carriage of intermodal containers other practices beingreviewedby FAA include:•Cargo restrained by straps to pallets without using a cargo net (e.g. vehicle transport)•restraint straps have potential to exceed airplane restraint component capabilities as a resultof uneven load distribution along pallet edge rail•Loading condition not covered by TSO-C90•Double stack car racks•resulting load distributions based on rigid connection of upper car rack to pallet edge rail•Height of vertical CG, based on height ofupper rack and carriage of 2 vehicles of sameweight•Jet Engine Transport•Many new transport stands utilize base platesthat are not TSO-C90 pallets, and are notintended to be restrained by cargo system•Not covered by TSO-C90•Not covered by STC•Pallet Couplers•Coupled pallets not TSO-C90 approved configurationCopyright © 2015 Boeing. All rights reserved.BOEING14Summary•FAA has beenreviewing industry practices associated with Special Cargo Loads•Many current industry practices donot have supporting substantiation data•FAA is requesting data to cover specific practices associated with Special Cargo Loadsand to validate that these Special Cargo Loadsare in alignment with TSO performancecriteria, Cargo Handling system capability and aircraft structural capability•Boeing efforts have been focused on findingways to provide substantiation beingrequested by the FAA in order to maintain capability and capacity of Boeing 747FRegarding Intermodal Containers•Boeing has been involved in developing testprocedures for carriage of Intermodalcontainers on 747F aircraft with the airlines and FAA; however, testing has beenconducted by individual airlines•No test reports have been generated due to inconclusive test results or decision to nolonger pursue restraint strap configuration being tested•FAA issued NPRM for carriage of intermodal containers on 747 Freighters with sidecargo doors•Boeing is aware of additional efforts being undertaken by airlines and suppliers, andcontinues to work with the FAA to obtain approvalCopyright © 2015 Boeing. All rights reserved.BOEING15