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. The statements contained herein are based on good faith assumptions are to be used for general information purposes only. These statements do not constitute an offer, promise, warranty or guarantee o

April 2015

D. Noe| The Boeing Company
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OverviewIntermodal Container

• Background Information• FAA Memorandum• Review of testing efforts• Next Steps• NPRM Issued

Other Special Cargo LoadsSummary
Copyright © 2015 Boeing. All rights reserved. 

Intermodal Container Testing

Background Information

• Following the National Airlines Flight 102 747-400BCF accident in Afghani

became more active in reviewing Special Cargo Loads, and are now revieairline Weight and Balance programs

• FAA Senior Aerospace Engineer, Mr. Steve Fox, was engaged internally b

provide engineering review of the practices being utilized for Special Carg

• Field Inspectors began questioning the practice of transporting 8.5 ft tall in

containers by offsetting them from the edge of a 20 ft. pallet base, and the proximity of the intermodal container to the aircraft structure

• Upon review of the offset Intermodal container, several questions and issu

by the FAA regarding the ability of the TSO-C90 net to appropriately react the pallet at the net attach point locations in accordance with NAS3610/AS

• Without the proper tension the net is unable to react loads in the outboard dir

allowing the Intermodal container to shift in the outboard direction

• When using secondary restraint straps, how are the strap loads to the pallet t

cargo handling system

• The FAA also questioned the frangibility of Intermodal containers (not related 

concern)

• Based on these concerns the FAA released an internal memo outlining the
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Intermodal Container Testing

FAA Memorandum November 8, 2013

1. Sea-Land containers themselves are not a Unit Load 

Device (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 not requiring additional tie-down to the airplane.

2. Sea-Land containers are not frangible cargo, as defined in 

the Boeing 747 WBM Section1-00,001 which states frangible cargo consists of items "which will progressively conform to the airplane contour.“

3. A Sea-Land container, placed on a ULD pallet, offset from 

concentric loading by up to 9" laterally does not appear to meet the requirements of TSO C-90, as it does not meet 

the cg limitations of the freight/pallet combination, and the cargo net does not adequately restrain the container. In addition, when loaded in this fashion Sea-Land containers are not an overhanging load, they are an offset load. Such offset placed Sea-Land containers are to be tied down to the airplane in accordance with the Boeing 747 WBM section l-68-901. We are working with Boeing and operators on potential alternate approaches, and will notify you by memorandum should circumstances change.
Copyright © 2015 Boeing. All rights reserved. 

Intermodal Container Testing

Industry practice has been to use secondary restraint straps beneath the palprovide 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 intermodal container in the lateral outboard dire

has insufficient tension to resist movement of the container in the outboard direction

• How does restraint strap react load in the other load directions (even if only intended to provide late• Load application from secondary straps not part of TSO-C90
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Intermodal Container Testing

First Test Efforts - January 2014

• Boeing was invited to attend National Air Carrier Association (NACA) meet

June 2013 to support discussions regarding Special Cargo Loads on 747 f

• Testing was suggested by airlines during the November 2013 NACA meet

of demonstrating the practices being used at the time for transport of intercontainers were acceptable. 

• Test development team consisted of engineering personnel from three 747 

operators, 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 intermod

with a net only, no secondary straps used beneath the pallet net

• Video of this testing showed that the net did not restrain the intermodal co

(validating the FAA’s predicted result), and that the container could move idirection 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 confi

future testing focused on the use of restraint straps as the primary means container to the pallet
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Intermodal Container Testing

Second Test Effort - March 2014

• Team worked together to refine the test plan and establish pass/fail criteria • Intent was to develop an approved method to accomplish transport via offs

configuration

• FAA goal was to validate the load path of the intermodal container: Restra

pallet--to cargo handling system--to airplane floor structure; thereby, demoflight loads the container would not shift in a manner that would potentially aircraft structure

• Test plan utilized Ultimate Load requirements from AS36100 (ULD Configu

• 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 res• Test was intended to validate overall load path as requested by FAA

• Airlines developed test plan including test weight and strapping configurati• Airline engineering tests used to validate the test conditions of the test pla

confidence level for testing at maximum weights

• Several meetings were held with the team and FAA to ensure test readine
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Intermodal Container Testing

Issues Discovered during Second Test Effort

• FAA inspection at the test site found that the test setup was 

not ready and that the strapping configuration was not per the test plan

• Strapping configuration had been modified from previously 

tested 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 until 

testing began

• Test bed was a body section of 747 fuselage with the correct 

seat tracks and cargo hardware

• Two cranes performing vertical lift could not be synchronized to 

develop uniform load

• Test fixture was being rotated to 90 degree position to develop 

load

• Results of previous engineering tests could not be 

reproduced

• Container rotated on the pallet such that it would have contacted the interior frames of 

which was a test fail under previously agreed-to criteria

• However, several discoveries were identified that if addressed might lead to successfu• No test report written since issues with test configuration and implementation provided 

results
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Intermodal Container Testing

Third Test Effort - May 2014

• Working from lessons learned during second test effort

• A test fixture was designed by Boeing Tooling engineering which eliminated deflections 

that were occurring within the test fixture 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 would be necessary to restrain the pallet weight alone

• Developed operational method for determining lateral CG of container (which side of 

container centerline) which allowed the container to be loaded with its CG excursion in a direction opposite the 9” offset

• Boeing generated a new test plan based on discussions with the 

FAA

• Secured FAA agreement that AS36100 allows for Forward, Aft and Side loads to be 

combined with down load equal to 2/3 of forward load

• Developed incremental approach for test weights

Total Lateral or 

Longitudinal Test 

Weight (LBS.)

Longitudinal 

or Lateral 

Load (LBS.)

Download 

(LBS)

Corresponding 

Required Vertical 

UP Test Weight 

(LBS.)

15000 12508 8279 20847

25000 20847 13798 3474535000 29186 19318 4864345000 37525 24837 62541

Arrowindicateswhichside ofC/L CG islocated
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Intermodal Container Testing

Third Test Effort - May 2014

• Test Results

• Strapping plan was very sequence dependent and required an excessive amount of time to accomp• Passed Longitudinal and Lateral load cases (Ultimate load of 45000lb)• Passed Vertical test at 20847lb• Failed Vertical test at 62541lb

• Restraint straps used to limit deflections, concentrated loads on the inboard pallet edge rail, th

concentration resulted in failure of cargo handling system restraint (center guide) leading to a of multiple cargo restraints

• Post test review with airline concluded:

• Strapping scheme was too complex, resulting in concerns about repeatability and practicality i

• Strap configuration concentrated loads at the end of the pallet—needed method to transfer loa

pallet to middle of pallet to keep from overloading cargo restraints

• Decision made to not pursue a lower weight using fewer straps as airlines wanted full weight c

• Based on airline input that this strapping configuration was unacceptable for field use, 

ceased and no test report generated

Total Lateral or 

Longitudina--l Test 

Weight (LBS.)

Longitudinal 

or Lateral 

Load (LBS.)

Download 

(LBS)

Corresponding 

Required Vertical 

UP Test Weight 

(LBS.)

15000 12508 8279 20847

25000 20847 13798 3474535000 29186 19318 4864345000 37525 24837 62541
Copyright © 2015 Boeing. All rights reserved. 

Intermodal Container Testing

Next Steps

• Boeing is aware of additional testing being done by airlines and suppliers

• One airline is continuing with development of an improved strapping arrange

meet the test requirements and pass/fail criteria developed for third test efforbeen involved and is waiting invitation to witness test

• Several airlines are developing Supplemental Type Certification data packag

that would attach to the pallet and support carriage of the intermodal containeposition while also providing terminating locations for restraint straps and suparrangement that will meet the test requirements and pass/fail criteria develotest effort – Boeing has been involved in this development 

• One supplier is also developing a device that would attach to the pallet and s

of the intermodal container in the offset position while also providing terminatrestraint straps – Boeing attended testing, but is not actively involved in this d

• Boeing continues to work with the FAA to determine how to use one or all of t

and to obtain FAA approval
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Intermodal Container Testing

NPRM Issued December 3, 2014Required Action

Within 14 days after the effective date of this AD, revise the Operating Limitations section approved AFM to include the information in figure 1 to paragraph (g) of this AD. This may accomplished by inserting a copy of this AD into the Limitations section of the AFM.FIGURE 1 TO PARAGRAPH (G) OF THIS AD–AFM REVISION

Unless approved by the Manager of the Seattle Aircraft Certification Office, the carriage payloads is prohibited:

1) Intermodal containers nominally sized at 20 feet long, 8 feet wide, and 8.5 fenot concentrically loaded on a pallet and restrained to the aircraft in accordancapproved Weight and Balance Manual or Supplement.2) ISO 668-1CC containers that are not concentrically loaded on a pallet and raircraft in accordance with the FAA-approved Weight and Balance Manual or S

Note: Both payloads 1 and 2 may be concentrically loaded on a pallet and netted in accoFAA-approved Weight and Balance Manual and then loaded in the center of the airplane to the airplane by the approved center loaded cargo restraint system or restrained directlairplane, both as defined in the FAA-approved Weight and Balance Manual.
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Other Special Cargo Loads

In addition to the ‘Offset’ carriage of intermodal containers other pracreviewed by FAA include:

• Cargo restrained by straps to pallets without using a cargo net (e.g. vehicl

• restraint straps have potential to exceed airplane restraint component capabi

of 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 pal• Height of vertical CG, based on height of upper rack and carriage of 2 vehicle

weight

• Jet Engine Transport

• Many new transport stands utilize base plates that are not TSO-C90 pallets, 

intended to be restrained by cargo system

• Not covered by TSO-C90• Not covered by STC

• Pallet Couplers

• Coupled pallets not TSO-C90 approved configuration 
Copyright © 2015 Boeing. All rights reserved. 

Summary

• FAA has been reviewing industry practices associated with Special Cargo • Many current industry practices do not have supporting substantiation data• FAA is requesting data to cover specific practices associated with Special 

and to validate that these Special Cargo Loads are in alignment with TSO criteria, Cargo Handling system capability and aircraft structural capability

• Boeing efforts have been focused on finding ways to provide substantiatio

requested by the FAA in order to maintain capability and capacity of Boein

Regarding Intermodal Containers

• Boeing has been involved in developing test procedures for carriage of Int

containers on 747F aircraft with the airlines and FAA; however, testing has conducted by individual airlines

• No test reports have been generated due to inconclusive test results or de

longer pursue restraint strap configuration being tested

• FAA issued NPRM for carriage of intermodal containers on 747 Freighters 

cargo doors

• Boeing is aware of additional efforts being undertaken by airlines and supp

continues to work with the FAA to obtain approval
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