How to transport cargo in the aircraft cabin during COVID-19 outbreak?

Reference: 00.00.00370 Issue date: 06-APR-2020 Last check date: 06-APR-2020 Status: Open
A/C type/serie: A300, A300-600, A310, A318, A319, ... ATA: 00-00
Engine manufacturer: Supplier:
Purpose / Reason for revision: Creation
Flight Operations and Training Status: Open Modification on Operational Impact: NO

Applicability:

References:

General Overview
Due to the COVID-19 crisis, the passenger transportation by air has drastically decreased. In the meantime the demand for cargo transport rapidly
increases.
Combined with the natural cargo capabilities of the Airbus aircraft, the passenger compartments offer a significant additional loading capacity for pure
cargo operations.

Airbus published general guidance for the transport of cargo in the cabin in the FOT 999-0028-20-01, clarifying the Airbus position on four possible
situations:

 Operators willing to transport freight in existing approved cabin areas

Existing certified cabin areas (under the seats, luggage compartments) offer approximately 4T of extra-transport capability on A320 and 10T on
A350.
It does not require any approval. Operation can be started immediately.
  Operators willing to transport medical supply on passengers seats in relation with Covid-19
The transport of cargo on passenger seats requires a major change to aircraft type certificate or an STC. However national authorities can grant
exemptions. EASA issued guidelines for exemptions under Article 71(1) of Regulation 2018/1139 valid for the duration of the crisis and not to
exceed 8 months. Exemption allowing to consider transport on seat as minor change is limited to the transport of medical supplies.
In addition to the information already available in the FOT 999-0028-20-01 and in this ISI article, Airbus provides on demand via Techrequest the
additional information to apply for exemption.

 Operators willing to transport non-medical supply cargo on passengers seats

The transport of cargo on passenger seats requires a major change to aircraft type certificate. In the Covid-19 crisis context, EASA committed to
process Major Change or STC application with priority.
Several STC already exist on the market. Operators are reminded that such operation could generate significant cabin tear and wear.

 Operators willing to transport any cargo after seat removal

The removal of seats to allow fixation of cargo onto the aircraft structure requires a major change to aircraft type certificate or an STC.
Airbus launched a task force in order to deliver an option for a service bulletin offering a quick solution. This service bulletin will be made available
in the coming days.

The Operational aspect of such ad-hoc operations requires to review and adapt the crew procedures and the load control process.

In addition, this article provides answers to Frequently Asked Questions relative to the transport of Cargo in cabin.

Question
How to transport cargo in the cabin during COVID-19 outbreak?

Answer

1. CREW AND PROCEDURES

The Operator must demonstrate that the crew and the cabin procedures are adapted for the transport of medical supply, while no passenger is on board.
1.1 CREW COMPOSITION:

Who is a ‘crew member’?:

As per EASA’s guidelines below:
3.1 Crew composition
a) Operations without passengers shall still require one or more crew members to survey and access all areas of the cabin during
all phases of flight. Any fire that might occur must be discovered and extinguished immediately utilizing existing emergency
equipment.
Airbus’s interpretation of ‘crew members’ refers to airline personnel who are trained or who could be trained with airline procedures in handling
normal and abnormal/ emergency operations in the cabin.

To be taken into account, the ‘crew member’ must be able to:

- conduct preflight/pre landing checks of both the emergency equipment and securing of cabin,
- pass the “cabin ready” notification,
- correctly secure the cabin in preparation for taxi, take-off and landing (TTOL) or upon the instructions of the operating flight crew,
- correctly use the cabin attendant seat (CAS),
- provide communication to the operating flight crew by any means, such as the use of the interphone/ PA system,
- effectively fight fires according to published procedures and have knowledge of the cabin electrical power supply,
- apply turbulence procedures if applicable,
- apply depressurization procedures if applicable,
- locate and utilize emergency equipment,
- conduct an evacuation, inclusive of door and slide operation.

1.2 MINIMUM CREW REQUIREMENT:

Based on the EASA guidelines; 3.1 (a)‘Operations without passengers shall still require one or more crew members to survey and access all areas of the
cabin during all phases of flight.’
In addition, as per EASA’s guidelines; 3.1 (a) ‘Any fire that might occur must be discovered and extinguished immediately utilizing existing emergency
equipment.’
Airbus recommends the minimum number of 2 crew members for the purpose of firefighting. This is based on an adaption of the firefighting roles:
Standard firefighting procedures are based on 3 roles:
1. fire fighter,
2. assistant fire fighter and
3. communicator

In order to mitigate minimal disruption to the existing firefighting roles and to maintain the firefighting efforts, Airbus recommends to have 2 crew members with the
following roles:
1. fire fighter
2. assistant fire fighter and communicator

Therefore the process in firefighting roles and firefighting remains unchanged as per the CCOM abnormal procedures (reference material; CCOM 14-20 Firefighting).

The benefit of combining the existing firefighting roles:

- Minimize or result in no additional training,
- Existing cabin crew are already proficient in firefighting procedures,
- Minimize updates of airline cabin crew manual.

Maintaining the presence of 2 crew members, enables effective task sharing and effective CRM amongst the team.

1.3 CABIN ATTENDANT SEAT (CAS) TO BE UTILIZED FOR TAXI, TAKE-OFF AND LANDING (TTOL):

The Airbus recommendation is for the following utilization of CAS for the flight:
Twin aisle aircraft:
Door 1 Left (1L) and Door 1 Right (1R)

Single aisle aircraft:

Door 1 (1L)

However instructions of alternate CAS may be defined by the pilot in command in compliance with company procedures.

The benefit of using the forward cabin attendant seats are as follows:
- ease of crew coordination,
- communication simplified to the forward area,
- minimizing post evacuation duties for a cabin inspection,
- vital emergency equipment located within this area, such as crash axe and ELT.
In the case of an aircraft that may be dispatched with inoperative slides/sliderafts, the location of CAS and attached slide/ sliderafts to be used for TTOL
may be redefined and instructed to the operating crew members as necessary.

1.4 CCOM PROCEDURES UPDATES/ AMENDMENTS:

The CCOM will not be updated and all normal and abnormal/ emergency procedures remain unchanged.
However the exception is the attribution of firefighting roles as documented above and the allocation of preflight checks.
Airbus recommends the following tasks to be equally distributed amongst the 2 crew members:
- preflight checks of the entire emergency equipment, and
- securing of the cabin for TTOL.

1.5 REQUIRED EMERGENCY EQUIPMENT:

As per EASAs guidelines and Airbus FOT (999.028/20) existing emergency equipment should be utilized.
In addition, equipment access should not be obstructed by any cargo.
The benefit of utilizing existing emergency equipment is as follows:
- no change to location, equipment evenly distributed throughout the cabin,
- location already documented within the CCOM for reference if necessary,
- no training for crew members on new locations for emergency equipment,
- knowledge and usage of emergency equipment remains unchanged by the trained crew members.
The cargo load should be able to be extinguished with the existing firefighting equipment as per the EASAs guidelines:
3.3.a) The operator shall load the aircraft considering the different levels of available fire protections of the loading areas.

1.6 GENERAL CABIN GUIDELINES:

The following guidelines may provide further assistance in the operation of cargo transportation within the passenger cabin:

Electrical loads;
Electrical loads in the cabin and galleys must be minimized during all flight phases. Therefore all passenger seat power must be turned off via the PAX
SYS pb on the FAP or via the IFE terminal or via the cockpit panel.
Prior to turning off the passenger seat power, ensure all electrically operated seats are in the TTOL position (reference: CCOM 13-060 “cabin crew safety
related duties during taxi before take-off”).
Power of galleys that are not in use should be turned off.
Galley and Lavatory usage;
Airbus recommends to utilize the fwd galley and fwd lavatory only (based on the cabin occupant seating arrangements).

Monitoring of cabin;
All galleys, lavatories and cabin areas must be monitored during regular intervals (reference: CCOM 13-060 “cabin crew safety related duties during
cruise”). This is to ensure that there is no risk of smoke/fire in any of the areas and all cargo items remain restrained.
As per CCOM 13-060, Airbus recommends that monitoring of the cabin should be conducted approximately every 15 mins.

2. MMEL ADDITIONAL RELIEF

Additional temporary relief can be given for inoperative slides. Airbus can provide relief under certain conditions via an "Approved Deviation to OSD-
MMEL" (ADOM), to be requested by Techrequest.

3. LOAD CONTROL

The Operators have a specific trim sheet (paper Trim Sheet (T/S), AHM 560/565, Flysmart+ Loadsheet) associated with the current cabin layout of the
aircraft and their current assumptions.
When there are no passengers on board, the cabin may be used to transport cargo.
In this case, is it possible to use the current trim sheet and how do you proceed?

The EASA provided guidance for the determination of the weight and CG of the cargo loaded in the cabin (Guidelines: Transport of Cargo in Passenger
Compartment - exemptions under Article 71(1) of Regulation 2018/1139 (the Basic Regulation)).

3.1 HOW TO USE THE CURRENT TRIM SHEET?

3.1.1 TRANSPORTATION OF CARGO IN THE APPROVED STOWAGE LOCATIONS OF THE CABIN AND ON THE PASSENGER SEATS.
First of all, the calculation of the aircraft Centre of Gravity (CG) at Zero Fuel (ZF) and at takeoff (TO) in the current T/S is based on scales or tables. The
CG impact of the loading of passengers is done by section (OA, OB,etc…). This way of working is not suitable for the loading of cargo in the cabin.

It means that the way to calculate the CG impact in the cabin of the current paper trim sheet cannot be used any more.
The Zero Fuel weight and CG should be calculated either manually or with a Departure Control System (DCS).

For the DCS, the easiest way would be to check with the DCS provider the availability of an appropriate functionality.
If the DCS cannot manage the loading of cargo in the cabin, you have to do the calculation manually (Refer to chapter Loading template below).

Consequently, the determination of the operational margins on the current T/S are based on the following:
The passenger loading scenario: The passengers are seated first on the windows seats then on the seats adjacent to the aisle and finally on the center
seats.
The average weight of the passengers.
The cabin sections.
The in-flight movements in the cabin.
The current operational margins can be used provided the weight and CG impact of the cargo in the cabin is known accurately.

Weight impact
The weight of the cargo must be provided with the highest possible accuracy. To achieve that, the cargo should be weighed.
Extract EASA Guidelines: Transport of Cargo in Passenger Compartment - exemptions under Article 71(1) of Regulation 2018/1139 (the Basic Regulation)
Exact cargo weight and position in the cabin and in the cargo hold shall be reflected in the mass and balance documentation (load sheet).

Additionally, the limitations below applies:

The weight on each individual seat should be less or equal to 77 kg (170 lbs).
The weight under the seat should be less or equal to 9kg (20 lbs).
The weight in the approved stowage locations should comply with the limitation given in the Chapter CTL-LIM-CAB Cabin and CTL-INTA Interior
arrangement of the WBM.
The weight limitations of the Overhead Stowage compartment (OHSC) should comply with the limitation given in the chapter CTL-INTA-Overhead
Stowage Compartment of the WBM and the limitation provided in the individual placard of the OHSC in the aircraft.

CG impact
The general formula used to calculate the CG is the following:
𝐶𝐺 = ∑(𝑊𝑒𝑖𝑔ℎ𝑡 𝑥 𝐶𝐺 ) / ∑𝑊𝑒𝑖𝑔ℎ𝑡
𝑖
𝑖 𝑖
𝑖
𝑖

With Weight = weight of each loaded item

CG = Center of Gravity of each loaded item

Approved stowage locations

The operator calculates the CG impact with the following:
The weight loaded inside the galleys.
The weight loaded inside the stowage units.
The weight loaded inside the OHSC.
The CG location of the galleys and stowage units is given in the chapter CTL-INTA Interior arrangement of the WBM.
The CG location of the OHSC. In the chapter CTL-INTA-Overhead Stowage Compartment of the WBM, only the H-arm of the beginning and the end of
the complete OHSC is provided. In that way, the OHSC should be empty or full and uniformly loaded in order to be able to accurately calculate the CG
location.

For a more accurate calculation, the main characteristics of the OHSC (dimensions, maximum load, volume…) are available in the Cabin Configuration
Guide (CCG) for each program, in the chapter 25-24. The CCG is available via Airbus world-->CDIS-->Standard Offer-->Configuration Guide-->Cabin
Configuration Guide.
 Stowage under the seats and on the seats
The Operator must know the weight, per row, of the cargo located on the passenger seats and under the seats.
The chapter CTL-PERS Passenger of the WBM provides the CG location of the seat row.
The CG impact is calculated for each seat row. The individual CG impacts are combined to provide the total CG impact of the cargo on the passenger seats.

3.1.2 TRANSPORTATION OF CARGO ON THE PASSENGER COMPARTMENT FLOOR AFTER THE REMOVAL OF THE SEATS.

The aircraft is not certified for the transport of cargo on the cabin floor.
The airline can operate under the following conditions:
Request for an Service Bulletin (SB) from Airbus, or
Request for an exemption certificate from their authorities, or
Apply their own Supplemental Type of Certificate (STC)

The current T/S must not be used. But the operational limits can remain the same provided the Operator knows accurately the weight and the CG impact
of the cargo on the pax compartment floor. An associated specific trim sheet should be calculated.
Should you need a new Trim Sheet (T/S) please contact Navblue at flightops.trimsheet@navblue.aero

3.2 FLYSMART+

There is no specific option for the customization of Flysmart+ Loadsheet in the following cases:
Cargo on the passenger seats, under the seats, in the approved stowage locations,
Cargo on the cabin floor compartment.
It is not possible to enter the cargo loading information in the current customization with the PAX cabin zoning.

There are two choices:

3.2.1 The Operator uses Flysmart+ Loadsheet in the REDUCED mode.

The inputs are the ZFW and ZFCG. The ZFW and ZFCG must take into account the impact of the cargo loaded in the cabin that is manually calculated
prior to the use of Flysmart+ (refer to chapter 1 above).

In order to be able to select the REDUCED mode in Flysmart+ Loadsheet, the Operator must select, in the user interface options customization, “enabled”
for the “Entry Mode Selection”.
Should you need assistance, please contact Navblue at DL-FlySmart-Support@navblue.aero

3.2.2 The Operator uses Flysmart+ Loadsheet in a DETAILED mode

The Operator must enter no pax in the cabin zoning. The cargo loaded in the cabin must be entered as MISCELLANEOUS items. The associated weight
and H-arm must be accurately known.

Note: The miscellaneous items are added to the Dry Operating Weight (DOW) and CG for the calculation of the ZFW and CG. The miscellaneous items are
not part of the payload.
Should you need assistance, please contact Navblue at DL-FlySmart-Support@navblue.aero

4. FAQ

3.1 CABIN OPERATIONS

3.1.1 Who are the crew?

Trained crew are airline personnel such as pilots/ cabin crew/ maintenance crew, who have undergone airline emergency training. The airline training
should include:fire fighting management/ evacuation pre and post management/ communication management/ decompression
management/emergency equipment usage and knowledge of their locations, as well as door and slide operation.

3.1.2 What is the minimum required cabin crew and will additional training be required?

As per EASA guidelines, a minimum of 1 crew is to be present within the cabin. Airbus is currently conducting a risk assessment on the minimum required
crew with regards to fire fighting roles. Current procedure on passenger aircrafts calls for 3 crew members. Airbus is proposing a slight modification to
the procedure to allow for 2 crew members( 1 firefighter and 1 assistant firefighter/communicator). So, we are looking at a minimum of 2 crew.
Therefore based on the utilization of current procedures with minimal adaptation we cautiously anticipate no additional training is required for current
crew who have current flying licenses.
This answer is based on the transport of ONLY cargo within the passenger cabin and does not address the operation of a combined passengers and
cargo operation.

3.1.3 What is the required emergency equipment?

There is no plan to have additional equipment loaded as the current emergency equipment and layout should be utilized. Please refer to EASA guideline
3.1 (a).
However please note that the cargo being transported must be compliant with the type of extinguishers onboard.
EASA’s Guideline 3.1 (a); Any fire that might occur must be discovered and extinguished immediately utilizing existing emergency equipment.

3.1.4 Will the CCOM be updated/ changed?

Airbus does not plan to update the current CCOM as the procedures that are documented within Abnormal procedures may be utilized.
However the cabin operations team are proposing the merge of the fire fighting roles from 3 crew to 2 crew( 1 firefighter and 1 assistant/ communicator).
As a result, all “updated” information and further guidelines will be communicated to the operators in the coming day(s).

3.1.5 Will additional cabin guidance be provided?

The cabin operations department is currently reviewing a set of guidelines for such adhoc operations and these will be communicated in the coming
day(s).
Could you please advise the Cabin Temperature and Pack AIR FLOW setting?
It will be the airline to determine the cabin temperature based on the items that are to be transported in the cabin and the number of occupants within
the cabin.
EASA guideline 3.3 (q); The Air Conditioning system shall be set taking into account the nature of the cargo transported in the cabin and the number and
distribution of cabin occupants.

3.1.6 Will Airbus approve / accept our procedures and changes made which will help facilitate DGCA approval ?

This is the role of the local aviation authority. However Airbus will provide cabin operational guidance material in order to assist the operator in
obtaining approval from the National Aviation Authority.

3.1.7 Can we block emergency exits with cargo?

As per EASA guidelines and Airbus FOT, aisles and emergency exits should be left unobstructed.
From a certification perspective: It is possible, as part of the exemption process as well as part of a permanent design approval, to deviate from the
compliance demo of JAR25/CS25 certification paragraphs for certification of emergency evacuation, if it is demonstrated that with the number of crew
and supernumeraries on board, including their distribution in the cabin, safe evacuation of the aircraft is possible without making use of all emergency
exits of the aircraft.
EASA’s guidelines 3.3 (i) a) The cargo stowage location shall be such that, in the event of an emergency evacuation, it will not hinder aisle access and
egress.

3.1.8 How to make sure that the depression procedure for all the flight crew including cabin, especially for A330?

The decompression procedure within the CCOM and the FCOM will remain unchanged. Therefore the cabin occupants should adhere to current
procedures and the additional information made available by Airbus for the exemption process.

3.1.9 In case that medical supplies are transported (e.g. masks) in the overhead stowage bins, do we have to brief the on-board crew members?
The transportation of cargo within the overhead lockers is not uncommon. All operating crew should be informed of any items being carried for cargo
transportation.

3.1.10 When you talk about crew for firefighting, who are you referring to?

Trained personnel/ crew - such as pilots/ cabin crew/ maintenance - those that have undergone the airlines normal/ abnormal/emergency procedures
training.

3.1.11 I have a question about O2 containers. Since cabin crew or supernumeraries will take place on board, loading should be made in order to function
of O2 container flaps. For that reason, it should be noted in projects or loading manuals to be functional in flight during emergencies. Is that right?

Existing Emergency equipment should be used, therefore no additional oxygen bottles are necessary. With respect to oxygen containers and accessibility,
they must be available to crew on board, and not be obstructed due to cargo loading in the cabin, to fulfill the intent of 25.1443.

3.1.12 Will dangerous goods be allowed?

Not in the passenger cabin.

EASA’s guideline 4.1 (d); Dangerous goods shall not be carried in the passenger cabin and always be carried in the hold and shall be transported under the
conditions established by the Technical Instructions.

3.1.13 Will there be a fire suppression detection system?

Not in the passenger cabin.

3.2 AIRCRAFT WEIGHT & CENTER OF GRAVITY CALCULATION

3.2.1 In the case of transport of cargo on the seats and in the approved stowage locations, can I still use my current trim sheet designed for the transport
of passengers in the cabin?

Your current paper trim sheet cannot be used as it is. The EASA requires that the weight and the CG impact of the cargo in the cabin are accurately
known. Refer to §3 for more information.
3.2.2 Is the Load and Trim Sheet (LTS) software able to produce the trim sheet when the seats are removed?

No, the LTS software does not permit to produce the trim sheet when the seats are removed.
Refer to §3 for more information.

3.2.3 Is it possible to convert the cargo located on the pax seats into a number of passengers?

Based on the EASA requirement received on April 1st, it is not possible to convert the cargo weight into a number of passengers. The EASA requires that
the weight and the CG impact of the cargo in the cabin be accurately known.

However, operators willing to use this solution must coordinate with their local regulatory authority to ensure the compliance with the applicable
regulatory restrictions.

3.2.4 Does the Operator need to re-weight the aircraft after the removal of the seats or it is enough to manage the change by calculation?

The re-weight of the aircraft is not mandatory. However, If the Operator wants to remove seats and if the DOW modification exceeds ± 0.5% of the
maximum landing weight or the DOCG modification exceeds 0.5% of the Mean Aerodynamic Chord (MAC), the operator shall re-establish the DOW and
DOCG:
By weighing, or
By calculation, if the operator is able to provide the necessary justification to prove the validity of the selected method of calculation.

3.3 LOADING IN APPROVED LOCATIONS

3.3.1 Which are the stowage locations approved to transport cargo in the Cabin?

The approved stowage locations to transport the cargo in the cabin are :
- overhead stowage bins,
- stowage compartments which are not dedicated to emergency equipment,
- floor mounted stowage (e.g. doghouses),
- bulkheads that have a placard indicating maximum capacity,
- under seat stowage areas.
3.3.2 Can we use the galley space for cargo without using the cart ?

No, the cart compartments are designed to restrain the carts only.
However, it is allowed to load cargo into the carts.

3.3.3 What is the restraint bar system for loading cargo under the seat?

The restraint bar is usually part of the seat assembly, it is the bar already present below the seat to prevent forward and sideward movement. Note that
the loading of the cargo under each seat place should not exceed 9 kg (20 lbs).

3.3.4 Are there any additional restrictions on the carriage of Dangerous Goods in the hold due the fact of carrying cargo in the cabin?

For dangerous goods transportation on the holds, the current limitations for the cargo hold apply. This does not change with cargo in the cabin. Please
note that no dangerous goods are allowed in the cabin.

4.3 LOADING ON THE SEATS

3.3.5 Is it necessary to use seat bags?

It is not mandatory to use seat bags. It is only mandatory to ensure that the cargo is well fastened so that it cannot shift out of its location in any
direction.
It is further recommended to protect the seats when cargo is put on the seats.

3.3.6 Are there cargo seat bags on the market already?

Airbus is aware that there are a number of companies that offer special bags designed for the carriage of cargo in the cabin.
They can be a good turnkey solution for operators but, as stated by EASA (apart from the exemption cases) the cargo transport on seats is a major
change with regards to airworthiness. Therefore such systems need to be approved by National authorities / EASA for use in aircraft.
An approval through an STC or a Major change must be provided to enable the use in the long term.

3.3.7 Can we only carry medical supply ?

In order to operate a cargo flight with load on seats a major MOD or an STC must be approved by the airworthiness authorities.
As an exception to the above rule, the Operator may request an exemption of the major MOD approval to its National Airworthiness Authority.
The EASA has precised that such exemption is only acceptable for the transport of medical supply during the COVID-19 crisis.

Other cargo may be transported provided that an approved solution is used. Some products (cargo seat bags) may be approved for such usage. To be
checked with the product manufacturer/STC holder.

Non-medical supply could be carried in the overhead bins, below the seats or in the galleys while medical supply is on the seat.

3.3.8 Are there any recommended methods to fix the cargo on the seats?

Airbus is working on guidelines for the restraint of cargo on the seats. These guidelines can be used for the request in exemption for the transport of
medical supply.
Such material will be available in the coming days.

For permanent transport in the frame of an approval via an STC or a Major change, the method of restraining and restraint equipment will form part of
the approval.

As STC solutions already exist on the market Airbus has currently no plan to develop such solutions.

3.3.9 Which are the weight, CG and volume constraints of the cargo to be transported on the seats?

The loads transmitted to the seat must be within the certification limits of the seat, the loading on each seat should not exceed 77 kg (170 lbs) and the
vertical center of gravity (CG) of the cargo must be equal to or lower than the passenger CG of the seat.

The size of the cargo item shall be such that it cannot interfere with the aircraft systems (decompression panels) with the crew needs (free pathways, no
obstruction in case of evacuation).The cargo should not be such that it could damage the aircraft interior.

3.3.10 Do we have to seek approval from the seat manufacturer to put cargo on the seat?

As part of the exemption process, the seat manufacturer approval may not be required.
For the development of a permanent solution, the STC holder may need to get information from the seat manufacturer in order to demonstrate that the
solution is airworthy. A permanent, approved solution should however be independent of the individual seat design and stay within the limits of the
aircraft design.

3.3.11 Can the cargo be loaded in a reclined seat?

No, as it is not certified for takeoff and landing in that configuration.

3.4 LOADING ON FLOOR

3.4.1 What will be the Airbus solution?

Two solutions are investigated:

Transport cargo directly on the floor; cargo restrained to the seat tracks. Simple but may include the certification of nets for restraint because nets are
only approved for installation on a pallet.
Installation of pallets fixed to the seat track. Then cargo can be loaded onto the pallet and simply restrained with usual nets (already certified nets)

3.4.2 Can we carry passengers and cargo in the cabin compartment on the same flight? Is it possible to remove only partial seats for cargo load and
use the remaining seats for passengers?

A mix of fare-paying passengers and cargo is not part of the exemption process. This solution requires an STC/major change and is not under
investigation by Airbus.

3.4.3 If we don't want to wait for an Airbus solution. What can we do?

Another solution requires the development of an STC. The Operator should seek a third party company able to develop an STC solution.
3.5 AIRWORTHINESS GENERAL

3.5.1 If I want to transport only medical supplies, do I need a minor or major modification package?

No modification is required for transport of medical supplies on seats during the COVID-19 crisis. The EASA supports such exemption (by making use
of Article 71 of the Basic Regulation) for the transport of medical supply, so that only medical supply can be transported easily.

A supplemental type certificate (STC) is required for other cargo transportation and a major modification/STC is required for any other method of cargo
transport on the cabin floor with seats de-installed.

3.5.2 Some medical equipment can be considered as dangerous goods, such as portable oxygen concentrators. Can it also be carried on the passenger
seats without a STC ?

If the medical supplies are identified as dangerous goods, they have to be transported in the cargo hold. Dangerous goods shall not be carried in the
passenger cabin and always be carried in the hold. Refer to ICAO Dangerous Goods definition.

3.5.3 What is the difference between transporting medical supplies and other general commodities?

A question has been raised by Airbus to EASA. EASA considers that the transport of non-medical supplies on seats could fall under the exemption
process ; on a case by case basis:

“The use of article 71 for transportation of any other kind of cargo will have to be discussed on a case-by-case basis, with chances to success that will depend
on the level of control that can be expected on the cargo and the level of fire risk posed by the transported cargo items”

3.5.4 Do we need to have the agreement of all certification authorities that we fly to or do we need only EASA approval?

No, you need only the approval of the National Aviation Authority where the aircraft is registered.

3.5.5 Does the operator need to modify all operational documents?

The operational documents are not modified in the context of carrying cargo in the passenger cabin, so no update is necessary.
3.5.6 Can Airbus provide Master Minimum Equipment List (MMEL) additional relief for some specific conditions due to the COVID situation?

Yes, additional temporary relief can be given for inoperative slides. Airbus can provide relief under certain conditions via an "Approved Deviation to
OSD-MMEL" (ADOM), to be requested by Techrequest.

3.5.7 Are ETOPS operations affected if we transport cargo on passenger seats ?

ETOPS is not affected as such by cargo transportation on passenger seat. ETOPS regulations and operational considerations still apply.

3.5.8 Can Airbus provide additional documents to support the local aviation authority exemption?

Should you need more information to prepare the exemption dossier, please open a request through Techrequest

3.5.9 Are there any foreign airworthiness authorities who are in discussion with Airbus on this topic? Is there alignment between EASA and FAA on
requirements for this type of operations?

Airbus is discussing with the FAA. EASA and FAA are currently discussing the topic bilaterally. Communication between the OEMs, EASA and FAA is
ongoing. The International Coordinating Council of Aerospace Industries Associations (ICCAIA), and more precisely the Cabin Safety Working Group
(CSWG) will provide an additional forum for this.

3.5.10 Is there any collaboration across the OEM using ICCAIA?

Under the umbrella of the ICCAIA, there is a Cabin Safety Working Group (CSWG) maintained by the aircraft manufacturers. The International
Coordinating Council of Aerospace Industries Associations (ICCAIA), and more precisely the Cabin Safety Working Group (CSWG), under the umbrella of
ICCAIA, will provide an additional forum for the collaboration between the OEMs and the Agencies.

3.6 FOLLOW UP QUESTIONS

3.6.1 When is Airbus expecting to provide more information on an approved fast-track solution, including applicable procedures and documentation for
loading on the seats? Is it going to be a SB?

Apart from the FOT revision of the 6th of April and this ISI article, additional technical information needed for enabling the transportation of medical
items (such as the cabin seat track loading limitations) should be requested Through Techrequest on AirbusWorld.
3.6.2 When is Airbus expecting to provide more information on an approved fast-track solution, including applicable procedures and documentation for
loading on the floor? Is it going to be a SB?

The solution is still under development. The availability date of the Service Bulletins (SB) for each aircraft family will be provided in the coming days

3.6.3 How much is this fast-track solution for loading on the floor going to cost?

Due to the COVID19 crisis Airbus understands that this extra cargo capability is important for our customers. In this context, Airbus is preparing a
commercial policy that reflects this status and the commitment of Airbus to accompany his customer during the crisis. It will be available by 10th of Apr.

Survey for the Flight Operations and Training section

 Annex

General Information
Potential impact: Airworthiness, Specific Operations - ETOPS/EDTO/Others
Key information:
Solution benefit:
First issue date: 06-APR-2020 Issue date: 06-APR-2020 Last check date: 06-APR-2020

Technical parameters
ATA: 00-00
A/C type/serie: A300, A300-600, A310, A318, A319, A320, A321, A330, A340, A350, A380, AST
Engine:
Engine manufacturer:
Fault code/ECAM
warning:
FIN:
Part Number:
Supplier:

Attachments
N/A

Links
N/A

© Airbus SAS, 2020. All rights reserved. Confidential and proprietary document.The technical information provided in this article is for convenience and information purposes only. It
shall in no case replace the official Airbus technical or Flight Operations data which shall remain the sole basis for aircraft maintenance and operation. These recommendations and
information do not constitute a contractual commitment, warranty or guarantee whatsoever. They shall not supersede the Airbus technical nor operational documentation; should
any deviation appear between this article and the Airbus or airline's official manuals, the operator must ensure to cover it with the appropriate document such as TA, FCD, RDAS.
Access to WISE is supplied by Airbus under the express condition that Airbus hereby disclaims any and all liability for the use made by the user of the information contained in
WISE. It shall be used for the user's own purposes only and shall not be reproduced or disclosed to any third party without the prior consent of Airbus.
CUSTOMER SERVICES DIRECTORATE
2 ROND POINT EMILE DEWOITINE
31700 BLAGNAC FRANCE
TELEPHONE + 33 (0)5 61 93 33 33

FLIGHT OPERATIONS TRANSMISSION - FOT

TO: All A300,A300-600,A310,A318,A319,A320,A321,A330,A340,A350,A380,AST Operators

SUBJECT: ATA 03,25,26,50 – CARGO TRANSPORTATION IN THE CABIN

OUR REF.: 999.0028/20 Rev 00 dated 30-MAR-2020

CLASSIFICATION: General information

APPLICABLE AIRCRAFT: This FOT is applicable to A300,A300-

600,A310,A318,A319,A320,A321,A330,A340,A350,A380,AST

Notice: This FOT provides general flight operations information. It is left to each
Operator’s discretion whether to distribute this FOT, or to distribute the information
contained in this FOT, to all of their applicable flight crews for information.

0. REFERENCES

Regulations associated with transportation of cargo in the Cabin (Passenger compartment) are
specified by the EASA in AMC2.CAT.OP.MPA.160 (carriage of cargo in the passenger
compartment) and FAA 14 CFR 121.285.

The transportation of cargo on passenger seats using cargo seat bags is addressed by the EASA
in CM–CS–003 Issue 01 (Installation of “Cargo Seat Bags” on Passenger Seats) and related
Special Conditions (Proposed Special Condition on Installation of Cargo Seat Bags - Applicable to
Large Aircraft)

The floor loading limits of the aircraft cabin floor are provided in the Weight and Balance Manual
(WBM):
 Chapter CTL-LIM-CAB-FLL for A320, A330/340 and A350 families
 Chapter 1-10-80 and 1-10-90 for A380
 Chapter 1-10-04 for A300/A300-600

1. PURPOSE / INTRODUCTION

Due to the COVID-19 crisis, the passenger transportation by air has drastically decreased. In the
meantime the demand for cargo transport rapidly increases.
Combined with the natural cargo capabilities of the Airbus aircraft, the passenger compartments
offer a significant additional loading capacity for pure cargo operations. This message is to
provide operators with the Airbus position and general guidance on carrying cargo in the cabin
(Passenger compartment).
It will be followed by webinars (see Section 3) in order to share the Airbus action plan for support
of cargo operations on passenger decks.

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 FLIGHT OPERATIONS TRANSMISSION - FOT

2. DESCRIPTION

2.1 Transport of cargo in approved stowage locations of the cabin

In line with the referenced regulations, Operators may transport cargo in the cabin as long as
the Cargo is placed in the approved stowage locations within the passenger compartment as
described below.

2.1.1 Stowage locations approved to transport cargo in the Cabin

The approved stowage locations to transport the cargo in the cabin are as follows:
 Overhead stowage bins,
 Stowage compartments,
 Floor mounted stowage (e.g. doghouses),
 Bulkheads that have a placard indicating maximum capacity,
 Under seat stowage areas.

2.1.2 Stowage locations not approved to transport cargo in the cabin

The following locations are not approved to transport the cargo in the cabin
 Lavatories,
 Crew Rest Compartments,
 Bulkheads that are incapable of restraining the items from movement,
 All locations that are identified with placards ‘No Stowage’.

2.1.3 Requirements to be met to transport cargo in the cabin

The following requirements shall be met for cargo to be transported in the cabin:
a) The cargo shall be placed only in the approved stowage locations (Section 2.1.1 of
this memo) and the cargo shall NOT be placed in the stowage locations that are not
approved (Section 2.1.2 of this memo).
b) As per the EASA AMC2.CAT.OP.MPA.160 the Operator should not transport
dangerous goods in the cabin. The Operator must comply with the latest ICAO
technical instructions and IATA dangerous goods regulations.
c) For the bulkheads that have a placard indicating maximum capacity, the cargo items
stowed in these bulkheads shall not exceed the maximum capacity indicated in the
placard.
d) The maximum capacity limitations in the placards (on or adjacent to the cargo
approved stowage locations – Section 2.1.1 of this memo) shall not be exceeded. All
stowage limits specified in the placards apply.
e) The mass of the cargo shall not exceed the structural loading limits of the floor or
seats , published in the Limitation chapter of the Weight and Balance Manual (WBM).
f) The cargo placed in enclosed stowage areas shall not be of such size that they
prevent latched doors from being closed securely.
g) The cargo items shall be stowed only in a location that is capable of restraining it.
h) The cargo stowage location shall be such that, in the event of an emergency
evacuation, it will not hinder aisle access and egress.
i) The cargo shall not be placed where it can impede access to emergency equipment.
j) The cargo shall be checked to ensure proper stowage in the following instances (at
the minimum):
 Before take-off,
 Before landing,

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 FLIGHT OPERATIONS TRANSMISSION - FOT

 Under orders of the Pilot in command.

k) The aisles shall remain free of cargo to enable access to the seats and the goods in
case of smoke or fire.
l) Trained crew shall be on-board to survey and access all areas of the cabin during all
flight phases. Any smoke/ fire within the cabin must be easily detected and effectively
managed using the existing emergency equipment. Specific details must be
coordinated with local regulatory authorities.
m) For ‘Under seat stowage’, the seat shall be equipped with a restraint bar system and
the cargo items shall be placed fully underneath the seat. The loading of the cargo
under each seat should not exceed 9 kg (20 lbs).
n) The cargo packaging shall be able to equalize the pressure so that it can handle the
Delta Pressure (DP) during the flight.
o) All smoke and fire detectors shall be maintained as per Maintenance Manual
instructions.
p) The Air Conditioning system shall be configured according to the nature of the cargo
and / or crew member on board.
q) The calculation of the aircraft weight & center of gravity must be adapted according to
the cargo loaded in the cabin.

2.2 Transport of cargo on the passenger seats

The EASA does not provide any Certification Specifications for the transportation of cargo on
passenger seats. The EASA considers this as a Major Change and approval is required.

Airbus is currently working on an approved fast-track solution, including applicable

procedures and documentation. More information, including date of availability, will be
provided during upcoming webinars (See section 3).

Operators willing to proceed before the Airbus solution is available must coordinate with their
local regulatory authority to ensure the compliance with the applicable regulatory restrictions
(cargo type, fire suppression, smoke detection, etc.).

Note: The EASA has published a guidance material on the installation of cargo seat bags in
the CM–CS–003 Issue 01 (Installation of “Cargo Seat Bags” on Passenger Seats) and related
Special Conditions (Proposed Special Condition on Installation of Cargo Seat Bags -
Applicable to Large Aircraft).

All of the following requirements shall be met for cargo to be transported on the passenger
compartment seats:
a) The Operator must comply with the requirements defined in sections 2.1.3 b) to q).
b) The load should be evenly distributed across the seat row. The loading on each seat
should not exceed 77 kg (170 lbs) in the case of cargo transportation.
c) 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 current seat supplier.
d) The cargo shall be adequately restrained and the restraints must be attached to the
existing seat belt or to the seat itself.
e) All other safety requirements (regulatory, flammability, fire suppression, flight operations,
payloads, etc.) shall be met.

2.3 Transport of cargo on the passenger compartment floor after removal of the seats

The EASA does not provide any Certification Specifications for the transportation of cargo
stowed on the passenger cabin floor after removal of the seats. The EASA and Airbus
consider this as a Major change and approval is required.

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© AIRBUS S.A.S. 2020. ALL RIGHTS RESERVED. CONFIDENTIAL AND PROPRIETARY DOCUMENT
 FLIGHT OPERATIONS TRANSMISSION - FOT

Airbus is currently working on an approved fast-track solution, including applicable

procedures and documentation. More information, including date of availability, will be
provided during upcoming webinars (See section 3).

Operators willing to proceed before the Airbus solution is available must coordinate with their
local regulatory authority to ensure the compliance with the applicable regulatory restrictions
(cargo type, fire suppression, smoke detection, etc.).

2.4 Ad-Hoc operation considerations

The carriage of cargo in the cabin is not currently deemed as “normal operation” and
therefore falls into the category of “ad-hoc operations” (e.g. Ferry flights) which require
specific procedures that can only be defined by each individual operator and requires final
approval by the local airworthiness authority.

It is the Operators responsibility to implement procedures that must be included in flight

operations manuals and adhered to by the operating crew. Airbus is not in a position to
provide specific rules, regulations and procedures on such ad-hoc operations.

Operators may operate the carriage of cargo in different ways, which cannot be individually
addressed by Airbus, and therefore should only be addressed by the local aviation authority.

3. FOLLOW-UP PLAN

This FOT will be followed by webinars in order to share the Airbus action plan for support of cargo
operations on passenger decks:
- Thursday 2nd April 2020 at 07:00 UTC time
- Thursday 2nd April 2020 at 14:00 UTC time

Note: Further details and electronic invitations will be sent shortly

For any questions about the operational content of this FOT, please use TechRequest on
AirbusWorld.

Best regards,

Capt. Yann LARDET

Vice President, Flight Operations Support & Training Standards

FOT ref: 999.0028/20 Rev 00 Page 4 of 4 Date: 30-MAR-2020

© AIRBUS S.A.S. 2020. ALL RIGHTS RESERVED. CONFIDENTIAL AND PROPRIETARY DOCUMENT