Freighter Aircraft  IRCD rule won’t meet OMB Circular A-4, so will Congress mandate Installation?

cargo cockpit door and horses & handlers in main cabin
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INTRUSION RESISTANT COCKPIT DOORS needed on Freighters

Primary Risk– supernumeraries on flights carrying animals

Not likely to meet Congressional/OIRA benefit/cost test

Reps. Brian Fitzpatrick (R-PA) and Jesus G. “Chuy” Garcia (D-IL), the legislation (H.R. 6190;  introduced on March 11, 2020, in a previous session of Congress, but it did not receive a vote.) The Cargo Flight Deck Security Act of 2020 would require all-cargo aircraft to be equipped with cockpit doors (intrusion-resistant cockpit doors (IRCD) ) that meet certain safety requirements, and for other purposes.

HR 6190

The risk to be minimized is explains as follows:

Non-flightcrew members, known as supernumeraries, can be onboard to support transported animals (e.g., horses) and have unfettered access to the flight deck. These animal handlers are often on board and carry lethal animal tranquilizers. These individuals, who are not airline employees, are seated directly behind the pilots and are not required to meet the same security background checks as airline crew members with access to an aircraft flight deck. The lack of an IRCD on all-cargo aircraft creates a vulnerability if there is an attempt to take over the aircraft or an attack on the pilots or flight deck.”

This is not the first time that ALPA has demanded this installation—request for rulemaking and a previous comprehensive IRCD bill (which passed, but did not include the cargo door requirement).

Why seek another bill? Any further administrative action would be doomed to failure. The existing cost/benefit review (Circular A-4) administered by the OMB Office of Information and Regulatory Affairs (OIRA), as Congress mandated, would find  IRCD deficient under the cost/benefit standard. A few of the impediments to a barrier requirement through regulations:

B/C test

  • The number of freighter flights with supernumeraries on board is not substantial. Perhaps a more effective mechanism would be to include the supernumeraries within the existing safety-related personnel background checks. A lot cheaper and probably a lot more effective to identify real risks.
  • Perhaps more telling is the judgment of French equivalent of the NTSB (the BEA) in its research of Germanwings, where it found that the need for an IRCD was not yet
  • In 2002, the FAA estimated that the cost of installation per plane was substantial (this statement was made in a press release announcing that the Congressional mandate for passenger planes IRCD equipage)l:

2002 IRCD costs

The 2002 price of between $12,000 and $17,000 per cargo door would escalate over almost 20 years to an even higher cost and make the denominator small fraction.

 

 

 

 

 


ALPA Applauds Requirements For Reinforced Flight Deck Doors on All-Cargo Birds

Would Require The Installation Of Intrusion-Resistant Cockpit Doors

Cargo IRCD

ALPA has applauded Rep. Jesus G. “Chuy” Garcia (D-IL) and Rep. Brian Fitzpatrick (R-PA) for introducing legislation (H.R. 4598) that would require the installation of intrusion-resistant cockpit doors (IRCD) (patent)on aircraft used in all-cargo airline operations. The Cargo Flight Deck Security Act of 2021 is an important step toward the establishment of one level of security for both passenger and all-cargo flight operations.

Rep. Garcia and Fitzpatrick

“For far too long, there has been a dangerous double standard when it comes to common safety and security provisions for cargo pilots. Thanks to Reps. Garcia and Fitzpatrick’s leadership, this bill will help advance commercial aviation by protecting not only pilots and their cargo, but also citizens in communities on the ground and flying in our shared airspace,” said Capt. Joe DePete, ALPA president.

After 9/11, Congress mandated hardened flight deck doors on commercial airliners. Unfortunately, the only all-cargo aircraft included were those that had flight deck doors at that time. The majority of all-cargo aircraft were not equipped with doors, and virtually all cargo aircraft manufactured since are not equipped with the hardened flight deck door.

One example of a critical threat that an IRCD would help mitigate is found on all-cargo flights that transport large animals. During these operations, animal handlers are often on board and carry lethal animal tranquilizers. These individuals, who are not airline employees, are seated directly behind the pilots and are not required to meet the same security background checks as airline crew members with access to an aircraft flight deck. Without a door separating them, these individuals continue to have access to the flight deck and pilots during flight.

“The all-cargo airline arena continues to be identified as a significant security target in our aviation system, yet current regulatory requirements allow relatively unfettered access to the cargo flight deck during flight operations,” said DePete. “ALPA encourages Congress to pass this important bipartisan bill to mandate hardened flight deck doors on all-cargo airliners and close the gap in aviation security loopholes for cargo pilots.”

FMI: www.alpa.orgcockpit and LD 3 containers

 



 

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