Have you ever wondered how many trainings you have undertaken?
For those of us who fly, you can include the pre-flight safety briefing (assuming you are paying attention and not asleep or reading the newspaper) which for many of us adds up to hundreds if not thousands. Add to this all the other trainings and briefings in your life, training on office safety regulations such as fire drills, training on how to use your computer, training to drive a car, the list goes on and on, and these are just the trainings you have to do as part of your job or life. And then there is the list of voluntary trainings you may take on as part of a recreation, or to acquire additional qualifications… the list is endless.
Yes, life without training is as unimaginable as life without food and drink.
Yet, somehow there seems to be an almost universal belief in the air cargo industry that there need be no training for a person to work with a ULD! How can this be? It goes against the general principle that in any workplace staff training is part of the company structure, training managers abound, training courses are part of any workplace schedule and, to obtain and maintain any kind of ISO 9000 or equivalent qualification, an organization shall always have in place comprehensive training programs.
Furthermore, when we get to aviation the bar moves higher still, from flight crew through cabin crew to ground staff not to mention anyone going near an aircraft to perform any kind of technical function. Training is a non-negotiable requirement, established and enforced by the aviation authorities and enshrined in the International Civil Aviation Authority policies.
So, how is it that in the midst of all this training, ULDs are completely ignored –
A black hole in the training universe?
There seems to be a number of possible reasons, none of them particularly good, but all too often rolled out in the air cargo environment:
- ULD’s are simple
- Anyone can stack cargo
- We can’t afford the time/cost of training
- The staff are always moving on, training is a waste of time/money
- Joe’s been around a long time, he knows how to do things
These are just five of the reasons one will hear (by the way Joe never had any training either, he learnt all he knows from Fred who learnt what he knows from Bill etc. etc. etc.) and none of them are justifiable in any business let alone one that has a direct bearing on flight safety.
The IATA ULD Regulations take a very clear position on training, and how can they not? As a comprehensive standard for the operation and handling of ULD’s, it would be negligence on the part of IATA not to set a clear standard for training in this document. With the ULD Regulations now being referenced in IATA processes such as IOSA and ISAGO, the need to establish training programs is becoming more evident by the day, with airlines becoming aware of this requirement.
Some might question the basis on which IATA has made training a requirement, after all the industry has gone many years without such a demand. The answers to this question are twofold:
- As we have expounded above, training is an essential part of all workplace activity; you cannot exclude ULD, it doesn’t make sense
- Aviation Authorities expect training and the clearest specific example relating to ULD is the FAA Advisory Circular AC 120-85 which makes very specific demands for training
“268. INDIVIDUALS WHO SHOULD RECEIVE ULD TRAINING. All air carrier and vendor personnel involved in the loading of cargo should receive ULD training.”
Based on these two factors alone the requirements for training in the ULD Regulations cannot in any manner be taken as some kind of arbitrary demand imposed by IATA on an already overburdened industry.
Neither should this be seen as an exercise in money making for IATA- an argument that is often raised when the subject of IATA, training and ULD are found in the same conversation. There is nothing to prevent airlines or other organizations developing their own ULD training programs, the ULDR’s provide guidance on the content requirements ( see Section 1.6 ULDR) and the ULDR’s themselves provide more than adequate material on the operating and handling requirements of ULD, all it takes to develop a very effective training course is a willingness to sit down and put it together, failing which of course one can turn to an IATA training program, but in that case yes, there is a cost.
It must be noted here that when it comes to Loadmasters, who are required when loading special cargo, the training requirements and content are more stringent and specialized (and it may well be that in house training is insufficient), but for the vast majority of personnel this is not the case.
The next couple of years may well prove pivotal for ULD operations as the air cargo industry starts to embrace the fact that the current training vacuum is simply not acceptable and cannot be allowed to continue. With ULD damage incidents probably occurring in excess of 1 million a year, not to mention countless breaches of Weight and Balance requirements and also damage to aircraft and cargo, the current lack of training is simply unsustainable and must change.
Whether one hour online awareness training for people who work around ULD’s or one week advanced training for someone having major responsibility for ULD doesn’t matter. Both are equally important. ULD CARE takes this opportunity to emphasize that ULD without training creates a perfect storm from which ULD owners and operators cannot escape.