Commercial and Business Aviation Advisory Circulars

Cargo and Baggage Compartment Fire Protection

INTRODUCTION

The purpose of this Commercial and Business Aviation Advisory Circular (CBAAC) is to advise air operators that an upcoming Canadian Aviation Regulation (CAR) amendment will require that cargo/baggage compartments on transport category aeroplanes, operated under CAR Part VII, comply with upgraded fire protection standards no later than January 1, 2003.

BACKGROUND

Accident experience (including Valujet, 1996, 110 fatalities), and full-scale tests and analyses conducted by the United States (U.S.) Federal Aviation Administration (FAA) have established that:

• fires could rapidly burn through certain types of cargo/baggage compartment liners, thereby compromising the integrity of Class D and Class C compartments fire control mechanisms; and
   
• the ‘oxygen starvation/fire containment’ concept used in Class D compartments is inadequate in controlling certain types of fires (including those resulting from the bursting of consumer aerosol cans).

The FAA has accordingly adopted rules:

1. to require that cargo/baggage compartment liners meet upgraded fire resistance standards on new transport category aeroplane type designs and on the majority of in-service transport category aeroplanes; and
    
2. to eliminate Class D compartments as an option for new transport category aeroplane type designs, and to require that Class D compartments on the majority of in-service transport category aeroplanes meet the fire/smoke detection and fire suppression standards applicable to Class C compartments (or, optionally, Class E for all-cargo aeroplanes).

CURRENT SITUATION

Transport Canada (TC) has adopted the pertinent design standards (CAR Part VII) for the certification of new aeroplane type designs.

With respect to in-service aeroplanes, it was agreed, at a special meeting of the Canadian Aviation Regulatory Advisory Council (CARAC), held with industry in September 1997, that TC would proceed expediently to promulgate amendments to CAR Part VII regulations equivalent to those of the FAA, and that a comparable compliance ‘window’ would be provided. TC immediately initiated regulatory action.

However, delays encountered in the regulatory process dictate the need to set the final compliance date at this time so as not to further delay fleet implementation. Accordingly, it has been agreed with the Air Transport Association of Canada (ATAC) that the final compliance date would be set at January 1, 2003, irrespective of the CAR amendment promulgation date (essentially providing the agreed ‘compliance window’). It was further agreed that industry would be requested to provide the required Plan of Compliance and Quarterly Information Reports in accordance with a schedule based on the date of publication of this CBAAC (rather than the date of promulgation of the CAR amendment), to support compliance flexibility in cases where specific compliance difficulties are encountered.

The proposed Regulations and Commercial Air Service Standard are presented in Annex 1.

CONCLUSION

Accordingly,

• Cargo/baggage compartments on affected aeroplanes will have to be in compliance with the upgraded fire protection standards no later than January 1, 2003.
   
• Air operators are requested to provide the required Plan of Compliance and Quarterly Information Reports in accordance with a schedule based on the date of publication of this CBAAC.

M.R. Preuss
Director
Commercial & Business Aviation