EASA has just released ETSO-C90e, the updated technical standard order for cargo pallets, nets and containers. This is good news for the air cargo industry, which has been waiting several years for regulatory harmony between the FAA and EASA on ULDs.
For the first time, EASA-certified ULDs must comply with flammability requirements that mirror those issued by the FAA. But what impact will this new design and performance standard have on European manufacturers and users of fire-resistant containers?
A quick trip down memory lane
In July 2021, the FAA replaced TSO-C90d “Unit Load Devices” with TSO-C90e to reflect the latest scientific and technical progress. The main change revolved around the reference to SAE AS8992 “Fire Resistant Container Design, Performance, and Testing Requirements.”
This external aerospace standard requires passive fire-resistant containers (FRCs) to be tested for their ability to contain a Class A fire. In effect, the FAA introduced enhanced flammability requirements for all ULDs and a new standard for FRCs.
Ever since, ULD manufacturers under FAA jurisdiction have been able to sell certified fire-resistant containers, while their counterparts in Europe could not. The release of ETSO-C90e changes all that.
Applause for regulatory alignment
To be certified by EASA, all new ULD designs must now comply with the flammability requirements set out in SAE AS8992. They must also comply with two other external standards: SAE AS36100C, ‘Air Cargo Unit Load Devices—Performance Requirements and Test Parameters,’ and the latest version of SAE AS36102B, ‘Air Cargo Unit Load Devices—Testing Methods.’
At VRR, we welcome this realignment between FAA and EASA standards. ULD manufacturers under EASA jurisdiction can now offer customers fire-resistant features that are certified by EASA and receive straightforward mutual recognition from FAA partners. Competitiveness in the FRC global market has been restored.
Different flammability tests
Of course, with new standards come new processes and new stipulations. In the future, ULD manufacturers based in Europe will have to conduct much more testing, especially when it comes to flammability and fire-resistant materials.
Before the release of ETSO-C90e, European manufacturers were required to use only the Horizontal Bunsen Burner Test (with a 2.5-inch/minute burn rate criterion) to evaluate the flammability of their materials. Now, they must demonstrate a material’s fire resistance by conducting the 12-second Vertical Bunsen Burner Test and/or the 45-degree Bunsen Burner Test.
It should be noted that these flammability tests apply to all ULDs. However, FRCs are subject to additional “wear and tear” tests. UV and abrasion resistance testing must be carried out before flammability tests are conducted. Puncture tests are also required to obtain certification.
Simulating real-life scenarios
Why the additional tests? Vertical and 45-degree tests are just as accurate as horizontal tests, but they give a more realistic picture of how aircraft materials might burn in an actual fire. This additional insight helps ULD manufacturers better understand the safety of their products in real-life scenarios and comply with the newer, stricter regulations on fire-resistant parts.
Here’s how the Vertical Bunsen Burner Test works:
A material sample is held upright, and a flame is placed at the bottom edge for 12 seconds. After removing the flame, testers wait to see if the material keeps burning and/or if any burning pieces fall off.
The testers then measure how long and how much of the material burns. They repeat this process twice more with different samples. Based on the average results, the material passes or fails the test.
The 45-degree test is similar, but as the name suggests, the material sample is held up at an angle instead of vertically or horizontally. Together, all three tests provide a more reliable way to check how well materials used in an FRC resist catching fire.
What does ETSO-C90e mean for you?
The new requirements for enhanced fire properties are aimed directly at the manufacturers of ETSO components. However, owners and users of FRCs should be aware of the following:
All ETSOs are updated from time to time. The updated version applies to new ULD designs submitted for approval by the manufacturer. Previous designs that were approved under earlier versions remain valid.
As of now, if you want to buy or use an FRC from a European manufacturer that complies with the regulatory safety standards, you must ensure it complies with ETSO-C90e.
If you own or use an FRC whose design was approved by EASA before ETSO-c90e came into effect, you do not have to do anything. That design is still safe, and you can continue to use it indefinitely.
To identify an FRC that has been certified in accordance with the new regulations, check the container’s ETSO plate. It should say, “In compliance with (E)TSO-C90e.”
What does ETSO-C90e mean for VRR?
As a ULD manufacturer based in Europe, the main impact of this updated standard is the increased level of fire resistance and other testing. Specifically:
We will use the 12-second Vertical and 45-degree Bunsen Burner Tests in addition to the Horizontal Bunsen Burner Test to evaluate materials for flammability.
We will test fire-resistant materials for durability. This involves conducting environmental tests to anticipate defects caused by wear and tear in normal operating conditions (e.g., temperature, UV light, stretching, and punctures).
This more extensive testing will demonstrate that any ULD that we design meets the highest flammability standards and will continue to perform within durability and quality standards throughout its useful life.
The alphabet soup of ULD compliance
If you’re not a design or compliance engineer, it can get a little confusing when we start talking about TSOs, ETSOs and SAE standards, so for a quick summary please visit our Certification page.