The reporters expressed a safety concern regarding new carry-on baggage allowances for passengers on domestic flights.
The changes permit passengers to carry two bags ([weights kg]) into the cabin. [Operator] has advised, via email "from today, we ask for your continued support in the process by not weighing bags at the gate, but instead directing customers with obvious bags that you think may exceed the allowance to the customer service agent.” The reporters advise that it is not possible to visually detect cabin bags that may be overweight and relying on this method as a safety risk control is completely inadequate.
The reporters state that baggage weight limits are in place for safety reasons, as such, limits need to be adhered to. All checked baggage is weighed to ensure the limits are not breached. The reporters query why the same measures are not taken for carry-on baggage.
The reporters had additional concerns, specifically relating to the Boeing 737-800 aircraft. One reporter advised that lockers on this model aircraft are fitted with mechanical assist latches, which are regularly faulty or broken, yet remain in use rather than deemed unserviceable. Risk of injury to passengers and cabin crew from baggage falling from these lockers is real, and there are no controls in place to mitigate the risk. In addition, another reporter stated that some of these lockers have a latch closed load limit of 99lb/44kg for certification. Under the previous baggage limits ([weight] per bag), the lockers were likely over weight capacity and potentially unsafe, which [Operator] acknowledged through introducing a policy that two flight attendants must close the locker for WHS reasons. The reporters state that the risk of injury has increased with the introduction of the increased allowable baggage limits.
In addition, two reporters referenced REPCON AR201800019, in which a concern was raised regarding the size and number of carry-on baggage in overhead lockers leaving no room to stow baggage, except under the seat in front. The reporter concurred with this concern, specifically in relation to the seating density on the 737, and believes that the increase of weight limits to carry-on baggage will result in an increase of larger bags being placed under seats, further increasing the risk of impeding passenger evacuation should an emergency event require rapid evacuation of the aircraft.
Operator's response (Operator 1)
The reporters advise that it is not possible to visually detect cabin bags that may be overweight and relying on this method as a safety risk control is completely inadequate.
[Operator] has carry-on baggage allowances that are documented on [website] for customers and within policy manuals for both cabin crew and airports staff. [Operator] airport staff and cabin crew are responsible for enforcing carry-on baggage regulations, both at check in and during boarding. If cabin baggage is excessive, ground staff will arrange for stowage in the hold. At the end of 2018, a review of the [Operator] domestic in-cabin baggage allowance policy was conducted. This policy review and subsequent decision to change the cabin baggage policy from [weight per bag] to bags totalling [weight kg] to an ‘envelope’ of [weight kg] in which no bag would exceed [weight kg], was introduced.
This change to cabin baggage policy was conducted following the [Operator] documented, and CASA approved, change management process. As part of the change process a risk assessment was conducted that included representatives from the following business units:
- Flight Operations
- Engineering - technical
- Engineering - cabin
- Engineering - weight and balance
- Cabin Crew WHS
- Cabin Safety
- Human Factors
- Customer Strategy
- Airport Systems
- Airport Operations
- Customer Experience
- [Operator 2] (airports/safety/WHS)
Prior to the change to the new cabin baggage policy the following steps were undertaken:
- Customers were advised of the new cabin baggage allowances at all points in their booking and travelling journey.
- Customers were advised that they would be responsible for the management and handling of their own baggage at all points of their journey.
- Additional cabin baggage weigh stations were purchased and are located in the passenger terminal landside to assist the customer service agents in the monitoring of both size and weight of cabin baggage.
- Additional passenger announcements have been incorporated into airport terminal announcements and aircraft cabin announcements detailing the responsibilities of each passenger in relation to their baggage.
In addition to the above, extensive consultation occurred with the cabin crew WHS Health and Safety representatives regarding the proposed cabin baggage policy change. This included an ergonomic review of the manual handling risks and techniques used by cabin crew, which was conducted by an independent ergonomist. The ergonomist deemed the injury risk low, with the manual handling mitigation controls that have been put in place for when the power assist closing mechanism is inoperable. This review led to the development of new policies and procedures, which were augmented by a 15 minute training video highlighting a two-person bag lift into the overhead locker and; a two-person locker close procedure.
A Post Implementation review of the new cabin baggage policy was recently conducted. This review measured the success of the cabin baggage controls that have been implemented during the change process. The controls are categorised in the following areas:
- Customers are now responsible for the carriage and stowage of their own bags
- Industry and direct customer awareness around cabin baggage expectations
- Increase in messaging at all digital and physical interactions
- Landside controls including dedicated resources to weigh bags and ensure compliance
- New manual handling procedures including a two person lift and locker close (with less requirement to lift and shuffle bags given the re-setting of customer expectations).
In addition to the above, weekly PIR (Post Implementation Review) meetings are being held with cabin crew HSRs, cabin safety, Airports and cabin crew management in attendance. A PIR scorecard is produced for each meeting, which details the number of oversize cabin bags intercepted, number of landside customer interactions, feedback from cabin crew and airports and any crew injury reports received. Key points emerging from these scorecards are a significant reduction in cabin baggage non-compliance reports, no workers compensation claim injuries since implementation of the new cabin baggage policy and a shift in customer compliance based on a large sample set.
The reporters had additional concerns, specifically relating to the Boeing 737-800 aircraft. One reporter advised that lockers on this model aircraft are fitted with mechanical assist latches, which are regularly faulty or broken, yet remain in use rather than deemed unserviceable. Risk of injury to passengers and cabin crew from baggage falling from these lockers is real, and there are no controls in place to mitigate the risk. In addition, another reporter stated that some of these lockers have a latch closed load limit of 99lb/44kg for certification. Under the previous baggage limits (weight kg per bag), the lockers were likely over weight capacity and potentially unsafe, which [Operator] acknowledged through introducing a policy that two flight attendants must close the locker for WHS reasons. The reporters state that the risk of injury has increased with the introduction of the increased allowable baggage limit.
To clarify the concerns raised above, overhead lockers will never be utilised if the locking mechanism is not operational. If an overhead locker locking mechanism is inoperative, the Minimum Equipment List (MEL) states that the locker must not be utilised with the door secured closed. The affected bin must be placarded “Do Not Use” and must not be used for the storage of any items.
The reporter may be alluding to the power assist mechanism, which assists with the force required to close the overhead locker. Due to a world-wide shortage of a manufacturers part, the power assist mechanism on some of the B737-800 BSI lockers are not working to full functionality. The power assist mechanism is in place to reduce the push force required to move the locker to the fully closed position but does not affect the lockers ability to latch correctly nor remain close during take-off, landing or during turbulence. [Operator] Engineering have added a task to the aircraft heavy maintenance check to replace these power assist gas springs at that time.
The reporter concurred with this concern, specifically in relation to the seating density on the B737, and believes that the increase of weight limits to carry-on baggage will result in an increase of larger bags being placed under seats, further increasing the risk of impeding passenger evacuation should an emergency event require rapid evacuation of the aircraft.
Cabin baggage is only allowed to be carried on board if it complies with the [Operator] carry-on baggage dimensions and can be safely stowed in an approved stowage. Approved stowages include the overhead locker and the area under the passenger seat in front. At emergency exit rows, the documented cabin crew policy requires that the area under the passenger’s seat in front is kept clear.
At these locations all bags must be placed in the overhead locker for taxi, take-off and landing. Cabin crew procedures are such that cabin crew are required to visually check that cabin baggage is stowed correctly during pre-flight and prior to landing. This includes the detection of any oversized bags that would impede egress during an evacuation. As stated above these bags would be re-directed to the overhead locker or if insufficient room, to the cargo hold prior to departure. [Website] details the information for passengers in relation to their carry-on baggage:
Things to know
Your carry-on baggage must:
- Fit under the seat in front of you or in an overhead locker (including musical instruments)
- Not exceed the carry-on baggage allowances
- Not include any dangerous goods unless permitted for carriage.
If your baggage meets the above requirements, but we reasonably believe it's not safe to be included as carry-on baggage, we may require you to check it in. It’s up to you to ensure your baggage doesn’t exceed the allowance and you’re able to lift your bag into the overhead locker. If your bag is too heavy or too large to fit safely on board, you’ll need to check it in.
ATSB comment: The ATSB subsequently queried if [Operator] could clarify the intent of the reported email sent to staff requesting that carry-on baggage not be weighed at the gate.
[Operator] subsequently provided the following updated response:
The weighing of cabin bags is the responsibility of ground staff. As cabin crew are the last line of defence, they may still identify cabin baggage that has the potential to be overweight. The new procedure is for the cabin crew to direct these passengers to ground staff personnel at the gate to manage the bag appropriately. This may mean redirecting the bag to the hold, but only after the appropriate questions about dangerous goods and medication have been asked.
The email that the reporter mentions likely relates to messaging from cabin crew management reinforcing this change in procedure – that the cabin crew are no longer required to weigh potentially overweight bags – but to redirect them to ground staff. As mentioned in our previous response, the post implementation data is supporting that less noncompliant bags are making it to the gate given the additional controls that are in place at landside locations.
Regulator's response (Regulator 1)
Management of passenger carry-on baggage presents an ongoing challenge for all regular public transport (RPT) operators and frontline airline personnel.
Stowage of loose articles in the aircraft cabin to prevent injury to persons or damage to the aircraft is enshrined in Civil Aviation Order 20.16.2 Air services operations – Loading - General and Civil Aviation Order 20.16.3 Air service operations – Carriage of persons.
These Orders, however, do not stipulate number, weight or size limitations of carry-on baggage allowed onboard an aircraft. As a consequence, an operator will determine and develop policy and procedure, in conjunction with the legislative framework, and integrate into requisite operations manuals which are ‘accepted’ by CASA. The operators’ personnel, specifically, ground operations and cabin crew members, work in accordance with these procedures.
[Operator] in formulating documented policy and procedures as it relates to carry-on baggage currently comply with legislative requirements.
Civil Aviation Order 82.5 Conditions on Air Operators’ Certificates authorising regular public transport operations in high capacity aircraft, requires an operator to establish and maintain a safety management system (SMS), of which a safety risk management plan, inclusive of hazard identification, risk assessment and mitigation processes, are a part.
[Operator] currently comply with the documented provisions of their SMS.
The operator’s proficiency in the management of its safety risks, change management processes and its ability to comply with legislative obligations, remains a continued focus of CASA’s surveillance activities.
CASA appreciate being informed of this matter.