Fire hazard in closed cargo compartments: retrofit or not?

DC-9 Cargo Compartments EASA NPADespite eliminating class D cargo compartments, Europe’s current fleet still features quite some aircraft built before the change of the related Certification Specifications for large aeroplanes. These aircraft have not been equipped with the necessary fire and fumes detection and extinction devices. And although they might prove more risky to operate, EASA advocates for no regulatory change and the industry has 49 million reasons to be happy with this decision.

Several accidents in the last decade involving uncontrolled fires inside closed cargo compartments have clearly illustrated what is at stake:  such fires can completely destroy aircraft with potentially numerous casualties. This has been the case of the ValuJet Airlines Flight 592 accident in 1996, caused by an uncontrolled fire in the airplane's forward Class D cargo compartment. All 105 passengers, two pilots and three cabin crew died in the accident (source: Lessons Learned FAA).

After the accident the FAA – EASA’s American counterpart – initiated a rulemaking to improve cargo fire protection for future airplane designs and to require retrofit incorporation of these improvements on existing airplanes. Concretely, this led not only to removing the Class D cargo compartment classification entirely, but also new requirements to upgrade all cargo compartments to meet the Class C cargo compartment standard and install smoke or fire detection systems. 

A mandatory retrofit of existing Class D compartments to upgrade them to Class C for passenger aircraft or to Class E for cargo aircraft could have significant safety benefits in Europe as well.  While such regulatory measures have been taken in the US, Europe is still lagging behind.

In Europe, EASA has published a Notice of Proposed Amendment (NPA) on Fire Hazard in Class D Cargo Compartments, aiming to consult stakeholders whether such regulatory change is needed. This is indeed a much-needed move. The only problem is that EASA itself advocates for no regulatory change. This is why ECA has officially responded to the NPA and called for retrofit of aircraft of existing class D cargo compartments in order to reduce the risk of uncontrollable fires.

Swift measures for all large airplanes operating in European airspace to be (retro) fitted with fire and fume detection and suppression devices for cargo holds that are in flight not accessible to air crew are the only safe way forward. This is why EASA should follow FAA’s lead and ensure the necessary regulatory changes are carried out as soon as possible.