CAP3082 Consultation on Changes to UK Regulation (EU) No. 965/2012 with regards to the Specific Cargo Compartment Safety Risk Assessment

Closes 2 May 2025

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Benefits

To enable an accurate assessment to be conducted, the CAA is inviting air operators to provide an estimate of costs and benefits that should be considered as a result from adoption and implementation of the proposed changes.

We have factored the following four types of costs in this consultation, which address the principal areas the CAA believes may be impacted by the adoption and implementation of the proposed changes:

  • One-off Costs – resulting from the implementation of the changes
  • Transitional Costs – resulting from the transition to the new requirements
  • Ongoing Costs - annual costs required for maintaining and upkeeping the new SMS and CMS requirements.
  • Benefits - resulting from adequate mitigation of an uncontrolled fire in the cargo compartment resulting from items being carried.

Each cost type will have a series of associated descriptors to allow necessary granularity of the estimations and what covered.

In case we have not captured all potential associated costs, we have included at the end of this section, an additional opportunity for estimation of ‘Other Costs’ not considered previously, to be entered.

When responding to this part of the consultation, go to each of the types of costs listed and applicable descriptor, select the drop down for each associated assumptions and insert the total estimated cost for each assumption.

At the end of each type of cost there is a free text box into which additional information can be entered, for the purpose of explaining a rational or providing clarification deemed necessary by the commentator.

Please provide as much detail as possible, as this will allow the CAA to account for as many variables as possible in the impact estimation.

Related information

CAP3082: Consultation on Changes to UK Regulation (EU) No. 965/2012 with regards to the Specific Cargo Compartment Safety Risk Assessment | Civil Aviation Authority

25. Descriptor 1 – Loss of aircraft hull

This descriptor aims to consider the benefits of the Specific Risk Assessment being conducted by an operator to allow for sufficient mitigation and prevention of an accident which could cause the loss of the aircraft, resulting from an uncontrolled fire in the cargo compartment.

This is the highest risk that is currently in the UK CAA Regulator Safety Management System and the adoption of the proposed changes to the regulation offer the opportunity for adequate preventative measures to be adopted by operators.

The inherent costs will vary depending on aircraft type being operated and average number of passengers being carried throughout the operator’s network / operation.

26. Descriptor 2 – Loss of revenue - Aircraft Unserviceability due to damage caused by fire

This descriptor aims to consider the benefits of the Specific Risk Assessment conducted by an operator which allows for sufficient mitigation and prevention of an incident resulting from a fire in that cargo compartment, which could cause damage to the aircraft but not result in the loss of the aircraft or cause fatalities.

This is associated to the highest risk that is currently in the UK CAA Regulator SMS and the adoption of the proposed changes to the regulation offer the opportunity for adequate preventative measures to be adopted by industry.

Inherent costs will vary depending on aircraft type being operated, average number of passengers, baggage, mail and cargo being carried throughout the operator’s network / operation.

27. Descriptor 3 – Loss of reputation

This descriptor aims to account for the costs inherent to loss of reputation which could result from an incident or accident involving a fire in the cargo compartment of an aircraft.

28. Descriptor 4 – Other on-going benefits

This descriptor allows for any other on-going benefits that may not have been captured in the previous cost types.