AMC 25.855 and 25.857 Cargo or baggage compartments

• ED Decision 2020/024/R found in: CS-25 Amdt 27 - Large Aeroplanes (Jan 2023)

AMC 25.855 and 25.857 Cargo or baggage compartments ED Decision 2020/024/R 1. PURPOSE This Acceptable Means of Compliance (AMC) sets forth an acceptable means, but not the only means, of demonstrating compliance with the provisions of the airworthiness standards for Class B and Class F cargo compartments for large aeroplanes. This AMC provides a rational method for demonstrating that the requirements of the related paragraphs of CS-25 are met and that fires occurring in the compartments can be controlled to ensure that they do not present a hazard to the aeroplane or its occupants. Like all AMC material, this AMC is not, in itself, mandatory and does not constitute a requirement. Terms used in this AMC, such as “shall” and “must,” are used only in the sense of ensuring applicability of this particular method of compliance when the acceptable method of compliance described herein is used. 2. RELATED DOCUMENTS a. Certification Specifications. CS 25.851 Fire extinguishers CS 25.855 Cargo or baggage compartments CS 25.857 Cargo compartment classification CS 25.858 Cargo compartment fire detection systems b. FAA Advisory Circulars (AC). The following FAA Advisory Circulars are accepted by the Agency as providing acceptable means of compliance with [CS 25.857:](#_DxCrossRefBm1709821309) AC 25-17A Change 1, Transport Airplane Cabin Interiors Crashworthiness Handbook (the relevant parts addressing the applicable FAR Part 25/CS-25 paragraphs) AC 25-9A Smoke Detection, Penetration, and Evacuation Tests and Related Flight Manual Emergency Procedures, AC 25-18 Transport Category Airplanes Modified for Cargo Service AC 20-42D, Hand Fire Extinguishers for use in Aircraft AC 25-22, Certification of Transport Airplane Mechanical Systems FAA Order 8150.4, Certification of Cargo Containers with Self-Contained Temperature Control Systems (Active ULDs) 3. BACKGROUND [CS 25.857(b)](#_DxCrossRefBm1709821309) and [25.857(f)](#_DxCrossRefBm1709821309) provide standards for certification of two classes of cargo compartments, Class B and Class F. A Class B cargo compartment is configured in a manner that allows a crewmember to extinguish or control any fire likely to occur in the compartment using a hand fire extinguisher. While the person combating the fire must have access to the compartment, it must not be necessary for that person to physically enter the compartment to extinguish the fire (see [CS 25.857(b)(1)](#_DxCrossRefBm1709821309)). The contents of the compartment may be reached by hand or with the contents of a hand extinguisher while standing in the entry door. A Class F cargo compartment is similar to a Class C compartment in that there are means to extinguish or control the fire without any requirement to enter the compartment. Both Class B and Class F cargo compartments have fire or smoke detection systems to alert the crew to the presence of the fire. 4. COMPARTMENT CLASSIFICATION All cargo compartments must be properly classified in accordance with [CS 25.857](#_DxCrossRefBm1709821309) and meet the requirements of [CS 25.857](#_DxCrossRefBm1709821309) pertaining to the particular class involved (see CS 25.855 (a)). In order to establish appropriate requirements for fire protection, a system for classification of cargo or baggage compartments was developed and adopted for large aeroplanes. Classes A, B, and C were initially established; Classes D, E, and F were added later. Class D has been eliminated from the CS-25 specifications (by Amdt 3). The classification is based on the means by which a fire can be detected and the means available to control the fire. a. A Class A compartment (see [CS 25.857(a)](#_DxCrossRefBm1709821309)) is one that is located so close to the station of a crewmember that the crewmember would discover the presence of a fire immediately. In addition, each part of the compartment is easily accessible so that the crewmember could quickly extinguish a fire with a portable fire extinguisher. A Class A compartment is not required to have a liner. b. A Class B compartment (see [CS 25.857(b)](#_DxCrossRefBm1709821309)) is one that is more remote than a Class A compartment and must, therefore, incorporate a fire or smoke detection system to give warning at the pilot or flight engineer station. Because a fire would not be detected and extinguished as quickly as in a Class A compartment, a Class B compartment must have a liner in accordance with [CS 25.855(b)](#_DxCrossRefBm1709821326). In flight, a crewmember must have sufficient access to a Class B compartment to reach any part of the compartment by hand or with the contents of a hand extinguisher when standing at any one access point, without stepping into the compartment. There are means to ensure that, while the access provisions are being used, no hazardous quantity of smoke, flames, or extinguishing agent will enter areas occupied by the crew or passengers. c. A Class C compartment (see [CS 25.857(c)](#_DxCrossRefBm1709821309)) differs from a Class B compartment in that it is not required to be accessible in flight and must, therefore, have a built-in fire extinguishing system to suppress or control any fire. A Class C compartment must have a liner and a fire or smoke detection system in accordance with [CS 25.855(b)](#_DxCrossRefBm1709821326) and [CS 25.857(c)(1)](#_DxCrossRefBm1709821309). There must also be means to exclude hazardous quantities of extinguishant and products of combustion from occupied areas (see [CS 25.857(c)(3)](#_DxCrossRefBm1709821309)). d. A Class E compartment (see [CS 25.857(e)](#_DxCrossRefBm1709821309)) is found on an all-cargo aeroplane. Typically, a Class E compartment is the entire cabin of an all-cargo aeroplane; however, other compartments of such aeroplanes may be also classified as Class E compartments. Shutting off the ventilating airflow to or within the compartment controls a fire in a Class E compartment. A Class E compartment must have a liner (see [CS 25.855(b)](#_DxCrossRefBm1709821326)) and a fire or smoke detection system installed in accordance with [CS 25.857(e)(2)](#_DxCrossRefBm1709821309). It is not required to have a built-in fire suppression system. e. A Class F compartment (see [CS 25.857(f)](#_DxCrossRefBm1709821309)) is one in which there are means to control or extinguish a fire without requiring a crewmember to enter the compartment. Allowing access by a crewmember in the presence of a fire warning is not envisioned. Class F compartments that include a built-in fire extinguisher/suppression system or require the use of acceptable fire containment covers (FCCs) would meet these requirements. The Class F compartment must have a fire or smoke detection system installed in accordance with [CS 25.857(f)(1)](#_DxCrossRefBm1709821309). Unless there are other means of containing the fire and protecting critical systems and structure, a Class F compartment must have a liner meeting the requirements of part III of Appendix F, or other approved equivalent methods (see CS 25.855(b)). It is not envisaged that lower deck cargo compartments be approved as Class F cargo compartments. The Class F cargo compartment was introduced as a practicable and safe alternative to the previous practice of providing large Class B cargo compartments. These latter compartments were limited to the main deck for accessibility reasons. Lower deck cargo compartments in aircraft carrying passengers need to comply with the Class C cargo compartment requirements of [CS25.857(c).](#_DxCrossRefBm1709821309) 5. FIRE PROTECTION FEATURES Based on the class of the compartment, fire protection features must be provided. The fire protection features must be shown to meet the standards established by the original type certification basis for the aeroplane or later CS-25 standards. These features may include liners, fire or smoke detection systems, hand fire extinguishers, and built-in fire suppression systems. a. Liners The primary purpose of a liner is to prevent a fire originating in a cargo compartment from spreading to other parts of the aeroplane before it can be brought under control. For Class B compartments, it is assumed that the fire will be quickly extinguished. Therefore, the liner does not need to be qualified to the requirements of Part III of Appendix F. For Class F cargo compartments, the fire might have grown larger prior to being suppressed, and therefore, better protection is needed to prevent damage to surrounding systems and structure. However, the liner does not need to serve as the compartment seal. It should be noted, however, that the liner is frequently used to perform the secondary functions of containing discharged extinguishing agent and controlling the flow of oxygen into the compartment. If other means, such as compartment walls, are not capable of performing those functions, the liner must be sufficiently airtight to perform them. The liner must have sufficient fire integrity to prevent flames from burning through the liner before the fire can be brought under control and the heat from the fire is sufficiently dissipated. As stated in Part III of Appendix F, in addition to the basic liner material, the term "liner" includes any design feature, such as a joint or fastener that would affect the capability of the liner to safely contain a fire. b. Access (1) Class B. Class B compartments must provide sufficient accessibility to enable a crewmember to reach any part of the compartment by hand or with the contents of a hand extinguisher without physically entering the compartment. This requirement, by its nature, tends to limit the size and shape of the compartment. Additionally, the access provisions should be sufficiently large to enable the crewmember to determine visually that a fire has been extinguished. Access is also a function of how the compartment is configured rather than just dimension and/or volume. In determining access, it would not be acceptable for there to be a need to pull baggage or cargo on to the floor of the passenger compartment to gain access to the seat of the fire. Such action may introduce a safety hazard to the passengers. "To reach any part of the compartment" means that the crewmember should be able to open the door or hatch and, standing in the opening, reach by hand anywhere in the compartment where cargo or baggage can be located. The extension of the crewmember's reach through the use of fire extinguisher wands, etc., should not be considered in determining reach. Based on the estimated reach of a 95 percentile male, the outline of any compartment, viewed from above, should fit within a vertical cylinder of radius 132 cm (52 inches) measured from the centreline of the access door or hatch (see Figure 1). This dimension assumes the above male can reach a one foot square box located anywhere within the compartment. Access by a smaller crewmember to reach the same area within the compartment could require that the crewmember move laterally within the access door or hatch opening, while not physically entering the compartment.  Figure 1 Example of possible cargo compartment shapes within 132 cm (52 inches) reach from access point centreline. (2) Class F. In the case of a Class F compartment, a means should be provided to control or extinguish a fire without a crewmember entering the compartment. One means is to design the compartment to Class C requirements but not include a built-in fire suppression system. One suppression method might be to utilize a plumbing and nozzle distribution system within the compartment that would provide acceptable suppression capability throughout the volume of the compartment. The source for such a system could be hand fire extinguishers, which interface with the distribution system through a suitable interface nozzle. This reduces the complexity and costs associated with a built-in suppression system and could be suitable for smaller compartments. For certification purposes, the extinguishing agent concentration should be measured in flight, following aeroplane flight manual (AFM) procedures, and the length of protection time afforded by the system should be recorded. This time of protection should be used to establish AFM limitations for cargo or baggage compartment fire protection times. The operator, for route planning, could then use these times. For Halon 1301 fire extinguishing agent, a minimum five percent concentration by volume at all points in the compartment is considered adequate for initial knock-down of a fire, and a three percent concentration by volume at all points in the compartment is considered the minimum for controlling a fire after it is knocked down. This option requires the use of a liner as stated in [CS 25.855(b)](#_DxCrossRefBm1709821326). Another means of providing fire protection in a Class F compartment might be the use of cargo containers or fire containment covers (FCCs) shown to be capable of containing a fire. Some FCCs have already been developed and are typically constructed of woven fibreglass-based materials that will pass the oil burner test requirements of Part III of Appendix F. This is in line with the revised [CS 25.855](#_DxCrossRefBm1709821326) which for a Class F cargo or baggage compartment not using FCCs requires a ceiling and sidewall liner constructed of materials that meet the requirements of Part III of Appendix F and be separated from the aeroplane structure (except for attachments), while the floor panels must comply with Part I of Appendix F. Similarly, if FCCs are proposed as a means of compliance for the new Class F compartment, it is likely that in order to meet the intent they must also meet these standards (i.e. Part III of Appendix F for the sides and top and Part I of Appendix F for the bottom). However, based on full scale qualification testing there is evidence that alternative materials, not fully in compliance with Part III of Appendix F, might also be acceptable for FCC side and top portions, as long as they are successfully tested and meet the intent of the rule. It is recommended that the Agency be contacted for concurrence when FCC or Container qualification is envisaged in order to address the relevant test method. Unless evidence can be presented to support a different design, if FCCs are used as a means of compliance, they should completely surround all cargo, including underneath the cargo, except for obviously non-flammable items, such as metal stock, machinery, and non flammable fluids without flammable packaging. Because the fire is controlled or extinguished within the isolated compartment, but is separated from the actual cargo compartment boundaries, the cargo compartment liner requirements of [CS 25.855(c)](#_DxCrossRefBm1709821326) would not apply. However, the effects of the heat generated by the contained/covered fire should be evaluated to ensure that adjacent systems and structure are not adversely affected. For certification purposes, test data with the actual design configuration and possible fire sources would have to be provided. The temperature and heat load time history measurements at various locations above, around and below the FCC are needed to ensure the continued safe function of adjacent systems and structure. The time history data should be used to establish the length of protection time afforded by the system and subsequent AFM limitations for cargo or baggage compartment fire protection times. The operator would then use these times for route planning purposes. Class F cargo compartment designs which rely on fire containment, e.g. fire hardened containers/pallets and/or FCCs (placed over palletised loads or non-fire hardened containers) should be considered in regards to the possibility of incorrect usage. All practicable means to prevent the carriage of cargo in standard containers or pallets (if special pallets are required) and/or the omission of FCCs should be incorporated. Means may include, but not be limited to, physical features at the container/pallet to cargo compartment floor interface or operational procedures such as requiring aircraft crew verification of cargo loading before every flight or a suitable detection system that would warn the crew in the event a non authorized cargo configuration has been loaded. c. Extinguishing Agent. In order to effectively extinguish or control a fire in a Class B or F cargo or baggage compartment, sufficient fire extinguishing agent must be allocated. Guidance on this topic is contained in FAA AC 20-42D. This guidance material is accepted by the Agency as addressing how to implement the provisions of CS 25.851(a) that require that at least one hand fire extinguisher be located in the pilot compartment, at least one readily accessible hand fire extinguisher be available for use in each Class A or Class B cargo/baggage compartment and in each accessible Class E or Class F cargo/baggage compartment, and one or more hand fire extinguishers be located in the passenger compartment for aeroplanes with a passenger seating capacity of 7 or more. d. Fire Control. "To control a fire" ([CS 25.857(f)(2)](#_DxCrossRefBm1709821309)) implies that the fire does not grow to a state where damage to the aeroplane or harm to the passengers or crew occurs during the time for which the fire protection system is demonstrated to be effective (ie, from the time a fire is detected to the time when an emergency evacuation from the aeroplane can be completed). This in turn implies that critical aeroplane systems and structure are not adversely affected and the temperature and air contaminants in areas occupied by passengers and crew do not reach hazardous levels. (1) Adequate protection should be provided for cockpit voice and flight data recorder and wiring, windows, primary flight controls (unless it can be shown that a fire cannot cause jamming or loss of control), and other systems and equipment within the compartment that are required for safe flight and landing. (2) Regardless of a compartment’s classification, it must be demonstrated that hazardous quantities of smoke, flames, extinguishing agent, or noxious gases do not enter any compartment occupied by passengers or crewmembers. FAA Advisory Circular 25-9A, Smoke Detection, Penetration, and Evacuation Tests and Related Flight Manual Emergency Procedures, provides guidance concerning smoke penetration testing. (3) If an aeroplane has one or more Class B cargo compartments, portable protective breathing equipment must be provided for the appropriate crewmembers in accordance with [CS 25.1439](#_DxCrossRefBm1709821351). (4) Additional protective breathing equipment or breathing gas supply, and additional fire extinguishers, may be required for Class B cargo compartment operation to ensure that the fire can be controlled for the time the aeroplane is expected to be in the air after onset of a fire. 6. PROCEDURES AND LIMITATIONS a. To ensure that the contents of Class B and F compartments are either accessible or located such as to allow firefighting, any cargo or baggage loading limitations and any operational limitations or procedures provided must be identified with placards in the compartment. The loading and operational limitations must also be addressed in the appropriate weight and balance or loading document. b. Any operational limitations or procedures necessary to ensure the effectiveness of the fire protection system for Class B and Class F cargo and baggage compartments should be clearly defined in the AFM. This should include such items as any changes to the ventilation system to prevent the entrance of smoke or gases into occupied areas, use of hand fire extinguishers, use of protective breathing equipment, use of protective clothing, and use of the FCCs. The certification engineers should work closely with the Agency to ensure that additional training necessary for crewmembers assigned to combat fires is adequately addressed. c. Any time limit for a cargo or baggage compartment fire protection system, or other conditions or procedures related to combating a fire in a compartment, should be clearly defined in the AFM. 7. AFM CONSIDERATIONS. a. Crewmember(s) designated to combat a fire in a Class B compartment will need special training. Fires occurring in luggage are difficult to extinguish completely and rekindling may occur. Crewmembers designated to combat fires in Class B compartments should be trained to check periodically to ensure that a fire has not grown back to hazardous proportions. b. Aeroplane flight manuals should contain instructions to land at the nearest suitable airport following smoke/fire detection, unless it can be positively determined that the fire is extinguished. c. Any limitations regarding occupancy of Class B and Class F compartments during flight, or during takeoff and landing, should be defined in the AFM. d. Any loading restrictions associated with access to cargo or baggage or special containers should be clearly identified in the AFM. This would include, but not be limited to, placement of luggage in a Class B compartment or identification of special containers or covers associated with fire protection in a Class F compartment. If covers are used in conjunction with a Class F cargo compartment, they should be easy to install and sufficiently durable to withstand in-service conditions. [Amdt 25/8] [Amdt 25/11] [Amdt 25/12] [Amdt 25/26]