June 12, 2025

Steven Bentley

How to Use This Risk Register in Safety System Benchmarking & Analysis

  • Benchmarking: Compare your cargo airline’s risk exposures against industry best practices, EASA requirements, and peer organizations.
  • Analysis: Prioritize risks based on likelihood and severity, evaluate existing controls, and identify gaps in hazard mitigation strategies.
  • Continuous Improvement: Regularly review and update the risk register, integrating lessons from audits, incident reports, and operational feedback.
  • Training & Awareness: Use the risk register to inform targeted training programs, safety campaigns, and leadership workshops.
  • Evidence for Compliance: Demonstrate proactive risk management in your SMS, including evidence of hazard identification, risk assessment, mitigation planning, and performance monitoring.

Organizational and Administrative Risks

  • Inadequate Resource Management: Insufficient staffing, fatigue risks, skills gaps, or poor manpower planning leading to operational stress.
  • Ineffective Policies & Procedures: Outdated, incomplete, or poorly enforced SOPs causing inconsistencies in operations.
  • Organizational Culture Weaknesses: Lack of safety reporting, poor safety leadership, or resistance to change hindering continuous improvement.
  • Leadership & Governance Failures: Ineffective management oversight, unclear responsibilities, or failure to address safety priorities.
  • Ineffective SMS Implementation: Poor hazard identification, risk assessment, safety performance monitoring, and continuous improvement.
  • Change Management Gaps: Insufficient planning for equipment upgrades, process changes, or organizational restructuring.

Flight Operations Risks (Cargo Specific)

  • Incorrect Cargo Loading & Distribution: Improper weight and balance calculations, unsecured cargo, or shifting loads during flight.
  • Undeclared or Misdeclared Dangerous Goods: Dangerous goods improperly identified, packaged, or documented by shippers or freight forwarders.
  • Improper Handling of Lithium Batteries or Dry Ice: Non-compliance with packaging, labelling, or stowage standards.
  • Inadequate Airworthiness Checks Before Dispatch: Missed inspections or unaddressed defects impacting flight safety.
  • Obsolete or Incomplete Operational Documents: Missing flight manuals, NOTAMs, or outdated charts.
  • Fuel Quality & Loading Errors: Incorrect fueling, contamination risks, or quantity discrepancies.
  • Operational Deviations: Response failures during rerouting, weather diversions, or airspace restrictions.
  • In-Flight Security Threats: Cargo hold fire, smoke, or potential sabotage.

Ground Handling Risks

  • Equipment Misuse & Damage to Aircraft: GSE collisions, improper docking, or failures during pushback or loading.
  • GSE Positioning Hazards: Blocked escape routes, obstructed hydrant access, or unsecured equipment left near aircraft.
  • Ramp Congestion & Resource Shortages: Overlapping ground activities, lack of equipment, or delays impacting aircraft turnaround.
  • Ground Personnel Competence Gaps: Insufficient training, poor hazard awareness, or fatigue leading to errors.
  • De/Anti-Icing Errors: Incorrect application procedures, fluid quality, or environmental contamination.

Maintenance & Engineering Risks

  • Inadequate Maintenance Oversight: Poor QA processes, unapproved repairs, or gaps in maintenance documentation.
  • Incorrect Maintenance Practices: Human factors errors, non-compliance with OEM procedures, or improper tool usage.
  • Deficient Reliability Monitoring: Failure to detect emerging trends or systemic failures through reliability analysis.
  • Inadequate Spare Parts Control: Use of unapproved or counterfeit parts, poor inventory management, or shortages.
  • Unscheduled Maintenance Impacts: Unplanned defects leading to operational delays or safety concerns.

Cargo Operations Risks

  • Cargo Mis-Identification: Dangerous goods not declared, incorrectly labelled, or misclassified.
  • Temperature-Controlled Cargo Failures: Loss of temperature integrity in pharmaceutical or perishable shipments.
  • Shifting Loads or Load Collapse: Improperly secured ULDs, pallets, or containers causing instability.
  • Container or Pallet Device Malfunction: Fires from powered containers, battery issues, or dry ice sublimation risks.
  • Human Error in Cargo Documentation: Incomplete or inaccurate cargo manifests impacting safety or regulatory compliance.

Security Risks

  • Cargo Security Breaches: Unauthorized access to cargo, tampering, or smuggling attempts.
  • Insider Threats: Potential for sabotage or theft by employees or contractors.
  • Terrorism & Sabotage: Direct or indirect threats against aircraft, facilities, or cargo.
  • Inadequate Security Screening: Failure to detect prohibited items or dangerous goods.
  • Cybersecurity Threats: Risks of data breaches, ransomware, or system manipulation impacting flight safety or cargo integrity.

External & Environmental Risks

  • Adverse Weather Events: Storms, lightning, or temperature extremes affecting cargo integrity or operations.
  • Natural Disasters: Earthquakes, floods, or volcanic activity impacting infrastructure.
  • Third-Party Service Failures: Disruptions from fueling, catering, cleaning, or de-icing contractors.
  • Regulatory Non-Compliance: Failure to meet EASA, ICAO, IATA, or local authority requirements.
  • Geopolitical & Economic Instability: Sanctions, conflicts, or economic shocks affecting operations or cargo flows.

Human Factors & Competency Risks

  • Fatigue Management Failures: Insufficient rest periods, high workload, or poor shift scheduling.
  • Training Deficiencies: Gaps in initial, recurrent, or emergency training across flight, ground, and cargo operations.
  • Communication Failures: Misunderstandings between teams, unclear instructions, or language barriers.
  • Procedural Non-Compliance: Shortcuts, workarounds, or “normalized deviance” leading to unsafe practices.

Technology & System Risks

  • IT System Failures: Disruptions in flight planning, dispatch, or cargo management systems.
  • Automation Over-Reliance: Complacency due to automation, leading to reduced situational awareness.
  • Data Integrity Risks: Errors in weight and balance, flight plans, or cargo documentation.
  • Integration Failures: Misalignment between systems (e.g., warehouse management and load planning).

Next Steps

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Cargo Airline, Flight Operations Risks, Cargo Specific, Culture Weaknesses, Policies, Resource Management, Evidence for Compliance, Training & Awareness, Cargo Airline Risk Register, Safety System, Safety System Benchmarking, Aviation Safety Management System (SMS), continuous improvement, Risks, SAS blogs, analysis, Procedures, Risk Register