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Complete and attach this cover sheet to your assessment before submitting
Grade/Mark: 82
Comments:
Mohamed’s paper was good and seemed very structured in terms of the flow of information. The use of
sub-titles within each section made it easy to follow. The section about “technologies” stood out as the
examples given were very good and applicable to the assignment question. Some parts however could
use more depth such as the “impact/effect”. Overall, a good paper.
2
Assignment 1 – Report (Individual)
You are required to write a 3000-word report (+/- 10%) on the following topic:
Air freight has traditionally been viewed as the weak link within cool chain.
1. With specific reference to pharmaceuticals (LO1) explain in detail (a) what is the cool chain
and how the cool chain functions, (b) identify those areas of air cargo operations (LO1)
where the chain is most likely to break and (c) the technologies that are used by the
aviation industry to ensure compliance with cool chain requirements.
2. IATA recently launched CEIV Pharma as a “concerted effort to improve the level of
competency, operational and technical preparedness”. Describe in detail (a) why this
programme is required, (b) what this programme entails, and (c) the impact and effect it
will have on agents, airlines and airport service providers in improving the cool chain
performance of the aviation industry, (LO1).
Apply NETS theory to cool chain air cargo operations, listing and discussing the various networks
which apply to cool chain air cargo operations (LO2).
To score well in this assignment you should cover all the bullet points and expand on them in full including
clear explanations and examples where appropriate. The reason for writing anything, including a report, is to
communicate your message effectively and failure to do this will result in a loss of marks. You must make sure
that you relate your findings to the transport and logistics industry to demonstrate how theory can translate
into effective risk management. Finally, your report should be professionally written and presented as is
expected in an industry setting. Errors such as typos, spelling mistakes and poor formatting do not meet the
expected industry requirements.
This assignment should be written on this document (a Microsoft Word document - do not PDF the file) and
appropriately formatted; headings and subheadings should be used, you should use either Calibri or Arial font
(size 11 – excluding headings and subheadings), your work should be double-spaced, and pages should be
numbered. Remember to reference your work (including in-text referencing) at all times using the APA format.
Submissions – Use this document as the template for your submission! Please submit the whole document
including cover page, instructions, your report and the rubric via Moodle. All assignments will be checked for
plagiarism and originality using Turnitin. All submissions must be saved using the following naming convention
(failure to do this may result in your assignment not being marked):
First Name ID number Assignment 1
e.g. Ahmed 20109090 Assignment 1
BILM Assignments – Rules & Guidelines
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ACADEMIC INTEGRITY & HONESTY: When submitting an assignment, you are confirming that you have adhered to
Bahrain Polytechnic’s policy on academic integrity and honesty including using APA referencing appropriately. Any
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WORD LIMIT: All assignments have a required word limit which we permit a variation of +/-10%. For example, an
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tutor will stop marking at that point where it is 10% over (e.g. 3300 words for an assignment with a 3000-word limit). You
will not receive any marks for work that is submitted outside of the maximum word limit.
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over how well the group has functioned or whether all members of the group have contributed equally. During the
defence, each member of the group is asked questions relating to the group’s submission. It is expected that all members
of the group have a thorough understanding of the whole assignment. Only the person asked the question may respond
until the tutor invites others to expand on the initial response. Failure to attend the defence will result in an automatic
mark of zero for the assignment unless extreme circumstances apply. Based on your performance, you will receive an
individual ‘adjusted’ mark for the assignment based on the following criteria:
Displays a thorough understanding and knowledge of the contents of the assignment
Is able to expand on the responses of other members of the group x1
Has clearly been a key member of the group
Displays a good understanding and knowledge of the contents of the assignment although there may
be minor gaps
x 0.9
Is usually able to expand on the responses of other members of the group
Has clearly been a contributory member of the group
Displays some understanding and knowledge of the contents of the assignment although gaps are
noticeable
x 0.75
Is sometimes unable to expand on the responses of other members of the group
Appears to have been a contributory but peripheral member of the group
Displays a poor understanding and knowledge of the contents of the assignment
Is frequently unable to expand on the responses of other members of the group or offers unhelpful
x 0.5
contributions
Has clearly offered little to the group as a whole
Displays no understanding or knowledge of the contents of the assignment
Is unable to expand on the responses of other members of the group and any contributions are
x 0.1
unhelpful or unrelated
Has clearly not contributed to the group
For example, following the defence, individual marks for a group assignment which was awarded a final mark of 85% may
be adjusted as follows: Student A: 85 x 1 = 85% / Student B: 85 x 0.75 = 63.75% / Student C: 85 x 0.1 = 8.5%
GHOST WRITERS / ESSAY MILLS: In cases where there is strong concern over the authorship of your submission (i.e. we
suspect someone has written it for you), you will be required to attend a meeting with your tutor and PM or HoS to
‘defend’ your work. If you are unable to satisfy all parties that the work is yours by displaying a thorough knowledge of
the contents, concepts, terminology etc, a full academic misconduct investigation will be carried out. Due to the severity
of this, a possible outcome is your permanent exclusion from the Polytechnic.
Please refer to the generic Course Guide or your tutor is you require further clarification of the above points.
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Report (Assignment 1)
5
Table of Contents
.........................................................................1
Introduction.....................................................................................................................................6
CEIV Pharma..................................................................................................................................11
Requirement of the initiative.....................................................................................................................11
CIEV Pharma Initiative...............................................................................................................................11
Impacts and effects of the initiative...........................................................................................................13
NETS Theory...................................................................................................................................14
Bibliography...................................................................................................................................16
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Introduction
As all organizations have their own supply chain, pharmaceuticals have their own unique cool chain, we will
get to know what a cool chain and how it functions while knowing the technologies needed.
The report will focus on why the what was the need of why IATA recently launched the CEIV pharma to the
aviation industry.
Additionally, the report will get into detail concerning the why the initiative is required and what it entails.
Also, what the initiative impact and effect it will have on agents, airlines and airport service providers in
improving the cool chain performance of the aviation industry.
Finally, a discussion on the various networks of the NETS theory when applied to the cool chain aviation
industry.
Supply chain is vital in every organization and every organization has a unique supply chain of its own, the
transportation of goods can either be by road, rail, sea and air according to hat is most suitable.
A basic view of a supply chain is the collecting RM from suppliers in upstream suppliers, gathering the product
to produce a final product and move it downstream to consumers throughout the chain.
Same process applies for pharmaceuticals but with concentrated care as the goods are sensitive.
Cool chain refers to the management and the handling of temperature sensitive products that are transported
from the beginning of the supply chain till the endpoint[ CITATION Ten12 \l 1033 ] .
Some products require ‘temperate’ and other require a ‘sub-zero’ to not get degraded. According to
pharmaceuticals, vaccines and other drugs generally require a temperature control range of 2-8 degree Celsius
throughout the chain to remain in good condition [CITATION Bah \l 1033 ].
Pharmaceuticals needs to be temperature controlled throughout each step in the supply chain, specially in
the loading and unloading environment when temperature is endangered from temperature change.
While the life of millions depend on pharmaceuticals, the ability to ship across long distances while
maintaining very low temperature is crucial to organizations and needs the following elements:
personnel to manage vaccine distribution [ CITATION Wor18 \l 1033 ]- any interactions with weather
changes will directly affect the vaccines.
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Equipment storage and transport [ CITATION Wor18 \l 1033 ]- requires a cold environment to be
stored in and transported. Refrigerated truck etc.
Maintenance of equipment [ CITATION Wor18 \l 1033 ]- equipment of the drugs must be 24/7
functional to support immunization activities through out the cool chain.
Monitoring [ CITATION Wor18 \l 1033 ]– monitoring equipment, temperature and transportation.
There are some scenes that requires critical planning such as when flights are delayed,
pharmaceuticals are not be paused for a longer time or else a catastrophe will happen.
The more activities added to the cool chain, the more the risk increases thus, any failure along the chain can
ruin the whole cargo.
Air freight is a weak link in the cool chain, as there are no temperature or atmosphere controlled
ULD’s [ CITATION Bah \l 1033 ]. Some scenes occur when the aircraft is on air the temperature is
below -30 degrees where heat is required.
Insulated vehicles should be able to load and unload inside a controlled temperature area like
warehouse or terminals.
Aircraft delays on ground.
Transport area from production to store, from store to cargo facility, facility to aircraft where
pharmaceuticals are exposed to different environments and temperature stages.
Process:
Phase 1
In the first stage the activities consist road transport from production to the airport by a 3 rd party logistics
company that plans the movement physical movement. Additionally, includes insulation packaging,
temperature tracking equipment that forms of coolants to create additional insurance in the cool chain. A
simple example that can be used is the pressure-sensible label which is a temperature gauge that changes
color alerting the supply chain of a disruption or danger in the cool chain when the goods are exposed to
temperature change during the loading and the un-loading of the goods [ CITATION NCS18 \l 1033 ]. This also
digitally keeps track of the goods in the cool chain.
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Phase 2
In the second stage, activities such as aircraft freight and storage in airports will occur, goods will be delivered
to the airports handled by flight forwarders carriers that can be such as emirates, DHL etc. The air cargo agent
will arrange pick ups and deliveries with the 3 rd party logistics companies, and maintain detailed tracking
record of cargo.
Airports have now started facilitating with temperature controlled stores that the goods will be stored in until
the aircraft is ready to be loaded [ CITATION Wor18 \l 1033 ].
Phase 3
Pharmaceuticals will then reach to other facilities which are distribution centre where then to be distributed
to the receiver who are medical centre and the end customers. The distribution way will be integrated and not
consolidated. Goods will be integrated to optimize the supply chain, reduce the costs, time and minimize the
risks of a breach of temperature protocols [ CITATION Bah \l 1033 ]. So goods will be loading for instance from
two truck loads into one truck load, shipments consolidated with multiple-stop routing [ CITATION Bah \l
1033 ].
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Technologies:
In order to guarantee safe freight of drugs, biotech and pharmaceutical products application of temperature
control, tracking and packaging technology is required to assure quality control of supply [ CITATION Bah \l
1033 ].
To do so and maintain sustainability of the pharmaceuticals, technologies plays a key role and it compromises
of hardware’s and software’s.
Hardware’s:
To be more specific hardware’s are the tangible technologies used to control and have safe environment in
compliance to pharmaceuticals.
ULD’s
Monitoring tracking devices recognizes the fluctuations of the temperature and alerts if the pharmaceuticals
are endangered. In means of vaccines, the state distributions centres must use cool chain monitors or data
loggers when transporting vaccines [ CITATION Wor181 \l 1033 ].
Also, the regional distributions are to use cool chain monitors, minimum/maximum thermometers, while
sending ISP’s in their regions, as recommended in the national vaccine storage [ CITATION Wor181 \l 1033 ].
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As a result, ground handlers and air cargo agents will have information and updates of the condition regarding
to the pharmaceuticals, and will help manage to keep an eye. As if it was in the only in the responsibility of
employees, human errors are likely to occur. The monitoring devices will provide accurate information about
the condition and will reduce any likely risk. Yet, the monitoring devices will need maintenance from time to
time to stay sustainable.
As the technologies in the world are emerging day by day, FedEx now for the first time has chartered an entire
temperature-controlled plane for health care on April 2018 [ CITATION Coo18 \l 1033 ]. This is one of the most
innovative ways that FedEx is using its convoy. The charters can maintain a temperature control of 2-8 degree
Celsius which is suitable for most of the pharmaceutical products [ CITATION Coo18 \l 1033 ].
This type of aircraft will make an impact in the aviation industry, because if pharmaceuticals are assured of the
required temperature throughout the air freight it will lead to efficient delivers. Additionally, it will also help to
reduce the other operations in the aircraft. Stakeholders will start to also invest more in this particular
technology in the aviation industry [ CITATION Coo18 \l 1033 ].
ExpediteTC Passive
Expeditetc is the first US-based passenger carrier approved to carry the full suite of
pharmaceuticals[ CITATION Ame18 \l 1033 ].
American airline cargo has launched the expeditetc to complement their active temperature controlled
services [ CITATION Coo18 \l 1033 ]. it is a thermal packaging that is used by the airlines, which the goal is to
control the pharmaceuticals that needs extra temperature control from the cargo facility to the time loading
into the aircraft which is 90 minutes [ CITATION Coo18 \l 1033 ]. The expeditetc uses phase-change material,
cool packs or dry ice that is exactly what most pharmaceuticals are in critical need.
Software’s
As to the software, the software is the intangible service that completes the all of the technologies mentioned
above. It will provide agents and ground handlers to control the technologies which are provided to the
pharmaceuticals. To be more specific, the monitor devices will alert if the pharmaceuticals are exposed to
irrelevant weather condition being showed in the system, the agent will realize and will have to set the
temperature to a more suitable environment through the system.
Which to sum it up, the hardware and software complete each other to bring out the final efficient handling of
the pharmaceuticals.
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CEIV Pharma
IATA introduced the CEIV Pharma lately due to poor regulations and weak processes that had negative effects
on cool chains of pharmaceuticals [ CITATION IAT \l 1033 ]. The negative effects included defects in the
pharmaceuticals, returns and loss of costs because of lack of compliance with the past poor regulations
[ CITATION IAT \l 1033 ]
This is because of not being able to fully control the temperature throughout the cool chain process, while
also, increased in losing costs because airfreight is costlier than sea freight which when the goods are put to
reversed logistics, which caused a logistical catastrophe to the aviation industry.
Because of this, IATA had decided to develop the CEIV Pharma initiative which explains newly developed
regulations and rules such as, temperature requirement, handling procedures and safety strategies in
transporting pharmaceuticals to customers and to control the cool chain much better than before [ CITATION
IAT \l 1033 ]
An illustration on why the CEIV Pharma initiative was required is provided below in figure 3:
The CIEV Pharma initiative entails lately developed temperature regulations, cargo handling procedures and
proper standards to ensure efficient air cargo operations for pharmaceuticals [ CITATION Ait18 \l 1033 ].
The temperature regulations include specific equipment, storage facilities, coordinated handling procedure
which is a complex logistical process.
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Equipment and training standards
The specific equipment that are required to be utilized with respect to the CIEV Pharma Initiative, to comply
with all the safety standards to meet the requirements of the customers without developing issues in the cool
chain. The employees are required to have training to correctly use the equipment for different kinds of
handling. Safety standards include guidelines from health and safety organizations such as the WHO
[ CITATION Ait18 \l 1033 ]
As an example, the employees must properly follow instructions in how to deal with pharmaceuticals such as
health and personal protective clothing as it will aid in control the products more adequate. This is to remove
any possible risks that might have impacts and effects on the pharmaceuticals.
However, the employees must have training sessions on how to handle equipment’s such as ULD’s, cool dollies
etc. to have a better understanding and be efficient to when it comes to following the instructions required to
deal with the pharmaceuticals.
The initiative also entails the need for improving regulations for proper agreement combined with proper
training for employees involved in the activities of the initiative [ CITATION Ait18 \l 1033 ] This is for
management purposes in terms of quality and ethics to make sure the air cargo operations such as cargo
handling by ground handlers, to assess such against the requirements for the purpose of managing the cool
chain quality as mentioned.
These regulations are crucial to minimize the risk in failures that occur while processing the activities in the
cool chain. While it will also improve the aviation industry into achieving better results and maintaining ‘in
full, on time, in specifications.’ For future efficient deliveries of pharmaceuticals.
The storage is where the pharmaceuticals are kept in an environment suiting the requirements needed to
keep the goods safe till its ready for dispatching or distribution.
The storage procedures and requirements are important for the cool chain for air cargo operations as
employees are required to follow the proper policies to properly store pharmaceuticals under different
environments [ CITATION Wor10 \l 1033 ].The policies include the storage areas that are designed and meant
for the storage of pharmaceuticals.
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The products must be around a well cleaned and dry areas in an airport storage facility in order to succeed in
doing so to continue the flows of the cool chain until the products reach the consumers and end-customers
[ CITATION Wor10 \l 1033 ] The storage activities must also be recorded such as changes in temperature
range between specific time intervals to ensure an efficient handling and safety.
The activities and stages that the goods pass by in the storage facilities are vital to be tracked and recorded as
when it reaches to the medical centres and other consumers, documents are needed for proof and to
continue the process of handling the pharmaceuticals. As they are very sensitive products.
Since the program has applied its recent regulation and requirements. There are some initiatives that
influenced and some that had made a result in the aviation industry.
The implementation and the influence that the CEIV Pharma has provided, countries got influenced and
started an almost worldwide trend to the developing countries to focus on the issue of creating their own
rules and regulations guidance on how to handle the operations of the pharmaceuticals in air freight
[ CITATION Ait18 \l 1033 ].
As a result of that, although the focus grew on the higher standards, it led to more careful handling of
pharmaceuticals in their temperature and transportation and also dealing with the same inevitable issues that
the airlines face, in a better way than before [ CITATION Ait18 \l 1033 ].
Another influence is that it is expected that the numbers would increase of the air freight shipments of
pharmaceuticals due to the safety that will increase and the regulations effected and the global trends like the
demographics and economic development in various regions according to Juerg Zimmermann, Executive Vice
President Airline Handling for Cargo logic [ CITATION Ait18 \l 1033 ].
In result of the CEIV Pharma, many air carriers, handlers and freight forwarders responded to the creation of
the “pharma-regulated” and has been applied to several cargo aviation organizations. Which leads to
stakeholders investing again in the aviation industry for the movement of the pharmaceuticals [ CITATION
Ait18 \l 1033 ].
NETS Theory
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The NETs theory is about the networks that are connected together that apply to cool chains of air freight.
The networks consist of traffic, communication, auxiliary services, regulations, infrastructure and skill
[CITATION Tif07 \l 1033 ] .
Regulations
The regulations are about the standards and rules that are being put by airline organizations such as IATA and
the standards that they have. The regulations include temperature control regulations, cargo handling
procedures and safety requirements which has to be properly authorized and followed by trained employees
and agents [CITATION Tif07 \l 1033 ]. The regulations should be properly implemented so that the
performance of the air cargo be accurate and effective.
Infrastructure
The infrastructure is about the buildings and other structures such as roads that are being used for air cargo
operations. The aviation industry uses such as warehouses in airports for appropriate storage of perishable
products that are involved in cool chain[CITATION Tif07 \l 1033 ] The storage areas must be appropriately
placed and positioned based on the infrastructure of the airport itself to avoid problems such as traffic
congestion of the cool chain as it is critical to reduce the destination time while transporting goods in means of
pharmaceutical [CITATION Tif07 \l 1033 ].
Skills
The skills network is about the abilities of the agents who handle all the operations based on air cargo. This
network mostly includes the training that the agents and staff should have to follow the regulations while
operating appropriately, because this skill network is the most that links to the other networks [CITATION
Tif07 \l 1033 ].
The training of the staff mostly includes the handling of the cargo using technical equipment such as ULD’s,
monitoring devices etc., also includes how to appropriately store the pharmaceuticals at the right place and
time to avoid any possible consequences, in addition to follow the regulations for storing pharmaceuticals
[ CITATION Tif07 \l 1033 ].
Traffic
The traffic network highly relates with infrastructure because of their shared connection in the use of traffic in
infrastructure facilities like roads and airports. When cool chain related products are being transported, it is
important to manage their transportation due to the vast usage of freight and transportations worldwide. The
transportation consists of the physical movement of goods from one place to another, loading and unloading
from point A to point B. For instance, When the mode of transport is such as aircrafts, it is critical to control
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the traffic of the aeroplanes by traffic control systems to not cause any catastrophe as the aviation industry is
very sensitive by the timings.
Auxiliary (ASP)
Auxiliary network is about Auxiliary Service Providers are who provide the assistance and the safety of the
transportations and other activities that operate in the cool chain. [ CITATION Tif07 \l 1033 ]. Auxiliaries can be
police officers, ambulance, civil defence fire workers. When goods are transported through insulated trucks,
and the insulated truck driver is not driving in the right track of the road where lighter vehicles should be
driving, the police car will stop the driver and give out a fine, for putting other people and the products carried
at risk.
To be more specific, if by any chance any consequences went wrong and a fire started in an airport, the civil
defence will directly get notified by the alarms of the airport and rush to the airport to shut the fire off.
Communication
The communication network is critical to the cool chai and the aviation industry, information can be
exchanged, noticing instructions and instructing [ CITATION Tif07 \l 1033 ]. In the means of when an airplane is
on air it is vital to communicate with the traffic control towers to get the instruction while flying. However,
while moving the pharmaceuticals from the stores to the loading point by ground handlers, it is vital to
communicate with agents to know whether the aircraft is ready or not to not keep the products at risk.
Bibliography
16
Aitken, R. (2018, Jan 1). CEIV Pharma: industry cooperation that is taking off. Retrieved from international
airport review: https://www.internationalairportreview.com/article/21726/ceiv-pharma-industry-
cooperation-thats-taking-off/
American Airlines Cargo. (2018, Jan 1). ExpediteTC. Retrieved from American Airlines:
https://www.aacargo.com/ship/expediteTC.html
Bahrain Polytechnic University. (n.d.). Retrieved from Air Cargo Handeling and Management:
https://moodle.polytechnic.bh/moodle/course/view.php?id=289
Boeing. (2013, 3 1). Pallets and Containers. Retrieved from Boeing:
http://www.boeing.com/resources/boeingdotcom/company/about_bca/pdf/CargoPalletsContainers.pdf
Cool Chain Association. (2018, Jan 1). Cool Chain Association. Retrieved from Cool Chain:
http://coolchain.org/air-cargo-and-the-cold-chain
IATA. (n.d.). CEIV Pharma. Retrieved from IATA.org:
http://www.iata.org/whatwedo/cargo/pharma/Pages/ceiv-pharma.aspx
NC State University. (2018, Jan 1). Managing the Cold Chain. Retrieved from scm.ncsu: NC State University
Tennermann, J. (2012, 6 20). Cold Chain for Beginners. Retrieved from PharmaPro:
https://www.pharmpro.com/article/2012/06/cold-chain-beginners
Tiffin, J., & Kissling, C. (2007). Transport Communication. London.
World Health Organization. (2010, Jan 1). Retrieved from WHO.int:
http://www.who.int/medicines/areas/quality_safety/quality_assurance/GoodDistributionPracticesTRS957Ann
ex5.pdf
World Health Organization. (2018, Jan 1). Retrieved from World Health Organization:
http://www.health.wa.gov.au/circularsnew/attachments/623.pdf
World Health Organization. (2018, Jan 1). EPI logistics. Retrieved from
http://www.who.int/countries/eth/areas/immunization/epi_logistics/en/index1.html
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Marking Rubric for Assignment 1: Report (Individual)
Met criteria to an Met criteria to a very Met criteria to a Did not meet
Assignment excellent standard good standard satisfactory standard criteria
Weighting 35%
A B C F
(30 - 25.5) (25.4-21) (20.9 – 18) (17.9 – 0)
(20 – 17) (16.9 – 14) (13.9 – 12) (11.9 – 0)
(10 - 8.5) (8.49 - 7) (6.9 - 6) (5.9 - 0)
All elements are All elements are There is a basic There is little or no
(A) Explain in detail with specific reference to
comprehensively and concisely explained, with overview of the explanation of the
pharmaceuticals what the cool chain is, how it functions
clearly explained, with a a reasonable list of weak elements with some elements with some
and the weak spots
comprehensive list of spots identified. reference to weak information being
20 marks weak spots identified. spots. incorrect. References to
weak spots are vague
17 marks
and/or incorrect.
(B) Explain in detail the technologies that are used by All elements are All elements are There is a basic There is little or no
the aviation industry to ensure compliance with cool comprehensively and concisely explained, with overview of the explanation of the
chain requirements. clearly explained, with a a reasonable list of elements with some elements with some
comprehensive list of technologies used. reference to the information being
20 marks
technologies used. technologies used. incorrect. References to
18 marks technology are vague
and/or incorrect.
(C) The IATA CEIV Pharma scheme narrate why this All elements are All elements are There is a basic There is little or no
programme is required; what it entails, and the impact comprehensively and concisely and clearly overview of all the explanation of the
and effect it will have on agents, airlines and airport clearly explained in explained with both the elements with some elements with some
service providers in improving the cool chain detail with both the impact and effect this will narration of the information being
performance of the aviation industry impact and effect this have on the parties impact and effect this incorrect and
will have on the parties involved being concisely will have on the references to the
involved being narrated. parties involved. impact and effect this
30 Marks comprehensively will have on the parties
23 marks narrated. involved are vague
and/or incorrect.
Nets theory correctly Nets theory generally Nets theory is partially Nets theory is vaguely
applied to cool chain air correctly applied to cool applied to cool chain applied to cool chain air
(D) Nets theory applied to cool chain air cargo cargo operations with chain air cargo air cargo operations cargo operations with
operations, listing and discussing the various networks an excellent & operations with a concise with some discussion little or no discussion of
which apply to cool chain air cargo operations comprehensive discussion of the various of the various the various applicable
discussion of the various applicable networks. applicable networks. networks, some of
20 Marks
applicable networks. which are vague and/or
17 marks incorrect.