U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Carriage of Cargo Date: 1/25/22 AC No: 120-85B Initiated by: AFS-200 Change:
This Flight Standards Service advisory circular (AC) contains guidance on air carriers’ and operating Certificate Holders’ cargo operations. Proper cargo loading is essential for safe flight operations. Air carriers and operators must have procedures in place that provide information or instructions relating to safety per Title 14 of the Code of Federal Regulations (14 CFR) part 91, § 91.1025(r); part 121, § 121.135(b)(26); part 125, § 125.73(r); and part 135, § 135.23(s)). These should include procedures to ensure that employees and vendors are properly trained in the process, the loading is properly completed, and cargo restraints and loading devices are properly maintained. The operator must ensure that employees with the duty of supervising the loading of aircraft and preparing the load manifest, including the flightcrew, the load supervisor, loading personnel, and the person designated by the operator to perform Weight and Balance (W&B) calculations, all take responsibility to ensure that the process is completed correctly per § 121.665. The Federal Aviation Administration (FAA) intends this AC for air carriers and operating Certificate Holders.
This AC has been revised following evaluation of special cargo operations, load planning, restraint calculations, restraint methods, freight staging, freight forwarding, and interlining of cargo operations. It enhances the safety of flight operations by clearly identifying responsibilities of parties and provides guidance concerning an operator’s W&B control program and procedures for cargo restraint and aircraft loading, unit load devices (ULD) and restraint devices, and the transport of special cargo. It also provides clarity regarding cargo handling training requirements.
Adhering to the recommendations in this AC is one means, but not the only means, for operators to manage their cargo operations.
R obert C. Carty Acting Executive Director, Flight Standards Service
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CONTENTS Paragraph Page
Chapter 1. General Information1-1
1.1 Purpose of This Advisory Circular (AC)1-1
1.2 Audience ....................................................................................................................
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1.3 Where You Can Find This AC1-1
1.4 What This AC Cancels1-1
1.5 Background1-1
1.6 Document Organization1-2
Chapter 2. Operational Processes and Procedures2-1
2.1 General2-1
2.2 W&B Control Program2-3
2.3 Classifying Cargo Compartment for Fire Suppression, CLS Components,
Installed Nets, and Smoke Barriers2-6
2.4 ULDs and Cargo Restraint Devices2-11
2.5 Cargo Weigh Scales2-20
2.6 Operations for Cargo Handling and Aircraft Loading and Unloading2-22
2.7 Load Supervision, Load Verification, and Operator Audits2-30
2.8 Transport of Special Cargo2-32
2.9 Use of Multiple Entities2-35
2.10 Freight Staging2-38
2.11 Checklists and Job Aids2-38
2.12 Operator’s Evaluation System for W&B Control2-39
2.13 Training Programs2-40
Chapter 3. Administrative Information3-1
3.1 How to Obtain C opies of Publications3-1
3.2 AC Feedback F
orm3-1
Appendix A. Related RegulationsA-1
Appendix B. Guidance MaterialB-1
Appendix C. Definitions Related t o Air Cargo OperationsC-1
Appendix D. Acronyms and AbbreviationsD-1
Appendix E. Active Unit Load Device MarkingE-1
1-1 CHAPTER 1. GENERAL INFORMATION
1.1 Purpose of This Advisory Circular (AC). This AC provides operators with recommended procedures for managing cargo operations. Developing and using these comprehensive procedures is key to establishing a safe and efficient cargo operation. The AC provides guidance for aircraft bulk cargo loading, approved unit load device (ULD) cargo, and special cargo, including cargo loading systems (CLS). This AC is not mandatory and does not constitute a regulation.
1.1.1 The contents of this AC do not have the force and effect of law, and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.
1.1.2 The terms “must” and “will” in this AC indicate a mandatory requirement established by regulation that is to be followed when using the guidance in this AC. The term “should” is used in this AC to indicate a recommendation and not a requirement when using the guidance in this AC.
1.1.3 This AC describes an acceptable means, but not the only means, of complying with applicable regulations to manage cargo operations. However, if you use the means described in this AC, you should follow it in all important respects. While this is nonbinding guidance, you still must comply with the applicable regulations.
1.1.4 Since this AC represents an accepted means of compliance, an applicant seeking an alternative to any requirement or recommendation within this AC may need to discuss other means of compliance with the responsible Aircraft Certification Service office in order to achieve compliance with applicable regulations to manage cargo operations.
1.2 Audience. The audience for this AC includes air carriers and Operating Certificate holders conducting cargo operations.
1.3 Where You Can Find This AC. You can find this AC on the Federal Aviation Administration’s (FAA) website at http://www.faa.gov/regulations_policies/advisory_cir culars and the Dynamic Regulatory System (DRS) at https://drs.faa.gov.
1.4 What This AC Cancels. AC 120-85A, Air Cargo Operations, dated June 25, 2015, is canceled.
1.5 Background. This air cargo operations AC was originally developed in 2005, after a cargo-related accident involving a McDonnell Douglas DC-8 aircraft and in response to National Transportation Safety Board (NTSB) safety recommendations. Those recommendations included development of advisory material for Title 14 of the Code of Federal Regulations (14 CFR) part 121 operators and principal inspectors (PI).
Recommended changes also included detailed training curriculum content for cargo handling personnel which includes, but is not limited to, Weight and Balance (W&B), cargo handling, cargo restraint, and hazards of misloading. Refer to NTSB Safety Recommendations A-98-044, A-98-045, A-98-046, and A-98-047.
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1.5.1 Revision A. In April 2013, a Dubai-bound Boeing 747-400 crashed just after takeoff from Bagram Air Base, Afghanistan. It was transporting heavy military vehicles, known as “special cargo” loads. Following an NTSB recommendation, the FAA revised this AC after evaluating W&B personnel training, special cargo operations, load planning, restraint calculations, restraint methods, freight staging, freight forwarding, and interlining of cargo. Refer to NTSB Safety Recommendations A-15-015, A-15-016, A-15-017, and A-15-018.
1.5.2 Revision B. This revision includes new information as a result of reviews of operator cargo manuals and input from cargo operators. It also includes new definitions that align with those found in Operations Specification (OpSpec) A002, Definitions and Abbreviations.
1.5.3 Cargo Operations Program. Your cargo operations program is the foundation for safely transporting air cargo. This program includes such features as:
1. Acceptance of cargo by the operator;
2. Associated calculations and load analysis supporting carrying that cargo;
3. Maintenance and airworthiness of CLS components;
4. Processes by ground personnel for the buildup, handling, loading, and restraint of cargo;
5. Training of all personnel associated with your cargo program; and
6. Calculations and verification of an aircraft’s W&B by ground and flight personnel.
1.6 Document Organization. This AC has three chapters and several appendices:
1. Chapter 1 contains general information about the AC.
2. Chapter 2 addresses separate operational processes and procedures of cargo operations, with individual paragraphs addressing specific operational aspects.
3. Chapter 3 details administrative information about how to obtain copies of publications, and describes the Feedback Form for this AC.
4. The appendices contain information supporting the AC (and list related documents), including:
• Regulations (Appendix A),
• Guidance material (Appendix B),
• Definitions (Appendix C),
• Acronyms and abbreviations (Appendix D), and
• An example of active ULD marking information (Appendix E).
2-1 CHAPTER 2. OPERATIONAL PROCESSES AND PROCEDURES
2.1 General. This AC does not contain information pertaining to hazardous materials (HAZMAT).
2.1.1 Purpose. This chapter informs operators of the importance of providing necessary guidance to loading personnel for proper cargo buildup, weighing and restraint, and aircraft loading and unloading. These kinds of information may be included in your manual under 14 CFR part 91, § 91.1025(r); part 121, § 121.135(b)(26); part 125, § 125.73(r); and part 135, § 135.23(s).
2.1.2 Airplane Weight and Balance Manual (WBM). The WBM is part of the operating limitations section of the Airplane Flight Manual (AFM). Per 14 CFR part 21, § 21.41, operating limitations are part of the aircraft type certificate (TC) and are typically changed only by amending the TC or with a Supplemental Type Certificate (STC).
Revisions to the AFM are approved as AFM supplements, and approval is based on a finding that, with the AFM revisions, the airplane continues to meet airworthiness standards. You must comply with the operating limitations in the AFM, as required by § 91.9. The aircraft WBM (also referred to as a W&B Loading and Control Manual) is often a separate document, but remains part of the AFM. Title 14 CFR part 25, § 25.1583(c) authorizes the WBM as a separate document incorporated by reference in the AFM.
2.1.3 Company Operating Manuals. Certificate Holders must have operating manuals, as required by §§ 91.1023, 121.133, 125.71, and 135.21. You can find the content requirements for these manuals in §§ 91.1025, 121.135, 125.73, and 135.23. If your aircraft manufacturer’s procedures do not have sufficient detail and guidance, you may develop supplemental procedures and submit them to the FAA for acceptance. Any time you develop a procedure, it cannot contradict regulations. Only a responsible Aircraft Certification Service office approves changes to limitations that are referenced in paragraph 2.1.2 above. Supplemental procedures ensure cargo handling personnel have the guidance to maintain safety of flight operations. Certificate Holders should have a training program in place for cargo buildup, cargo loading system (CLS) configuration, aircraft loading/unloading, and special cargo (if applicable). Personnel performing these job functions and supervising cargo loading operations should be trained and qualified in these positions.
Note: Appendix B lists guidance materials that can be used as a resource to develop your supplemental procedures. However, we may still request additional data based on the submitter’s operation.
2.1.4 Process and Procedure Guidance. We recommend including the following in your manual, and consider these recommendations essential to air cargo operations. These recommendations are discussed in more detail throughout this chapter. This is not an all-inclusive list.
2.1.4.1 Procedures for control of W&B.
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2.1.4.2 Procedures to study and evaluate the capability of any aircraft the operator may use to transport any type of cargo, including special cargo. Operators may include a reference to the source document for this evaluation.
2.1.4.3 Procedures for special cargo recognition.
2.1.4.4 Procedures for loading and unloading all types of cargo.
2.1.4.5 Procedures to restrain cargo in aircraft compartments, including main deck, lower deck, fore and aft compartments, or pods, per the requirements of the design approval holder’s (DAH) WBM supplement for authorized unit load devices (ULD), certified ULDs, noncertified ULDs, bulk-loaded cargo, and special cargo.
2.1.4.6 Procedures for the use, storage, and evaluation of condition serviceability of cargo restraints—such as straps, netting, and ropes—which restrain bulk, ULD, or special cargo. Procedures should confirm routine serviceability checks and identification and removal of any unserviceable or expired restraint devices. Newer straps may indicate expiration dates. Procedures should also provide a process to follow if failed restraints are identified while in use.
2.1.4.7 Procedures to control the use, calibration, or verification of weigh scales for operators and vendors.
2.1.4.8 Repair procedures for ULDs, aircraft CLSs, cargo restraint devices, and other miscellaneous aircraft cargo handling equipment required for loading or unloading aircraft. These procedures should also include installed nets and installed smoke barriers.
2.1.4.9 Pr ocedures in your manual system for the control of all manuals and manual revisions applicable to air cargo operations. These procedures should ensure you:
1. Have current versions of the manuals, and
2. Provide authorized maintenance personnel and vendors with current manuals and manual revisions.
2.1.4.10 Procedures to ensure that all personnel are properly trained, qualified, and authorized to perform their job function(s).
2.1.4.11 Procedures for reconfiguring the CLS and documenting that the appropriate personnel have been notified. This ensures maintenance personnel, flightcrews, and loading crews are aware that center of gravity (CG) limits may have changed for current and future flights.
2.1.4.12 Procedures and processes for handling the carriage of special cargo.
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2.1.4.13 Procedures for freight forwarding, interlining, and freight staging.
2.1.4.14 Procedures for the carriage of HAZMAT, per §§ 121.135(b)(25)(ii),
125.73(o), and 135.23(p)(2).
2.1.4.15 Procedures for incorporating a Continuing Analysis and Surveillance System (CASS) to verify the performance and effectiveness of your CLS maintenance program, and provide corrections to deficiencies discovered in the program (per §§ 121.373 and 135.431).
2.1.4.16 Procedures for incorporating a closed-loop system that monitors the elements of surveillance, analysis, corrective action, and followup to verify the performance and effectiveness of your W&B control program—including cargo operations—and provide corrections to deficiencies discovered in the program. Note that this should be a part of your Safety Management System (SMS) per 14 CFR part 5, § 5.53.
2.2 W&B Control Program.
2.2.1 Develop a W&B Control Program. Type-certificated (TC) aircraft have an FAA-approved AFM/WBM provided by the DAH. Aircraft modified by an STC affecting W&B will have a manual supplement to the WBM approved by a responsible Aircraft Certification Service office. The DAH WBM for an aircraft is the basis for an operator’s W&B control program. Including appropriate operating instructions may help ensure compliance with the operating limitations in the WBMs.
2.2.1.1 Modified Aircraft. For aircraft with passenger-to-cargo conversions or other modifications, such as an aircraft CLS, a WBM supplement describing the modification’s effect on the aircraft is FAA-approved and is issued as part of an STC or amended TC.
2.2.1.2 Program Contents. The Certificate Holder’s W&B control program should include the following applicable items:
1. Loading limitations, including limitations on empty or unoccupied positions with missing or damaged restraints;
2. Information on aircraft cargo restraint systems, such as aircraft CLSs, installed nets, ULDs, and other restraint devices;
3. Requirements for special cargo loads;
4. A list of ULDs authorized for use with the CLS;
5. Aircraft operating weights;
6. Information for the determination of an aircraft’s CG;
7. Weight limitations for each compartment and zone, when applicable;
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8. Procedures for incorporating fuel loading and usage into the aircraft’s W&B calculations;
9. Instructions for, and samples of, load documents and manifests;
10. Aircraft loading schedules; and
11. Processes and procedures to monitor the W&B control program.
2.2.2 Contents of an Operator’s WBM. Sections 121.135, 121.141(b), and 135.23 allow operators to develop internal WBMs. As part of the AFM, the operating limitations contained in the WBM must be complied with in accordance with § 91.9(a). Operator WBMs must be accepted by the Administrator and must be based on an aircraft’s WBM data, amended TCs, and applicable STCs. Further, the operator’s WBMs should not exceed limitations in the aircraft’s DAH W&B data. Section 121.141(b) allows the operator to develop airline-specific operating procedures.
2.2.2.1 Aircraft Basic Operating Weight Control. An aircraft must conform to its basic operating weight as determined by the operator and specified as an operating limitation in its AFM (per § 91.9(a)). Operators should also consider other limiting weights in the WBM, such as zero fuel weight and minimum flight weight.
2.2.2.2 Zone and Compartment Weight Limitations. An operator’s aircraft must conform to all operating limitations in its AFM, including zone weight limitations and compartment weight limitations provided in the DAH specifications (per § 91.9(a)).
2.2.2.3 CG Range Limitations. The operator should include reference charts and/or tables in its WBM or other manual that provides the FAA-approved weight and CG range limitations. An operator should ensure CG range limitations in preprogrammed electronic W&B/CG calculators meet the operating limitations.
2.2.2.4 Aircraft Weight. An operator’s aircraft must conform to the DAH’s WBM requirements as an operating limitation contained in the AFM (see § 91.9(a)).
The operator should establish procedures for weighing the aircraft using the manufacturer’s WBM requirements or other FAA-approved or accepted methods. One accepted method is contained in AC 120-27, Aircraft Weight and Balance Control.
2.2.2.5 Aircraft Major Alteration Requirements.
2.2.2.5.1 The operator should have a procedure in place to ensure all relevant supplemental information developed, issued, and approved for that aircraft is incorporated into the operator’s W&B control program.
2.2.2.5.2 All major alterations or major repairs to an aircraft (§§ 121.379 and 135.437) must use FAA-approved aircraft data, including data that change the W&B
2-5 requirements and/or limitations (per 14 CFR part 43, § 43.5(c), § 121.135, and § 135.413).
2.2.2.5.3 In cases of multiple STCs applied to a single aircraft, the STCs should be evaluated for effect on each other and on the appropriate limitations applied.
At a minimum, an operator should include the supplemental information described above and cross-reference the supplemental information in the operator’s WBM. In addition, the operator should organize the supplemental information in a way that facilitates use by trained and qualified personnel.
2.2.2.6 Aircraft CLS Limitations. The operator must act in accordance with and apply the W&B and CG limitations of the aircraft CLSs, as established by the DAH WBM as operating limitations (per § 91.9). The operator should consider all limitations established by the DAH. The operating limitations are defined within the WBM. The WBM may allow for the reconfiguration of the CLS. The operator should have a method to determine W&B calculations for any reconfiguration of a CLS. When the operator modifies the aircraft, such as adopting a CLS STC, the associated instructions for continued airworthiness (ICA) are also incorporated into its maintenance and/or inspection program.
The operator should include the supplemental information provided by the ICAs in the operator’s WBM, and any charts or tables that indicate proper weight and CG range limitations.
2.2.2.7 Carriage of Other Persons (Other than Flightcrew). Sections 121.583,
125.331, and 135.85 permit, under certain circumstances, the carriage of persons aboard an airplane without compliance with certain passenger-carrying requirements of parts 121, 125, and 135, respectively.
They may be carried aboard an airplane because of their necessity for the safety of the flight, their relationship with the air carrier, or by virtue of certain knowledge and abilities attributed to them through selection and training. An operator must establish procedures for the carriage of other authorized persons. At a minimum, the procedures should address:
1. A method for calculating the weight of other authorized persons and their carry-on and checked baggage, such as actual weight or standard average weight (refer to AC 120-27 for guidance on calculating weights);
2. Any special procedures or limitations when carrying other authorized persons aboard an aircraft. These limitations are specified by the exemption, if required, for the carriage of other authorized persons; and
3. Instructions for documenting the weight of other authorized persons, and for communicating the information to the pilot in command (PIC) or other authorized, trained, and qualified personnel for determining W&B.
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2.3 Classifying Cargo Compartment for Fire Suppression, CLS Components, Installed Nets, and Smoke Barriers.
2.3.1 Classification of Cargo Compartments for Fire Suppression. Aircraft cargo compartments are designed to accept and restrain cargo in various ways. Cargo compartments are classified as Class A, B, C, E, or F, depending on accessibility and fire protection requirements. Under § 25.857, cargo compartments are classified as follows:
1. A Class A compartment is one in which:
• The presence of a fire would be easily discovered by a crewmember while at their stations, and
• Each part of the compartment is easily accessible in flight.
2. A Class B compartment is one in which:
• There is sufficient access in flight to enable a crewmember, standing at any one access point and without stepping into the compartment, to extinguish a fire occurring in any part of the compartment using a hand fire extinguisher;
• When the access provisions are being used, no hazardous quantity of smoke, flames, or extinguishing agent will enter any compartment occupied by the crew or passengers; and
• There is a separate approved smoke detector or fire detection system to give warning at the pilot or Flight Engineer (FE) station.
3. A Class C compartment is one not meeting the requirements for either a Class A or B, but in which:
• There is a separate approved smoke detector or fire detection system to give warning at the pilot or FE station;
• There is an approved built-in fire extinguishing or suppression system controllable from the cockpit;
• T here are means to exclude hazardous quantities of smoke, flames, or extinguishing agent from any compartment occupied by the crew or passengers;
and
• There are means to control ventilation and drafts within the compartment so that the extinguishing agent used can control any fire that may start within the compartment.
4. A Class E compartment is one on airplanes used only for the carriage of cargo, and in which:
• There is a separate approved smoke or fire detection system to give warning at the pilot or FE station;
• There are means to shut off the ventilating airflow to or within the compartment, and the controls for these means are accessible to the flightcrew in the crew compartment;
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• There are means to exclude hazardous quantities of smoke, flames, or noxious gases from the flightcrew compartment; and
• The required crew emergency exits are accessible under any cargo loading condition.
5. A Class F compartment must be located on the main deck and is one in which:
• There is a separate approved smoke detector or fire detection system to give warning at the pilot or FE station;
• There are means to extinguish or control a fire without requiring a crewmember to enter the compartment; and
• There are means to exclude hazardous quantities of smoke, flames, or extinguishing agent from any compartment occupied by the crew or passengers.
2.3.2 Cargo Compartments Designed to Accept ULDs. These compartments are equipped with an aircraft CLS designed to restrain ULDs in the aircraft. The CLS comprises various assemblies, such as restraint locks, side rails, and ball and roller conveyors. Some CLSs are powered, and some may be installed in main deck and/or lower deck compartments.
When the flightcrew and/or other persons are seated forward of the CLS, a smoke barrier should be installed (as applicable) between the CLS and those persons. In addition to a smoke barrier, protection of the occupants in an emergency landing is also required per §§ 25.561(a) and 25.853(e).
2.3.3 Cargo Compartments Not Designed to Accept ULDs.
2.3.3.1 These cargo compartments are called bulk compartments, and may have vertical or horizontal nets. Depending on its design and purpose, the net may restrain cargo from shifting vertically, longitudinally, and laterally within the compartment or from shifting onto the cargo door or cargo door area within the compartment. Bulk compartments protect aircraft systems and structures against damage from shifting cargo for all flight and landing conditions.
2.3.3.2 Some aircraft cargo compartments are versatile in that they may accept both authorized ULDs and bulk cargo. These compartments may also have a CLS to help in the movement of ULDs. The certification documents, either TC or STC, are the approval basis for these combined compartments. The combination bulk/ULD compartments can be found in the lower lobe and upper decks of appropriately certificated aircraft.
Note: Care should be taken when loading bulk cargo in these compartments to ensure that it does not block fire detection sensors or fire suppression agent nozzles, if installed.
2.3.4 Reconfiguring the CLS. The CLS contain components such as rails and locks that move and/or interchange in order to change the configuration of the CLS. An operator may
2-8 move/interchange these components using the DAH instructions that are typically found in one of the following source documents:
• TC, STC, and Type Certificate Data Sheets (TCDS);
• Service Bulletins (SB) or Service Letters (SL), if incorporated by reference into a mandatory advisory directive (AD); and
• Manufacturers’ ICAs.
2.3.5 Owner-Produced Parts. Section 21.9 provides that an owner or operator may manufacture replacement and modification parts for use on its own aircraft. As it pertains to this AC, an operator or owner should have processes to:
1. Identify components manufactured for the aircraft CLS in its maintenance program;
2. Ensure another operator or vendor does not sell or distribute the parts it manufactures;
3. Show its owner-produced parts meet the equipment manufacturer CLS type design; and
4. Maintain the continued airworthiness of the owner-produced part.
2.3.6 Addressing CLS Component Discrepancies. An operator may address aircraft CLS component discrepancies by replacing or repairing the applicable component. If the operator discovers systemic problems with the reliability of its components, the operator should report such problems to the component manufacturer. An operator’s CASS should track all cargo loading component discrepancies to measure the performance and effectiveness of the operator’s maintenance and inspection program.
2.3.7 Replacing a CLS Component. An operator may replace a CLS component with a new, rebuilt, overhauled, or repaired serviceable component, in accordance with any applicable regulations.
2.3.8 Repairing a CLS Component.
2.3.8.1 Operator Responsibility. An operator may repair a component on the aircraft, or may have a vendor repair a component, in accordance with applicable regulations. Under certain circumstances, an accepted manual may allow minor repairs. The repair vendor may be under the direct control of an operator, or may be a vendor the operator designates. The operator has primary responsibility for determining that the component meets applicable regulatory requirements.
2.3.8.2 Vendor Repair. CLS components repaired by a vendor should undergo a receiving inspection using operator procedures. The component should also have documentation to (1) confirm each component is certified as serviceable,