AC 120-85B

Advisory circular · Carriage of Cargo

Approved
January 25, 2022
Last reviewed
August 22, 2024
Cancels
AC120-85A
Family
AC 120-85 · 3 versions
Revision
B
14 CFR parts
21, 25, 43, 45, 119, 121, 145, 234, 382

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 21, 2025.

Show pages 9–20

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5. The new tare weight is marked on each ULD using the operator’s or owner’s procedures; and

6. ULD repair is per the operator’s, owner’s, or standard practices procedures, whether the operator or a repair vendor performs the repairs.

2.4.7.5 Use of a Repair Station/Vendor to Repair ULDs.

1. An operator or owner should ensure the availability of all necessary data and manuals for repairing its ULDs.

2. An operator or owner should conduct audits of contracted repair stations:

• For the vendor’s training program; and

• To ensure repair stations meet the operator’s or owner’s maintenance program requirements.

2.4.7.6 Returning a ULD to Service. An operator that owns ULDs should have procedures for repairing unserviceable ULDs and returning them to service.

As provided in §§ 121.363(b) and 135.413(b)(2), an operator remains responsible for the airworthiness of its aircraft, which may be impacted by the use of owned or leased ULDs, whether they are maintained in-house or by contract. Maintenance personnel should be appropriately trained and should return ULD equipment to service consistent with the applicable CMM or operator instructions. FAA-certificated repair stations operating under 14 CFR part 145 should return ULDs to service using the operator’s procedures.

2.4.7.6.1 Owners of certified and noncertified ULDs should have procedures established with repair entities that ensure repairs are conducted using the CMM or manufacturer’s procedures that ensure the ULD is returned to a serviceable condition.

2.4.7.6.2 An operator should use FAA-acceptable data if it decides not to follow the requirements of the manufacturer’s CMM. An operator may also choose to strictly follow the manufacturer’s maintenance procedures.

2.4.7.6.3 An operator should use its SMS to verify the performance and effectiveness of its ULD maintenance program, if applicable, and provide corrections to any deficiencies discovered in the program.

2.4.8 ULD and Restraint Damage Limits.

2.4.8.1 Identifying or Revising Damage Limits. It is important that the operator specify damage limits for ULDs and related restraint equipment.

2.4.8.2 Standardization of Damage Limits for ULDs. An operator may standardize damage limits for ULDs transported upon its aircraft. The operator should

2-18 apply the most restrictive damage limits categorized by the type of ULD, unless it has engineering data to support less restrictive damage limits.

2.4.8.3 Exceeding Allowable Damage Limits of a ULD. A ULD that exceeds allowable damage limits to the ULD base needs careful evaluation to determine if it is usable. A ULD with damage to its shell may be accepted for use by installing an authorized net over the shell, provided a pallet/net combination is authorized. A reduced-weight requirement may be necessary when an operator uses this procedure. The operator should develop procedures for using the damaged ULD with a net.

2.4.9 Establishing Usage Limits for Cargo Straps. Operators should ensure cargo strap assemblies are serviceable prior to use. If a cargo strap manufacturer does not provide damage limitations for its cargo straps, an operator should develop guidance to include, at a minimum, not using the strap if:

2.4.9.1 Buckle Latch Mechanism. A buckle latch mechanism will not lock or stay engaged. This allows the web to slip while under tension, or may result in the web binding or being out of alignment.

2.4.9.2 Mechanism Integrity. Attached mechanisms, fittings, hooks, or rings are bent, deformed, cracked, broken, or missing.

2.4.9.3 Webbing Integrity. Webbing is partially cut or torn, knotted, unraveling, or has loose or missing sewn stitches.

2.4.9.4 Environmental Conditions. The strap is deteriorated due to environmental conditions.

Note: TSO-C172 is available and provides a set of approved performance standards for manufacturing new cargo restraint straps.

Cargo restraint strap assemblies authorized under previous Technical Standard Order Authorization (TSOA) may still be manufactured under the provisions of its original approval.

2.4.10 Additional Procedures for Cargo Nets. If the operator owns or leases cargo nets, it should consider using additional procedures for cargo nets, such as:

1. Assigning a unique marking or serial number to nets and placarding that marking or number on the nets;

2. Placarding nets with their damage limits;

3. Attaching an identification tag to the operator’s nets; or

4. Ensuring proper storage when not in use to prevent damage.

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2.4.11 Temporary Repair on a Cargo Net.

2.4.11.1 Using Temporary Restraints. An operator must repair a cargo using temporary restraints in accordance with the AFM/WBM, and should have provisions for:

1. The net CMM authoring use;

2. A process in its manual system addressing the use and limits of temporary restraints; and

3. Personnel who install the temporary restraints are trained, qualified, and authorized.

2.4.11.2 Purpose. Temporary restraints are typically installed for the purpose of addressing items such as:

1. Using a bridge strap to bridge cut (or otherwise damaged) ropes, or missing or damaged fittings;

2. Installing temporary fittings and hooks to compensate for damaged or missing fittings, using equipment manufacturer or operator procedures; or

3. Installing net corner and supplemental lashing lines.

2.4.12 Performing Serviceability Checks on ULDs or Other Cargo Restraint Devices. An operator should perform a serviceability check for damage before using ULDs and other restraint devices (e.g., single and double stud rings, straps, and pallet couplers) for movement or buildup, and should conduct a final serviceability check before loading cargo aboard the aircraft.

2.4.12.1 Purpose. Serviceability checks are not intended to determine a ULD’s airworthiness. Instead, they ensure the ULD or other restraint devices do not have obvious damage greater than their damage limits. An operator should not use ULDs or other restraint devices with damage greater than damage limits specified.

2.4.12.2 Individuals Who May Perform Serviceability Checks. Personnel who perform serviceability checks do not have to be FAA-certificated mechanics or repairmen. Operators should train, qualify, and authorize personnel to perform serviceability checks. Operator procedures should identify who performs these checks and when the checks are performed.

2.4.12.3 ULDs That Fail a Serviceability Check. An operator should have a procedure for clearly marking or identifying ULDs and other restraint devices that fail serviceability checks. The method for identifying failed equipment should clearly distinguish these items from serviceable equipment so the operator or cargo loading vendor does not inadvertently place failed equipment into service. A procedure should be in place for individuals to

2-20 report damage to persons responsible for maintaining the ULD. If transporting unserviceable ULDs to a place where repairs are available, the operator should determine the method of transportation in accordance with the AFM/WBM.

Note: The operator may correct clerical, data entry, or other error of omission resulting in misidentifying or removing a ULD from service, and have the ULD returned to service. The operator should have a procedure in its manual system for identifying and correcting such errors.

2.5 Cargo Weigh Scales.

2.5.1 Ensuring the Weight of Loaded Cargo is Accurate. An operator must ensure the weight of cargo loaded aboard its aircraft is accurately described in the load manifest (per §§ 121.693 and 135.443). The operator’s W&B program should account for allowed tolerances to maintain approved W&B limitations.

2.5.2 Ensuring Weigh Scales Are Accurate. An operator should have a program to periodically check the accuracy of scales used for weighing cargo. The operator should conduct a periodic functional check using the weight recommended by the scale manufacturer for a periodic functional check. As an alternative, use weights simulating a typical load placed on the operator’s aircraft. Periodic function and calibration checks should be performed in accordance with the operator’s procedures and timeframes. Frequent checks and periodic calibrations ensure an operator accurately weighs the cargo loaded on its aircraft.

2.5.3 Ensuring Weigh Scales Are Calibrated. An operator should conduct periodic calibration of scales to ensure they are appropriately serviced and accurate to a known standard using an interval recommended by the scale manufacturer. Calibration records should show that scales are calibrated using a standard established by appropriate country, state, or local government regulations. Such standards could include the National Institute of Standards and Technology (NIST), an equivalent standard acceptable to the FAA, or standards recommended by the scale manufacturer.

Note: For more information on the standards provided by NIST, visit NIST’s website at https://www.nist.gov/.

2.5.4 Maintaining Records of Calibration Checks. An operator should keep a record of its scale calibrations, with the following criteria:

1. The records should be in the English language. If the records are not in the English language, operators should have the records translated, when necessary. If the operator cannot provide an English language interpretation of operator records, that operator should allow those individuals using the scales to inspect the scales and perform a functional check onsite to ensure scale accuracy.

2. The operator should establish procedures to maintain the records.

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2.5.5 Performing Functional Checks on Scales Used for Weighing Cargo.

2.5.5.1 Procedures. An operator should have procedures to functionally check scales used for weighing cargo between scale calibrations. A functional check should consist of field-testing the scale’s accuracy within the tolerance of the scale manufacturer, or within a tolerance of ±1 percent, whichever is more restrictive, using an item of known weight.

2.5.5.2 Frequency. At a minimum, the operator should ensure that functional checks are performed at intervals specified in (1) the operator’s procedures, or (2) the scale manufacturer’s recommendations. The operator also should conduct the functional checks at intervals commensurate with the frequency of scale use, and conduct functional checks more often for scales used more frequently.

2.5.5.3 Recordkeeping. An operator should record completion of functional checks.

The operator should maintain functional check records using accepted procedures. These records should include:

1. The identification number of the scale;

2. The date and time of the functional check;

3. The name or the initials of the person who performed the functional check;

4. The applied known weight of the item used for the functional check;

5. Instructions to ensure that the test load is completely free from all contaminants or any damage;

6. The scale’s indication of the applied known weight; and

7. The difference between the applied known weight and the registered weight.

Note: If the registered weight recorded for the item of an applied known weight is outside the tolerances specified for the scale in the operator’s procedures, the operator should not use the scale until the scale is inspected and calibrated. The operator should apply the scale variance to the total weight of the cargo being weighed.

2.5.6 Items for Which an Operator Should Know the Tare Weight. Personnel weighing cargo should know the weight of equipment such as dollies, slave frames, containers, and carts that are not being shipped on the aircraft but are only being used to facilitate loading of the aircraft. An operator should determine the tare weight of this equipment by weighing it on a calibrated scale.

2.5.7 Reweighing Loading Equipment for Tare Weight After Maintenance, Repair, or Modification. Immediately after any repair, maintenance, or modification of equipment such as dollies, slave frames, containers, and carts, the operator should provide a new tare

2-22 weight by reweighing the equipment. Operators should establish a method to communicate new tare weights to loading personnel before using the equipment to weigh cargo on a scale. This method may be in the form of the operator communicating the tare weight by stenciling it on the equipment or by providing notices to operator loading personnel.

2.6 Operations for Cargo Handling and Aircraft Loading and Unloading.

2.6.1 Overview. This section explains how to apply the content in paragraph 2.4 to an air carrier’s cargo operations.

2.6.1.1 Procedures. An operator should have procedures in its manual system for ULDs, cargo requiring unique or special handling, special cargo, cargo buildup, loading and unloading, and restraining cargo. The procedures should include bulk loading and unloading of cargo, whether the cargo is compartment-restrained or restrained by other devices, if the operator permits.

The procedures should use the operator’s WBM and DAH/STC WBM.

2.6.2 Operator Procedures on ULD Buildup and Cargo Restraint. An operator’s procedures covering ULD buildup and cargo restraint should address:

2.6.2.1 ULD CG Limits. Procedures should address maintaining the longitudinal, lateral, and vertical CG limits of a built-up ULD. The operator should consider the following guidelines when developing the procedures:

1. Place sturdier, heavier, and larger cargo pieces on the bottom of the load and evenly distribute them over the length and width of the pallet base.

2. Place smaller, lighter, and fragile cargo pieces on top and evenly distribute them from the center over the length and width of the ULD.

3. Level off the cargo in the ULD when less than full.

4. Interlock or overlap small pieces when practical.

2.6.2.2 Voided Space in ULDs. To minimize voided space within a ULD and between cargo pieces, the operator should consider using the following:

1. Supplemental restraint devices to restrain cargo within a container when less than full.

2. Dunnage in voided spaces. See Appendix C, Definitions Related to Air Cargo Operations, paragraph C.12.

2.6.2.3 Cargo Contours. The operator should have procedures for contouring cargo loads for the aircraft’s interior dimensions when using a pallet/net combination, pallet/strap combination, or other restraint methods/devices.

The operator should consider using techniques such as contour templates or

2-23 charts. Also, the operator should consider procedures for operational conditions in which variance in contouring might occur. For example, variances in contouring might occur when forming an aisle to access HAZMAT or ensure the integrity of a particular load. The operator must also account for height restrictions if required by the DAH WBM (per § 91.9).

2.6.2.4 ULD Identification Tags. The procedures should include providing tags to identify ULDs loaded aboard operator aircraft. This is especially important when using pallet/net or pallet/strap combinations; their identification is not always visible.

Note: Electronic tagging may be used but may present a concern about interference with onboard avionics equipment. Refer to AC 91.21-1, Use of Portable Electronic Devices Aboard Aircraft, for additional information.

2.6.2.5 ULD Weight Limits. The operator should include procedures so that cargo does not exceed ULD gross weight or area load limits if stated by the ULD manufacturer.

2.6.2.6 Serviceability Checks. The procedures should include checking the condition of ULDs and other restraint devices for damage before using them, conducting serviceability checks to ensure noted damage does not exceed damage limits, and providing a process to follow if failed restraints are identified while in use. The operator should base serviceability checks on information from:

• The equipment manufacturer,

• The STC, or

• Other data acceptable to the FAA.

2.6.2.7 Fastening Container Components. The operator’s procedures should address the correct method of positive closure and locking of container nets, curtains, and rigid or flexible doors after buildup. The operator should base these procedures on information from:

• The container manufacturer,

• The DAH, or

• Another source with information acceptable to the FAA.

2.6.2.8 Fastening a Cargo Net to a Pallet. The operator’s procedures should address how to fasten a cargo net to a pallet properly after buildup. The operator should base these procedures on information supplied by the pallet/net manufacturer or the DAH.

Note: Personnel whose job functions include determining co mpatibility of pallet and net combinations (per operator’s

2-24 procedures), pallet and airframe compatibility, and cargo restraint devices (e.g., intermixing straps) should have training in these areas.

2.6.3 Operator Procedures on Cargo Loading and Unloading. An operator’s procedures for aircraft loading and unloading should address:

2.6.3.1 Sill Guards (if applicable). The operator’s procedures should detail using, attaching, and detaching these devices. If an operator stows sill guards in the aircraft when they are not in use, the procedures should include the proper stowage in the aircraft.

2.6.3.2 Tail Posts (if applicable). The operator’s procedures should address using a nonstructural device called a tail post if the operator needs it to measure the distance between the aircraft’s tail section and the ground during loading and unloading. Procedures should include instructions on attaching, detaching, and using it. If an operator stows the tail post in the aircraft when not in use, the procedures should include the proper stowage in the aircraft.

2.6.3.3 Tail Stands (if applicable). The operator’s procedures should address using a structural device called a tail stand if the operator needs it to prevent the aircraft from settling on its tail during loading and unloading. The procedures should include instructions on attaching, detaching, and using it.

2.6.3.4 Tail Tipping Avoidance. The operator’s procedures should address methods to prevent the aircraft from tipping on its tail during loading and unloading.

Examples of these methods include step loading and unloading of cargo, and nose gear tethering.

2.6.3.5 Ai rcraft Doors, Nets, and Smoke Barriers. The operator’s procedures should address the proper use of cargo compartment and bulkhead doors, installed nets, and smoke barriers.

2.6.3.6 Aircraft Floor and ULD Base Load Limits. The operator’s procedures should address the aircraft’s floor load limits if the operator loads cargo directly onto the aircraft’s floor. These limits can be expressed as area load or linear/running load limits. The procedures also should address floor load limits for a ULD base if the ULD manufacturer has a limit. Operators must base these procedures on information derived from FAA-approved data, the aircraft manufacturer, or an STC WBM or supplement, as the WBM is part of the AFM and must be complied with per § 91.9). The procedures should address how to distribute or shore cargo weight greater than a floor load limit.

For more information, see paragraph 2.6.7.

2.6.3.7 Aircraft Weight Limits. The operator’s procedures should address the weight limits for aircraft cargo positions, floors, zones, and compartments, and include measures to ensure the operator does not exceed them. The operator should base these limits on information derived from FAA-approved data, the aircraft manufacturer, or STC WBM or supplements.

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2.6.3.8 Aircraft CG Range Limits. The operator’s procedures should address the CG range limits for the aircraft and longitudinal, lateral, and vertical CG limits for cargo positions. The procedures also should prevent an operator from exceeding these limits. The operator should base these procedures on information derived from FAA-approved data, the aircraft manufacturer, or STC WBM or supplements.

2.6.3.9 Cargo Access Aisle. The operator’s procedures should address a method for creating a flightcrew access aisle to cargo requiring access during flight.

Examples of cargo requiring such access include certain HAZMAT or live animals.

2.6.3.10 Aircraft Damage Avoidance. The operator’s procedures should prevent damage during loading and unloading to the cargo handling system, cargo liners, smoke detectors, light fixtures, fire retardant flow nozzles, and similar devices.

2.6.3.11 Aircraft Damage Notification. The operator’s procedures should provide for notification of flightcrew members or authorized maintenance personnel of a damaged or inoperative cargo compartment, cargo handling system, installed net, or smoke barrier and related components. These procedures should include a general guideline or list of what specific items cargo loaders should report to flightcrew members or authorized maintenance personnel, such as holes in the cargo compartment liner, damaged or missing cargo handling system restraints and rollers, and installed nets and smoke barriers.

2.6.3.12 Car go Clearance. The operator’s procedures should detail the minimum clearance (or distance) requirements between cargo and airplane systems and structure (e.g., cargo compartment liners, light fixtures, fire suppression systems, and smoke detectors).

2.6.3.13 CLS. The operator’s procedures should describe how to use the aircraft’s CLS to restrain ULDs. The operator should engage all CLS restraints for loading ULDs, including voided positions, unless the compartment contains no ULDs.

Engaging cargo restraints in voided positions may help prevent a large cargo shift in the event that a ULD’s restraint located forward/aft fails.

Note: Only FAA-certificated personnel may adjust CLS components by physical removal and reinstallation where tools are required.

Trained, qualified, and authorized loading personnel may reconfigure the CLS based on the operator’s WBM.

2.6.3.14 Bulk-Loaded Cargo. The operator’s procedures should describe how to properly load bulk cargo in cargo compartments and pods approved for bulk cargo. The operator must not bulk-load cargo in a cargo compartment or pod contrary to the aircraft manufacturer’s WBM or STC, or to the operator’s manual system (per § 25.1583). If the aircraft manufacturer’s WBM or STC

2-26 does not contain enough detail for bulk-loading cargo, the operator should establish procedures to ensure the safety of flight that address:

2.6.3.14.1 Cargo Clearance. The minimum clearance (or distance) requirements between cargo and airplane systems and structure (e.g., light fixtures and smoke detectors).

2.6.3.14.2 Load Distribution. Evenly distributing or spreading the cargo within compartments and pods over their length, width, and height.

2.6.3.14.3 Aircraft Nets. Properly using installed nets.

2.6.3.14.4 Aircraft Smoke Barriers. Properly using installed smoke barriers between cargo and flightcrew members and passengers.

2.6.3.15 Cargo Requiring Special Handling Procedures. Some cargo may require additional or unique procedures to protect cargo or the aircraft during handling, acceptance or loading, or in flight. Examples of special handling procedures include ceremony or instructions for transporting human remains, feeding live animals in transit, signature service forms for tracking mail/cargo, compatibility with HAZMAT, and protective gear when handling cryogenics.

The operator’s procedures should address cargo loads requiring special handling, which may include the following:

Note: Do not confuse special handling with special cargo. Not all special handling requires special cargo procedures. Refer to the definition of special cargo in Appendix C and OpSpec A002, Definitions and Abbreviations.

1. Offset cargo;

2. Overweight cargo;

3. Overhanging cargo;

4. Outsized cargo;

5. Sharp or piercing cargo;

6. Crated heavy machinery;

7. Reels or spools;

8. Motor vehicles and other wheeled cargo;

9. Tall cargo;

10. Rigid cargo;

11. Tall rigid cargo (TRC);

12. Cargo not fully restrained by the CLS;

13. Human remains;

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14. Foodstuff, feed, and postal mail;

15. HAZMAT (in compliance with Title 49 of the Code of Federal Regulations (49 CFR) and part 121 subpart Z);

16. Active ULDs (FAA-approved);

17. Temperature-controlled ULD containers (FAA-approved);

18. Live animals;

19. Small animals, such as mice, rats, dogs, and cats, typically shipped in self-contained boxes or containers and typically loaded with other cargo in bulk compartments and ULDs. The procedures should address measures to:

• Reduce the risk of animals escaping from containers while in the aircraft.

• Identify animals that have escaped from their containers in the aircraft.

• Remove escaped animals from the aircraft.

20. Large animals, such as horses and cattle, typically shipped in special containers, stalls, or penning systems where primary restraint is by the aircraft CLS that is STC-approved or approved by other FAA means. The procedures should address measures to:

• Verify that special containers, stalls, or penning systems are approved by the WBM for the aircraft, where primary restraint is by the aircraft CLS.

• Verify that the special container, stalls, or penning systems restrain the large animal.

Note: Open-top stalls, where animals have no vertical restraint, are not acceptable.

• Ensure special containers, stalls, or penning systems are properly installed in the aircraft.

• Protect the aircraft from damage by animal waste, such as urine or solid waste.

• Manage out-of- control animals in the aircraft.

• Remove animal waste from the aircraft.

21. ULDs;

22. Radio frequency identification (RFID) cargo; and

23. Special cargo.

Note: Cargo requiring special handling procedures is a separate but related concept to special cargo. See paragraph 2.8 for more

2-28 information and to assist in identifying when one of the “cargo requiring special handling” examples listed above is classified as special cargo.

2.6.4 Use of Cargo Restraint Devices Other Than ULDs. An operator may use other restraint devices as the primary restraint of cargo unless prohibited by (1) the aircraft manufacturer AFM/WBM or (2) the STC supplementary WBM. The manufacturer’s AFM/WBM or supplementary WBM should include serviceability limits and operational and repair procedures, and meet the flammability requirements of part 25.

2.6.5 Procedures for Use of Primary Restraint Devices Other Than the CLS. If an operator uses straps and other restraint devices as primary cargo restraints, it should have procedures for their use. These procedures must be based on the information provided by (1) the aircraft manufacturer or (2) the DAH. These procedures should address:

2.6.5.1 Installing straps or other restraint devices to aircraft structure, to include the CLS (e.g., floor tracks, rings, and hardware). An operator must emphasize in its procedures that reduced load limits and minimum separation requirements may exist between tiedown points if using the same aircraft floor track, ring, or hardware for multiple tiedowns. Operators must address minimum tiedown separation requirements for pallets so they do not overstress the aircraft floor attachments. These limits are found in the aircraft WBM.

Note: Intermixing cargo restraint devices made of different materials is not recommended.

2.6.5.2 Calculating other restraint devices for a given cargo load based on the restraint criteria in the aircraft’s AFM/WBM.

2.6.5.3 Calculating the number of straps or restraint devices required based on the device’s rated strength and limiting factors specified in the aircraft’s AFM/WBM or its supplement. The manufacturer’s AFM/WBM or its supplement may require strength reductions of the strap or other restraint devices based on limiting factors, such as aircraft sidewall or floor angles and the strength of attachment hardware.

2.6.5.4 Cargo strap and angle and G-force loading to determine the minimum number of straps necessary to safely secure the cargo.

2.6.5.5 Properly arranging straps or other restraint devices around the cargo or attached to the cargo. Instructions should include correctly cinching adjacent net panels together with a net corner lashing rope and securing the end of the rope to the net panel to prevent disengagement.

2.6.5.6 Res training cargo using the aircraft’s ultimate load conditions described by the manufacturer’s AFM/WBM or its supplement. These devices must provide restraint in the forward, aft, vertical, and lateral directions.