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 12–23

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.

2-29 Note: The FAA does not recommend that an operator tie multiple pieces on a pallet with straps or other restraint devices without an approved TSO net encompassing the load. Cargo, because of its size, condition, or shape that cannot be netted, should be classified and transported as special cargo.

2.6.6 Operator Procedures for Supplemental Cargo Restraint Devices. If the operator uses other restraint devices as supplemental cargo restraints, it should have procedures for their use.

These procedures should be based on the information provided by (1) the aircraft manufacturer, (2) the DAH, or (3) other sources acceptable to the FAA. These procedures should address:

1. Using and attaching other restraint devices to the aircraft’s installed seat track, tiedown track, and/or tiedown rings (see paragraph 2.8);

2. Using and attaching other restraint devices to commercial pallet cargo restraint tiedown tracks or to military pallets (436L) cargo restraint tiedown rings in accordance with the pallet manufacturer requirements; and

3. Properly arranging other restraint devices around the cargo or attached to the cargo.

Note: The operator should use care when positioning straps on cargo to prevent contact with sharp edges or irregular surfaces. The strap should not be prone to slippage from its intended position on cargo, and the operator should engage the lock mechanism so the strap is taut.

2.6.7 Procedures for Cargo Shoring. Aircraft floors and some pallet bases have a load-bearing weight limit, also called a floor load limit. Shoring is a technique to distribute the weight of a cargo piece over a larger area greater than its original load-bearing area, which is also called a footprint or contact area. Cargo pieces heavier than a load-bearing weight limit require shoring. The operator should have procedures describing:

1. Materials acceptable for use in shoring, such as wood planks or plywood;

2. Shoring weight (which must be included in the gross weight);

3. Calculations or methods for determining the amount and thickness of shoring materials; and

4. Methods for applying shoring material to the cargo piece.

2.6.8 Blocking and Bracing Techniques. An operator may need to stabilize cargo pieces such as large cable reels, motor vehicles, wheeled cargo, or odd-shaped cargo to prevent shifting during loading, unloading, and flight conditions. The operator should use blocking and bracing techniques to stabilize such cargo. The operator’s procedures should describe:

1. Acceptable materials for blocking and bracing;

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2. Calculations or methods for determining the amount and thickness of blocking and bracing materials;

3. Methods to account for the weight of the blocking and bracing materials, as part of the total weight; and

4. Methods for applying blocking and bracing materials to the cargo piece.

2.6.9 Frangible or Compressible Cargo. Frangible or compressible cargo may be required in certain positions for protection of the aircraft and its occupants, and its ability to withstand emergency landing conditions, as required by the aircraft WBM. Aircraft manufacturers’ W&B documents vary on the definitions of these terms; therefore, those documents should be referenced prior to developing procedures.

2.6.10 Cargo Loading Procedures for Combi-Configured Aircraft. Aircraft configured for carrying passengers and cargo on any deck, such as combi-configured aircraft, may require special cargo loading procedures. The operator should have special procedures to load such aircraft, and these special procedures should be based on requirements established by the aircraft manufacturer or DAH.

2.7 Load Supervision, Load Verification, and Operator Audits.

2.7.1 Supervising Cargo Loading. An operator should designate a trained, qualified, and authorized person or persons with the duty of supervising the loading of the aircraft, such as a load supervisor, to ensure:

1. All cargo is properly built up and weighed;

2. Vendor’s cargo scales have current calibration certificates;

3. Planning and calculation of cargo and passenger placement maintains the aircraft within permissible CG and structural load limits;

4. Cargo is properly secured with the appropriate type(s), quantity, and placement of cargo restraints, and all pallet locks are engaged when used;

5. The aircraft is correctly loaded and unloaded using the operator’s procedures;

6. Cargo is placed on the aircraft in such a way to prevent overloading sensitive sections of the airframe and cargo floor;

7. CLSs, ULDs, and other restraint devices are in serviceable condition and properly used;

8. Flightcrew members or authorized maintenance personnel are notified of damaged or inoperative cargo compartments, CLSs, installed cargo nets, or smoke barrier components;

9. All cargo-related documents are accurate and properly completed before submission to flightcrew members; and

10. The person supervising the loading and/or signing the load manifest is a trained, qualified, and authorized person, as outlined in § 121.665.

2-31 Note 1: Operators may use different terminology to identify the person who has the duty of supervising the loading of the aircraft. The load supervisor may physically load the aircraft, but primarily supervises loading crews and procedures.

Note 2: The signature of the person supervising the load, on the load manifest, attests that the aircraft is loaded correctly.

2.7.2 How to Verify Cargo was Loaded Properly. Operators should designate personnel to provide information to the PIC or the operator’s authorized, trained, and qualified loading personnel about how the aircraft was loaded. The designated loading personnel may provide loading information on one or more forms or documents, and may present it in hardcopy or electronic form. They may include additional information and certifications based on operator-specific requirements for cargo, such as HAZMAT, live animals, or special cargo.

2.7.3 Information Needed to Verify Cargo is Loaded Properly. The information indicating that cargo is properly loaded should include:

1. The flight date.

2. The flight number.

3. The aircraft registration number.

4. The origin of the flight leg.

5. The destination of the flight leg.

6. The ULD numbers (for cargo carried in ULDs).

7. The weight of each ULD loaded aboard the aircraft.

8. The weight of the bulk cargo, by compartment or position, as applicable.

9. The special cargo analysis function (SCAF) restraint plan (see paragraph 2.8.2).

10. A statement verifying that:

• All ULD locks are up;

• All installed nets or smoke barriers are properly attached;

• All ULDs loaded are in an operational condition;

• All cargo was loaded using operator cargo loading procedures; and

• All cargo was loaded aboard the aircraft as depicted on the load plan form, verification form, or other similar documents.

11. The signature (or electronic equivalent) of the load supervisor or other authorized, trained, and qualified loading personnel.

12. Location and quantity of any HAZMAT carried, and the HAZMAT notification to crewmembers, if applicable (per 49 CFR part 175, § 175.33).