2-33 data from the aircraft manufacturer/STC AFM/WBM (per §§ 23.2620 and 25.1583) and comply with all operating limitations.
2.8.3.1 SCAF Responsibilities. Based on the operator’s procedures, the SCAF should:
2.8.3.1.1 Evaluate Cargo Transport. Determine the aircraft’s ability to safely transport the cargo without causing structural damage. Evaluate the cargo and identify its tiedown capabilities. Take into account the special handling needs, placement of special cargo, weight limits, floor loads, and cargo clearance.
See paragraph 2.8.4, which provides characteristics associated with special cargo.
2.8.3.1.2 Determine Restraint. Provide a method to determine the appropriate quantity and types of restraint, shoring, and arrangement confirming the determination of the load’s restraint capability in each direction, whether restrained directly to the airplane or to a ULD restrained in the CLS. The operator should demonstrate that the orientation secures the load for all aircraft operations.
Restraint loads must not exceed the rating of cargo tiedown points, pallet tiedown fittings, or aircraft structure. The operator should also be able to determine how restraints are distributed in accordance with the aircraft TC/STC AFM/WBM.
2.8.3.1.3 Construct a Special Cargo Restraint Plan. Construct a diagram/pictorial schematic or textual description based on an FAA-approved AFM/WBM/supplement. The special cargo restraint plan should:
1. Calculate the restraint and develop a tiedown special cargo restraint plan for each special cargo item.
2. Include the number and angle of primary restraints and the attachment points from the special cargo to the aircraft structure confirming the determination of the load’s restraint capability in each direction. Some aircraft have approval to allow straps to pallets as the primary restraint.
3. Illustrate the position of all pieces of special cargo in relation or adjacent to the CLS and all other cargo having special requirements resulting from the carriage of the special cargo.
Note: The special cargo restraint plan must comply with the FAA-approved AFM/WBM/supplement and can be incorporated into the operator’s manuals (per §§ 23.2620 and 25.1583). A separate special cargo restraint plan is not necessary for the items incorporated in the operator’s manuals. However, when using this procedure, the operator should reference the manual name and diagram, illustration, or instruction number on a cargo loading document and retain it with the load manifest.
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2.8.3.2 Operator’s Responsibilities. The operator should:
2.8.3.2.1 Loading. Make the special cargo restraint plan and any necessary instructions available to the load supervisor, ground personnel, and flightcrew, as appropriate. Documents should be made available to those personnel involved with, or responsible for, the loading and securing of cargo.
Note: The operator should ensure that persons with the duty of supervising the cargo loading utilize the special cargo restraint plan and instructions during cargo loading.
2.8.3.2.2 Record Retention. File the special cargo restraint plan with the load manifest as outlined above in the note under paragraph 2.8.3.1.3.
2.8.4 Characteristics Associated with Special Cargo. Anytime a primary restraint—other than an authorized ULD restrained by a CLS—is used to restrain cargo, the cargo is classified as special cargo. The acceptance of special cargo requires a determination that the loading and restraint capabilities of the airframe and associated restraint devices provide compliance with all limitations contained in the FAA-approved TC/STC, AFM, and WBM. The operator should have procedures to determine if the cargo is indeed special cargo. The following list contains examples of characteristics to help make this determination:
2.8.4.1 Offset Cargo. Cargo positioned on the pallet in a manner that the cargo is shifted beyond the perimeter of the pallet resulting in either (1) the CG limits of the pallet being exceeded, or (2) the restraint by the net to the pallet becoming ineffective in protecting the aircraft and preventing cargo shift. A reason for offsetting the cargo could be to meet aircraft clearance requirements. Offset cargo is special cargo.
2.8.4.2 Overhanging Cargo. Cargo that extends beyond the perimeter of the pallet in at least one direction and prevents the net from performing its intended function.
2.8.4.3 Outsized Cargo. Cargo that exceeds the maximum allowable contour of an aircraft ULD such that the ULD must be loaded on board an aircraft as a non-CLS restrained ULD, as instructed by the AFM/WBM (per §§ 23.2620 and 25.1583).
2.8.4.4 Sharp or Piercing Cargo. Cargo of a piercing or penetrating nature, or cargo with sharp edges or corners, such as rods, pipes, extrusions, or beams, that could become a projectile hazard during flight operations.
2.8.4.5 Unusually Shaped Cargo. Cargo that is irregular in nature, such as crated heavy machinery, reels, spools, compressed springs, and actuators. Risks associated with these items include:
1. Can roll and shift during transportation due to their shape;
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2. Hard to lift and move without damaging the edges;
3. Can be bundled together and require blocking and bracing techniques to prevent cargo shift;
4. Can become projectiles if not handled and secured properly; and
5. The weight is concentrated in a very small area and often exceeds the floor-bearing weight capacity of the aircraft.
2.8.4.6 Motor Vehicles and Other Wheeled Cargo. Motor vehicles and other wheeled cargo with heavy weights represent a higher hazard and should be systematically handled with reinforced precautions, checks, and cross-checks, to include:
1. Fuel levels,
2. Load shoring and restraint,
3. Blocking and bracing (chocking) wheels to restrict movement, and
4. Tiedown attachment points.
2.8.4.7 Tall Cargo and TRC. Currently, TRC only applies to the Boeing 747. Tall cargo is cargo greater than 98 inches tall. Certain sections of tall cargo can be frangible and certain sections can be rigid. If any part of the rigid section of tall cargo is above 98 inches, the tall cargo is TRC. If the entire rigid section of tall cargo is at or below 98 inches, the tall cargo is not TRC. It is the responsibility of the operator to determine if cargo is tall cargo or TRC.
2.8.4.8 Car go Not Restrained by the Aircraft CLS. Cargo not fully engaged by the cargo loading restraint system but secured to the aircraft structure. Cargo not fully restrained by the aircraft CLS becomes special cargo.
2.8.4.9 Cargo Using a Sandwich Pallet. A sandwich pallet is when one or more pallets are placed on top of another. In some cases, wood (skid or plywood) is placed in between the pallets. In all cases, the upper pallet becomes cargo. A base pallet that is not secured by the CLS is special cargo.
Note: If a cargo net is placed over all the cargo and attached to the base pallet which is secured by the CLS, it is not considered special cargo.
2.8.4.10 Floating Pallet. ULD positioned over one or more pallet position and not fully restrained by the aircraft CLS, but restrained to the aircraft structure by means of strapping to tiedown fittings. Floating pallets are special cargo.
2.9 Use of Multiple Entities.
2.9.1 Interlining. Interlining is when cargo is transferred from one operator to another, whether using the same or different aircraft types. The receiving operator should ensure that all
2-36 cargo being transferred is acceptable and capable of transportation on the receiving operator’s aircraft.
2.9.1.1 Procedures an Operator Should Have for Interlining. The operator should develop standards for accepting cargo in accordance with its policies and procedures, or state that it does not interline. Policies and procedures should include, at a minimum:
1. Cargo check (visual examination), including serviceability of ULDs;
2. ULD compatibility with aircraft (see paragraph 2.4.5); and
3. Special cargo verification and validation, if applicable.
2.9.1.2 Using Vendors to Interline or Build Up Cargo. The use of third parties, foreign and/or domestic, reduces the need for the operator to employ personnel or to contract directly for interlining built-up cargo, aircraft loading, unloading, and cargo handling at a particular location. See Appendix C and paragraph 2.9.2 for additional information on vendors.
2.9.2 Vendors.
2.9.2.1 Vendors Performing ULD Handling or Buildup.
2.9.2.1.1 Under §§ 121.363 and 135.413, an operator is primarily responsible for the airworthiness of its aircraft. This includes work done both in-house and under contract with an outside source. This necessarily includes responsibility for the security of the cargo and safety of flight. There are multiple entities involved in the movement of cargo, which include shippers, vendors, freight forwarders, contractors, subcontractors, customs brokers, and service providers. All play a role in the air transportation of cargo and these roles may include cargo buildup, freight staging, cargo loading, and tiedown. Vendors performing ULD handling or buildup should ensure that:
1. Requirements are met in accordance with the instructions of the operator;
2. Sufficient and proper ULD storage capacity is available for all units handled;
3. All staff or supervising staff receive training appropriate to the tasks performed; and
4. Full access is guaranteed to enquiries or audits from the operator’s quality control (QC) departments.
2.9.2.1.2 An operator should have a system in place to perform audits of a vendor at regular time intervals in line with its SMS process.
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2.9.2.2 Operator Program for Vendors to Use in ULD Buildup or Loading. Given that it is common practice for an operator to carry cargo loads that vendors have built up or loaded, an operator should have a program that ensures vendors perform cargo buildup and loading using the operator’s procedures.
Under such a program, an operator should have procedures to:
1. Train a vendor employee to train other vendor employees (train-the-trainer method), or accept the vendor’s training program and procedures provided they meet or exceed the standards established in the operator’s training program and procedures.
2. Designate a trained, qualified, and authorized person to oversee the vendor services to ensure the vendor performs the services in accordance with the operator’s procedures.
3. Audit vendors for compliance with the operator’s procedures and training programs.
4. Have a recordkeeping system to track all trained individuals, including vendors, in cargo operations that are authorized, qualified, and trained by the operator.
Note: All cargo built up by authorized, trained, and qualified personnel should meet operator standards before being loaded. In some cases, some operators may have trained and qualified personnel inspect and accept the built-up freight prior to loading on the aircraft instead of having all of the vendor’s employees trained to the operator’s specific program.
2.9.3 Freight Forwarding. An operator may engage with other companies such as freight forwarders for organized shipment of cargo. An operator should have a system in place to perform audits of a freight forwarder at regular time intervals. An operator should have a system in place to perform audits of a vendor at regular time intervals in line with their SMS process.
2.9.4 Responsibility for Multiple Entities. The FAA recognizes it is common practice for multiple entities to perform different services associated with air cargo operations, but the operator is always ultimately responsible for cargo loading and securing and safety of flight. Therefore, the operator should ensure that those multiple entities are trained, qualified, and authorized to perform duties, audit third-party operations, and ensure adherence to the operator’s procedures, when applicable. Alternatively, the operator may use a trained and qualified person to inspect, accept, and supervise the loading of the freight on the aircraft.
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2.10 Freight Staging.
2.10.1 Staging Cargo at Different Operating Locations. An operator may engage in the process of staging cargo at different operating locations. When storing or staging cargo, the operator should consider the following, when applicable:
1. Proper security of all cargo is maintained;
2. Proper special handling of cargo is provided;
3. Proper storage of cargo that is also safe from natural elements is provided;
4. Appropriate climate control for cargo is provided, if applicable
(e.g., refrigeration); and
5. Proper documentation of all cargo is maintained.
2.11 Checklists and Job Aids.
2.11.1 Using Checklists and Job Aids. The operator should develop a system when performing tasks to incorporate controls as part of its processes and procedures. In other words, checks and balances are designed into a process to ensure a desired result. This could be a checklist or job aid. For example, a loading checklist or job aid and predeparture checklist or job aid may be used together to positively verify that the condition, weight, and sequencing of each pallet is correct for each loaded position on the aircraft. Examples of checklists and job aids with related items (not all-inclusive) to accomplish this may include the following:
1. Cargo acceptance:
• Documentation;
• Visual check;
• Special cargo (SCAF); and
• HAZMAT (refer to 49 CFR § 175.33).
2. ULD serviceability:
• Net limits not exceeded; and
• Damage limits not exceeded.
3. Cargo buildup:
• CG;
• Cargo contour; and
• Marking and labeling.
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4. Aircraft preloading, loading, and unloading:
• Preloading: Visual check of CLS for broken and missing components;
• Loading: Adequate restraint used to secure cargo; and
• Unloading: Check to make sure no locks are damaged or missing. If locks are damaged or missing, notify maintenance.
5. Predeparture and postflight cargo checks by trained and qualified person(s):
• Final check that cargo is secured properly;
• Load manifest signed and supporting documentation is available; and
• After flight, whether any broken restraint devices were identified.
6. HAZMAT. The shipping paper required by 49 CFR § 175.33 has been provided to the PIC, and Notification to Captain (NOTOC).
7. Live animals.
8. Special cargo:
• SCAF; and
• Special cargo restraint plan.
9. Vehicle inspection:
• Leaking fluids; and
• Fuel tank levels.
10. Station audit (depending on station classification):
• Documentation;
• Training records;
• Scale calibration;
• Operator’s manuals; and
• Vendor audits.
2.12 Operator’s Evaluation System for W&B Control.
2.12.1 Overview. An operator should establish and maintain an SMS for the continuing analysis, evaluation, and surveillance of the performance and effectiveness of its W&B control program. You can find these elements in AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.
Note: This is a shared responsibility between operations and maintenance roles. A process should be in place to ensure that the operator reports and tracks this information to the CASS or another closed-loop system.
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2.12.2 System List. The system should define how and when operators audit the W&B cargo operation control system to include, at a minimum:
• Aircraft loading;
• Cargo buildup;
• Carriage of special cargo;
• Vendors;
• Personnel training;
• Freight forwarders; and
• CLS.
2.12.3 System Performance. System performance should be monitored to include such items as load plans, load manifests, aircraft configuration changes, cargo loading and restraint system performance (e.g., broken straps identified after use in flight and in-flight shift of cargo), and human factors issues with loaders, load supervisors, and vendors.
2.12.4 System Effectiveness. System effectiveness should be monitored to identify the reliability of the overall performance for cargo operations.
2.13 Training Programs. Operators should develop cargo operations and W&B training programs. Training should explain employee functions (commensurate with their tasks and responsibilities) and express expectations of job duties and responsibilities according to the operator’s procedures. An operator should have procedures to train its employees, managers, and vendors to its standards. Personnel performing cargo operation functions should be trained, qualified, and authorized, as defined in the operator’s manual. This training should be easily identified by documentation in training records and authorization documents readily available.
2.13.1 Training Program Components. The operator’s training program should include:
1. A curriculum acceptable to the FAA.
2. Procedures for maintaining training records.
3. Recurrent training requirements in accordance with the operator’s manual.
4. A description of the training program methods. The program may consist of one or more of the following methods:
• Classroom sessions;
• On-the-job training (OJT);
• Computer-based training (CBT); or
• Other training methodologies operators consider appropriate.
5. A periodic review and update of the program.
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6. Proper identification of employees authorized to provide the training.
7. Content, application, and use of DAH/STC WBMs (source documents).
2.13.2 Identifying Individuals Who Need Training. An operator should have procedures to properly identify those individuals who need training, whether they are employees of the air carrier or of a vendor. These individuals may include:
1. Aircraft loading personnel;
2. Maintenance personnel;
3. Crewmembers;
4. Dispatchers/flight followers;
5. Supervisory loading personnel;
6. Ground handlers;
7. Cargo buildup personnel;
8. Load planners; and
9. Persons involved with W&B and CG calculations.
2.13.3 Curriculum for W&B and Cargo Operations Training.
2.13.3.1 W&B.
2.13.3.1.1 W&B Fundamentals. All operator and vendor personnel involved in W&B calculations should receive fundamental W&B training at a general subject matter level, appropriate to their roles, to include:
1. Familiarization with varying aircraft weights based on manufacturer requirements;
2. The importance of conforming to and applying aircraft manufacturer and TC/STC requirements and zone or compartment limits;
3. The importance of accurate W&B calculations;
4. The importance of proper communication among various personnel; and
5. Recognition of special cargo.
2.13.3.1.2 W&B and CG Calculations. The operator’s training course for personnel or contractors involved with W&B and CG calculations should include, at a minimum:
1. Conforming and applying weight limitations by position, zone, or compartment of an aircraft using the aircraft manufacturer’s requirements;
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2. Determining CG limits for the aircraft;
3. Loading the aircraft per CG limits;
4. Calculating W&B and CG using operator procedures, to include automated or manual calculation systems;
5. Notifying the flightcrew of the W&B of the aircraft;
6. Accounting for the effect of weights of crews, other persons, cargo, and baggage;
7. Communicating W&B or CG issues to personnel involved with cargo loading;
8. Position of cargo and baggage; and
9. Processes that factor CG offsets into cargo, both loaded into ULDs and loaded onto the aircraft.
2.13.3.2 CLS. An operator should provide CLS training to personnel with job functions involving equipment installed to the floor of an aircraft cargo compartment used to restrain ULDs. The CLS usually consists of ball mats, rollers, side guides, and locks for securing ULDs to the aircraft structure.
Operators should educate personnel under a training program that includes procedures, as applicable, for:
1. Inspections for serviceability, including reporting/accounting for damaged or missing restraint devices;
2. Repairs;
3. Reconfiguration within an approved TC/STC design configuration;
4. Loading procedures and their effect on aircraft performance;
5. Res train t requirements; and
6. Restraint systems for each of the operator’s aircraft types.
2.13.3.3 Cargo Buildup Training. All personnel involved in cargo buildup should receive cargo buildup training appropriate to their function, and the cargo should be inspected by trained personnel prior to being loaded on the aircraft.
Elements of cargo buildup training include:
1. Concentrated loads;
2. Pallet load limitations;
3. Restraints;
4. Damage limits for ULDs and restraint devices;
5. Compatibility of aircraft/pallet and net/pallet combinations;
6. HAZMAT;
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7. Scales;
8. Proper ULD configuration;
9. Container configurations and conditions;
10. CG offsets, profiling, and authorization for use on a particular aircraft;
11. Training on how to build up a ULD to comply with CG control;
and
12. Documentation.
2.13.3.4 ULD. Personnel whose job functions include determining compatibility of pallet/net combinations (per operator’s procedures), pallet and airframe compatibility, and cargo restraint devices (e.g., intermixing straps) should have training in these areas.
2.13.3.4.1 The operator should develop a training program that includes:
1. ULD identification (this should include a review of unique ULDs and identify the risks of loading a ULD not authorized for loading aboard the aircraft);
2. Voided space in a ULD;
3. Cargo contours;
4. ULD identification tags, if applicable;
5. ULD weight limits;
6. Serviceability checks;
7. Fastening container components;
8. Fastening a cargo net to a pallet; and
9. Recurrent training for all loading personnel involved in ULD buildup. Operators should determine the time and type of recurrent training appropriate to the type of operation. Operators should require training if loading personnel involved in ULD buildup are no longer considered properly trained.
2.13.3.4.2 P ersons performing ULD maintenance should undergo training on the operator’s or manufacturer’s maintenance program that includes:
1. Acceptance inspection;
2. Routine inspection;
3. Damage limits;
4. Repair;
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5. Maintenance records; and
6. Return to service.
2.13.3.5 SCAF Training Elements (as applicable):
1. TRC: Determining TRC, loading procedures, and restraint methods;
2. Frangible/compressible cargo: Determining frangible/compressible cargo requirements, usage, and procedures, and providing training instructions;
3. Procedures for transporting special cargo;
4. Proficiency with the applicable content of DAH/STC WBMs; and
5. DAH manuals.
2.13.3.6 Loading/Unloading Training. All operator and vendor personnel involved in cargo loading and unloading should receive training appropriate to their function. This includes personnel whose cargo handling functions include ground transportation of cargo, movement of cargo onto or off of an aircraft, or movement/securing of cargo aboard the aircraft with appropriate devices and equipment. Elements of loading/unloading training may include, if applicable:
1. Sill guards;
2. Tail posts;
3. Tail stands;
4. Tail tipping avoidance;
5. Aircraft doors, nets, and smoke barriers;
6. Aircraft floor and ULD base load limits;
7. Aircraft weight limits;
8. Aircraft CG range limits;
9. Cargo access aisle;
10. Aircraft damage avoidance;
11. Damage notification;
12. C argo clearance;
13. CLS;
14. Bulk-loaded cargo;
15. Cargo requiring special handling;
16. Shoring usage;