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 31–42

2-39

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.

2-40

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.

2-41

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;

2-42

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;

2-43

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;

2-44

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;

2-45

17. Blocking and bracing;

18. HAZMAT;

19. Frangible cargo; and

20. Material handling equipment.

2.13.3.7 Supervising Cargo Loading.

2.13.3.7.1 Responsibilities. The operator should ensure that the person supervising the loading of the aircraft and preparing the load manifest is responsible for the preparation and accuracy of the load manifest before each takeoff (per § 121.665).

2.13.3.7.2 Elements of Cargo Loading Supervision Training. Load supervision candidates should be trained in the elements listed in paragraphs 2.13.3.1,

2.13.3.2, 2.13.3.3, 2.13.3.4, 2.13.3.5, and 2.13.3.6; as well as the below topics, when applicable:

1. Interlining;

2. Aircraft cargo handling;

3. Cargo loading documentation;

4. Load planning;

5. COMAT; and

6. Familiarity with the accepted operator’s W&B control program or operator’s manuals, including the necessary DAH/STC WBMs.

2.13.4 Accident/Incident Reporting. An operator should have procedures to ensure it trains its personnel in accident/incident reporting procedures.

2.13.5 Providing Air Cargo Information to Flightcrew Members. An operator should inform the flightcrew of the following, when applicable:

1. Procedures used to ensure the aircraft weight is correct;

2. Procedures to report unserviceable ULDs;

3. Loading and weight limitations for removing or deferring cargo restraint components;

4. Proper load configurations when using nets, straps, or containers; and

5. Requirements when loading and restraining special cargo.

2.13.6 Use of Vendors to Provide Training. An operator may designate a person employed by a vendor, such as an aircraft company, ground handling company, or a freight forwarder authorized to train that company’s employees. The operator should have procedures to accept the program.

2-46

2.13.7 Evaluation of Training. An operator’s closed-loop system, which monitors the elements of surveillance, analysis, corrective action, and followup, should include an evaluation of the operator’s cargo training program. The operator also may use an internal evaluation program to review its training program. The operator should ensure it has procedures to periodically review the training program and make changes as necessary.

2.13.8 Training Record Contents. At a minimum, an operator’s training records, in accordance with the operator’s training program, should contain:

• The name of the person trained;

• The initial training date and most recent recurrent training date;

• A description, copy, or the location of training material used, if available;

• The name and location of the person who provided the training; and

• A record that the person was tested and successfully completed training.

3-1 CHAPTER 3. ADMINISTRATIVE INFORMATION

3.1 How to Obtain Copies of Publications.

3.1.1 The current edition of the Code of Federal Regulations (CFR) is available at https://www.ecfr.gov.

3.1.2 Current editions of advisory circulars are available on the FAA website at https://www.faa.gov/regulations_policies/advisory_circulars/ and on the Dynamic Regulatory System (DRS) at https://drs.faa.gov.

3.2 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.

Appendix A A-1 APPENDIX A. RELATED REGULATIONS A.1 Title 14 of the Code of Federal Regulations (14 CFR).

A.1.1 Part 5, Safety Management Systems. Section 5.53, System Analysis and Hazard Identification.

A.1.2 Part 21, Certification Procedures for Products and Articles.

1. Section 21.9, Replacement and Modification Articles.

2. Section 21.21, Issue of Type Certificate: Normal, Utility, Acrobatic, Commuter, and Transport Category Aircraft; Manned Free Balloons; Special Classes of Aircraft; Aircraft Engines; Propellers.

3. Section 21.101, Designation of Applicable Regulations.

4. Section 21.303, Application.

5. Subpart E, Supplemental Type Certificates.

6. Subpart K, Parts Manufacturer Approvals.

7. Subpart O, Technical Standard Order Approvals.

A.1.3 Part 23, Airworthiness Standards: Normal Category Airplanes. Section 23.2620, Airplane Flight Manual.

A.1.4 Part 25, Airworthiness Standards: Transport Category Airplanes.

1. Section 25.23, Load Distribution Limits.

2. Section 25.301, Loads.

3. Section 25.787, Stowage Compartments.

4. Section 25.851, Fire Extinguishers.

5. Section 25.853, Compartment Interiors.

6. Section 25.855, Cargo or Baggage Compartments.

7. Section 25.857, Cargo Compartment Classification.

8. Section 25.858, Cargo or Baggage Compartment Smoke or Fire Detection Systems.

9. Section 25.1301, Function and Installation.

10. Section 25.1309, Equipment, Systems, and Installations.

11. Section 25.1519, Weight, Center of Gravity, and Weight Distribution.

12. Section 25.1529, Instructions for Continued Airworthiness.

13. Section 25.1581, General.

14. Section 25.1583, Operating Limitations.

Appendix A A-2

15. Section 25.1583(c), Weight and Loading Distribution.

16. Section 25.1721, Protection of EWIS.

17. Appendix F.

18. Appendix H, Instructions for Continued Airworthiness.

A.1.5 Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration.

1. Section 43.5, Approval for Return to Service After Maintenance, Preventive Maintenance, Rebuilding, or Alteration.

2. Section 43.13, Performance Rules (General).

A.1.6 Part 45, Identification and Registration Marking. Section 45.15, Marking Requirements for PMA Articles, TSO Articles, and Critical Parts.

A.1.7 Part 119, Certification: Air Carriers and Commercial Operators.

1. Section 119.49, Contents of Operations Specifications.

2. Section 119.55, Obtaining Deviation Authority to Perform Operations Under a U.S. Military Contract.

A.1.8 Part 121, Operating Requirements: Domestic, Flag, and Supplemental Operations.

1. Section 121.135, Manual Contents.

2. Section 121.153, Aircraft Requirements: General.

3. Section 121.363, Responsibility for Airworthiness.

4. Section 121.367, Maintenance, Preventive Maintenance, and Alterations Programs.

5. Section 121.369, Manual Requirements.

6. Section 121.373, Continuing Analysis and Surveillance.

7. Section 121.375, Maintenance and Preventive Maintenance Training Program.

8. Section 121.379, Authority to Perform and Approve Maintenance, Preventive Maintenance, and Alterations.

9. Section 121.380, Maintenance Recording Requirements.

10. Section 121.400, Applicability and Terms Used.

11. Section 121.419, Pilots and Flight Engineers: Initial, Transition, and Upgrade Ground Training.

12. Section 121.422, Aircraft Dispatchers: Initial and Transition Ground Training.

13. Section 121.628, Inoperable Instruments and Equipment.

14. Section 121.665, Load Manifest.

Appendix A A-3

15. Section 121.693, Load Manifest: All Certificate Holders.

16. Section 121.695, Disposition of Load Manifest, Dispatch Release, and Flight Plans: Domestic and Flag Operations.

17. Section 121.697, Disposition of Load Manifest, Flight Release, and Flight Plans: Supplemental Operations.

18. Subpart G, Manual Requirements.

19. Subpart Z, Hazardous Materials Training Program.

20. Appendix O, Hazardous Materials Training Requirements for Certificate Holders.

A.1.9 Part 135, Operating Requirements: Commuter and On Demand Operations and Rules Governing Persons On Board Such Aircraft.

1. Section 135.21, Manual Requirements.

2. Section 135.23, Manual Contents.

3. Section 135.179, Inoperable Instruments and Equipment.

4. Section 135.413, Responsibility for Airworthiness.

5. Section 135.425, Maintenance, Preventive Maintenance, and Alteration Programs.

6. Section 135.437, Authority to Perform and Approve Maintenance, Preventive Maintenance, and Alterations.

7. Section 135.439, Maintenance Recording Requirements.

8. Section 135.443, Airworthiness Release or Aircraft Maintenance Log Entry.

A.1.10 Part 145, Repair Stations.

A.1.11 Part 235, Reports by Air Carriers on Incidents Involving Animals During Air Transport.

Section 235.3, Reports by Air Carriers on Incidents Involving Animals During Air Transport.

A.1.12 Part 382, Nondiscrimination on the Basis of Disability in Air Travel. Section 382.55, May Carriers Impose Security Screening Procedures for Passengers With Disabilities That Go Beyond TSA Requirements or Those of Foreign Governments?

A.2 Title 49 of the Code of Federal Regulations (49 CFR), Transportation. Subtitle B, Other Regulations Relating to Transportation; Chapter I, Pipeline and Hazardous Materials Safety Administration, Department of Transportation; Subchapter C, Hazardous Materials Regulations, as applicable.