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 39–50

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.

Appendix A A-4 A.3 Related International Regulations:

1. International Civil Aviation Organization (ICAO) Doc 9284, Technical Instructions for the Safe Transport of Dangerous Goods by Air.

2. ICAO Doc 9859, Safety Management Manual (SMM).

Appendix B B-1 APPENDIX B. GUIDANCE MATERIAL B.1 Advisory Circulars (AC) (current editions):

1. AC 00-58, Voluntary Disclosure Reporting Program.

2. AC 20-62, Eligibility, Quality, and Identification of Aeronautical Replacement Parts.

3. AC 21-43, Production Under 14 CFR Part 21, Subparts F, G, K, and O.

4. AC 25-9, Smoke Detection, Penetration, and Evacuation Tests and Related Flight Manual Emergency Procedures.

5. AC 25-18, Transport Category Airplanes Modified for Cargo Service.

6. AC 25-22, Certification of Transport Airplane Mechanical Systems.

7. AC 91.21-1, Use of Portable Electronic Devices Aboard Aircraft.

8. AC 120-16, Air Carrier Maintenance Programs.

9. AC 120-27, Aircraft Weight and Balance Control.

10. AC 120-59, Internal Evaluation Programs.

11. AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.

12. AC 120-80, In-Flight Fires.

13. AC 120-92, Safety Management Systems for Aviation Service Providers.

14. AC 120-121, Safety Risk Management Involving Items in Aircraft Cargo Compartments.

15. AC 145-9, Guide for Developing and Evaluating Repair Station and Quality Control Manuals.

B.2 Federal Aviation Administration (FAA) Orders, Forms, Bulletins, and Technical Standard Orders (TSO) (current editions):

1. FAA Order 8110.4, Type Certification.

2. FAA Order 8110.48, How to Establish the Certification Basis for Changed Aeronautical Products.

3. FAA Order 8120.22, Production Approval Procedures.

4. FAA Order 8150.4, Certification of Cargo Containers with Self-Contained Temperature Control Systems (Active ULDs).

5. FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance).

6. FAA Form 8100-9, Statement of Compliance with Airworthiness Standards.

7. FAA Form 8110-3, Statement of Compliance with Airworthiness Standards.

Appendix B B-2

8. FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag.

9. TSO-C90, Cargo Pallets, Nets and Containers (Unit Load Devices).

10. TSO-C172, Cargo Restraint Strap Assemblies.

11. TSO-C202, Cargo Stopper Devices.

B.3 Cargo AC Development Information:

1. Air Cargo System Implementation Plan, March 2003.

2. Cargo Strategic Action Plan, April 2002.

3. Civil Reserve Air Fleet Aircraft Procedures for the U.S. Military, FM 55-9.

B.4 Industry Information (current editions):

B.4.1 International Air Transport Association (IATA). Any IATA procedures used must not conflict with FAA regulatory requirements or aircraft limitations. The following documents are available at https://www.iata.org/en/publications/:

1. IATA ULD Regulations (ULDR).

2. IATA Airport Handling Manual (AHM).

3. IATA Ground Operations Manual (IGOM).

4. IATA Perishable Cargo Regulations (PCR).

5. IATA Live Animals Regulations (LAR).

6. IATA Dangerous Goods Regulations (DGR).

7. IATA Temperature Control Regulations (TCR).

8. IATA Lithium Battery Shipping Guidelines (LBSG).

B.4.2 International Organization for Standardization (ISO) International Standard ISO 4118, Air Cargo—Non-Certified Lower Deck Containers—Design and Testing, and other pertinent international standards. This standard is available at https://www.iso.org/home.h tml.

B.4.3 National Aerospace Standard (NAS) 3610, Cargo Unit Load Devices—Specification For.

B.4.4 SAE Aerospace Standards (AS). These standards are available at https://www.sae.org/standards/.

1. AS1130, Air and Air/Surface (Platform) Cargo Pallets.

2. AS1131, Air and Air/Surface (Platform) Cargo Pallet Nets.

3. AS1491, Interline Air Cargo Pallets.

4. AS1492, Interline Air Cargo Pallet Nets.

Appendix B B-3

5. AS1677, General Requirements for Noncertified Cargo/Baggage Containers.

6. AS4041, Air Mode General Purpose Containers.

7. AS5385, Cargo Restraint Straps—Design Criteria and Testing Methods.

8. AS5896, Certified Containers for Lower Deck Compartments.

9. AS36100, Air Cargo Unit Load Devices—Performance Requirements and Test Parameters.

10. AS36101, Air Cargo Unit Load Devices—Load Distribution Model.

B.4.5 SAE Aerospace Recommended Practices (ARP). These documents are available at https://www.sae.org/standards/.

1. ARP1334, Ground Equipment Requirements for Compatibility with Aircraft Unit Load Devices.

2. ARP1554, Vehicle Transport Unit Load Device (ULD).

3. ARP1621, ULD for Aircraft Transportation of Horses.

4. ARP1840, Aircraft Engine Transport Devices.

5. ARP5486, Air Cargo Pallets—Utilization Guidelines.

6. ARP5595, Cargo Restraint Straps—Utilization Guidelines.

7. ARP5596, Cargo Shoring Guidelines.

Appendix C C-1 APPENDIX C. DEFINITIONS RELATED TO AIR CARGO OPERATIONS C.1 Active Unit Load Devices (ULD). ULDs with active temperature control systems for transporting temperature-sensitive cargo. These systems consist of a highly insulated container with a battery-operated heating/cooling system integrated into the construction of the container. Active ULDs are intended to be operating during flight. Active ULDs are battery-powered in flight and are recharged only while on the ground. The “active” component of these units typically consists of a vapor cycle refrigeration/heat pump type system that is powered by various types of large batteries, depending on the manufacturer.

C.2 Aircraft Loading Schedule. The loading schedule is used to document compliance with the certificated Weight and Balance (W&B) limitations contained in the manufacturer’s Airplane Flight Manual (AFM) and Weight and Balance Manual (WBM). The loading schedule is developed by the operator based on its specific loading calculation procedures and provides the operational limits for use with the operator’s W&B program accepted under this advisory circular (AC).

C.3 Approved Parts. Unless used with reference to another person, means parts approved by the Administrator.

C.4 Authorized Unit Load Device (ULD). A ULD, as defined by National Aerospace Standard (NAS) 3610, Cargo Unit Load Devices—Specification For; SAE Aerospace Standard (AS) 36100, Air Cargo Unit Load Devices—Performance Requirements and Test Parameters; Technical Standard Order (TSO)-C90, Cargo Pallets, Nets and Containers (Unit Load Devices); or other standards, for carriage within the airplane as specified in the AFM/WBM approved by the type certificate (TC) or Supplemental Type Certificate (STC). (Refer to Operations Specification (OpSpec) A002, Definitions and Abbreviations.)

C.5 Bulk Cargo. Cargo transported as individual pieces and loaded into a compartment approved for bulk cargo by the AFM/WBM that is approved by the TC or STC. These items are generally loaded planeside and loaded directly into the bulk compartment.

(Refer to OpSpec A002.)

C.6 Cargo. Any property carried on an aircraft other than mail, stores, and accompanied or mishandled baggage. (Refer to OpSpec A002.)

C.7 Cargo Handling. An operator’s methods of accepting, weighing, securing, and transporting cargo on the ground, and the loading and unloading of an aircraft.

C.8 Cargo Loading System (CLS). Equipment installed to the floor of an aircraft cargo compartment to restrain aircraft ULDs against ground and flight loads. It usually consists of such items as ball mats, end stops, rollers, side guides, and locks for securing ULDs to the aircraft structure. It does not include ULDs, barriers, and tiedown straps.

Appendix C C-2 Note: The CLS is approved as part of either the aircraft’s TC or an STC.

Whenever a CLS is used, it includes cargo handling systems and cargo restraint systems.

C.9 Certified Restraint Straps. These devices should meet the requirements of TSO-C172, Cargo Restraint Strap Assemblies. In TSO-C172, the FAA describes the minimum performance standards (MPS) by which cargo restraint strap assemblies are approved and identified with applicable TSO markings.

C.10 Certified Unit Load Device (ULD). A cargo container (as defined by NAS 3610, SAE AS36100, TSO-C90, or other approval standards) that is authorized for carriage within the airplane as specified in the AFM/WBM approved by the TC or STC.

C.11 Company Materials (COMAT). Company material, commonly called COMAT, is an industry term used by operators to describe nonrevenue materials and supplies owned by the operator that are shipped by the operator in support of its operations.

C.12 Dunnage. Materials used to support and protect cargo in an aircraft cargo compartment or padding used in a shipping container to protect the container’s contents.

C.13 Dynamic Load. Loads imparted on the structure of the aircraft by loaded cargo during taxi, takeoff, cruise, and landing.

C.14 Floating Pallet. A ULD positioned over one or more pallet position(s) and not fully restrained by the aircraft ULD restraint system, but restrained to the aircraft structure by means of strapping to tiedown fittings.

C.15 Frangible or Compressible Cargo. Aircraft manufacturers’ W&B documents vary on this definition; therefore, you should reference the applicable manufacturer’s documents.

C.16 Freight Staging. The holding of cargo awaiting transportation and the delivery of cargo to the aircraft in the correct sequencing of cargo according to the load plan.

C.17 Hazardous Materials (HAZMAT). Materials or substances meeting the definition of hazardous material in 49 CFR part 171, § 171.8.

C.18 Interlining. Transfer from one operator to another, whether the same or different aircraft types are used. For example, a ULD transferred from a domestic operator to a foreign operator.

C.19 Load Supervisor. The job title of the person with overall responsibility for supervising the loading of the aircraft. This person may be responsible for signing the load manifest.

A person with a different job function may also sign the load manifest, if properly trained. Refer to 14 CFR part 121, § 121.665.

C.20 Noncertified Unit Load Device (ULD). A ULD that is not certified by the ULD manufacturer, does not meet the TSO-C90 or Parts Manufacturer Approval (PMA)

Appendix C C-3 certification requirements, and/or is not listed in the design approval holder’s (DAH) aircraft WBM (TC or STC).

C.21 Offset Cargo. Cargo positioned on the pallet in a manner that the cargo is shifted beyond the perimeter of the pallet resulting in (1) the center of gravity (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. Offset cargo may also include nonpalletized cargo loaded asymmetrically in the airplane.

C.22 Other Authorized Persons. Persons who are not members of the crew and who are carried on board the aircraft per § 121.583.

C.23 Overhanging Cargo. Cargo that extends beyond the perimeter of the pallet in at least one direction but still allows the net to perform its intended function. The pallet can still be restrained by the CLS and does not require additional straps to the aircraft structure.

C.24 Overweight Cargo. Cargo that exceeds the maximum allowable weight as defined by the aircraft AFM/WBM for aircraft ULD position.

C.25 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.

C.26 Pallet (Air Cargo). A flat platform with a flat undersurface of standard dimensions, on which cargo is assembled and secured and which interfaces directly with the aircraft cargo handling and restraint system.

C.27 Piercing Cargo. Cargo of a piercing or penetrating nature, such as rods, pipes, extrusions, or beams that could become a projectile hazard under flight operational loads.

C.28 Pod. An external container attached to an aircraft for carrying cargo.

C.29 Primary Restraint. The restraint of the cargo to the aircraft structure for regulatory load conditions, such as flight and emergency landing. This restraint secures cargo in the forward, aft, vertical, and lateral directions.

C.30 Receiving Inspection. Ins pection to ensure conformance to part number, purchase order, and/or other applicable criteria.

C.31 Rigid Cargo. Cargo with a density that is rigid in nature, as defined in the aircraft manufacturer’s W&B document.

C.32 Sharp Cargo. Cargo that has a piercing or penetrating nature, or cargo with sharp edges or corners.

C.33 Special Cargo. Cargo that requires special handling and securing/restraining procedures within the limitations specified in the AFM/WBM approved by the TC/STC. Special cargo may be enclosed in an approved bulk compartment if the WBM has limitations

Appendix C C-4 supporting procedures for securing and restraining the special cargo. (Refer to OpSpec A002.)

C.34 Special Handling Procedures. Additional or unique procedures, as determined by the operator, which may be required for some cargo in order to protect the cargo or the aircraft during handling acceptance, loading, or in flight.

C.35 Supplemental Restraint. Restraint that is utilized in addition to primary restraint in order to stabilize cargo and prevent shifting.

C.36 Tall Rigid Cargo (TRC). 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. TRC is used only on the Boeing 747 aircraft.

C.37 Tare Weight. The weight of the empty ULD, including its normal complement of loading restraint devices. Tare weight also may include the empty weight of other material handling equipment, such as baggage carts and dollies, used to weigh cargo on a scale.

C.38 Temporary Restraint Device. Temporary net restraint fittings installed in place of damaged or missing fittings, or temporary net take-up hooks and net corner lashing lines.

C.39 Unit Load Device (U LD). A device for grouping, transferring, and restraining cargo for transit. It consists of a pallet with a net or it may be a container.

C.40 Unitized. Consolidated multiple packages or items loaded into or on a ULD.

C.41 Vendor. Any person or entity performing a service on behalf of the operator who is not an employee of the operator. This may include, but is not limited to, freight forwarders, service providers, contractors, subcontractors, customs brokers, shippers, or other operators who perform cargo buildup, aircraft loading, and unloading for the operator.

This also includes repair services provided by an FAA-certificated entity.

C.42 Zone Weight. Cumulative weight loaded within a designated zone in the aircraft as defined by the aircraft’s WBM. That zone weight may include upper deck loads and lower loads directly beneath.