Par 2.6.3 Page 31 NOTE: Under 14 CFR part 382, the Department of Transportation (DOT) makes a distinction between service animals, such as seeing-eye dogs, and animals kept as cargo, such as pets. Under part 382, an animal that a passenger can properly identify as a service animal must accompany the passenger at the passenger’s seat. The operator should treat animals not classified as service animals under part 382 as pets and handle them as a special cargo load as discussed above.
NOTE: Under 14 CFR part 234, the term “animal” is defined as a warm- or cold-blooded animal that, at the time of transportation, is being kept as a pet in a family household in the United States. In this AC, “live animals” refers to all animals transported as cargo, regardless of whether they are kept as pets as defined in part 234. The operator should review incident reporting requirements of part 234, § 234.13.
2.6.3.15.19ULDs;
2.6.3.15.20Special cargo; and NOTE: Cargo requiring special handling procedures is a separate but related concept to special cargo. See Section 2.8 for more information and to assist in identifying when one of the cargo requiring special handling examples listed above is classified as special cargo.
2.6.3.15.21Radio Frequency Identification (RFID) 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 if authorized by (1) the aircraft manufacturer WBM or (2) STC supplementary WBM. The authorizing document should include serviceability limits, 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) STC holder. 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 should 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 it does not overstress the aircraft floor attachments. Reference aircraft manufacturer prohibitions.
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 WBM.
Par 2.6.5 Page 32
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 WBM or its supplement. The manufacturer’s 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.
NOTE: The best method to determine the effectiveness of a strap or other restraint devices is that the reaction to load must be in the same direction as force is applied. Consideration should be given to strap installation angle and resulting reduction in available restraint.
2.6.5.4 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 secure the end of the rope to the net panel to prevent disengagement.
2.6.5.5 Restraining cargo using the aircraft’s ultimate load conditions described by the manufacturer’s WBM or its supplement. The operator should consider that these devices must provide restraint in the forward, aft, vertical, and lateral directions.
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, must 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 STC holder, or (3) other sources acceptable to the FAA. These procedures should address:
• Using and attaching other restraint devices to the aircraft’s installed seat track, tiedown track, and/or tiedown rings (See Section 2.8);
• Using and attaching other restraint devices to the pallet base tiedown track of commercial pallets according to the ULD manufacturer requirements and rings of military pallets; and
• 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 must not be prone to slippage from its intended position on cargo, and the operator should engage the lock mechanism so the strap is taut without being over-tightened.
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
Par 2.6.6 Page 33 a footprint or contact area. Cargo pieces heavier than a load bearing weight limit require shoring.
The operator should have procedures describing:
• Materials acceptable for use in shoring, such as wood planks or plywood;
• Calculations or methods for determining the amount and thickness of shoring materials; and
• 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, and odd-shaped cargo to prevent shifting during loading, unloading, and flight conditions. The operator should use blocking and bracing techniques to stabilize such cargo pieces. The operator’s procedures should describe:
• Acceptable materials for blocking and bracing;
• Calculations or methods for determining the amount and thickness of blocking and bracing materials; and
• Methods for applying blocking and bracing materials to the cargo piece.
2.6.9 Frangible (Compressible) Cargo. Frangible cargo may be required in certain positions for protection of the aircraft, occupants, and its ability to withstand emergency landing conditions, as required by the aircraft manufacturer W&B document. An aircraft manufacturer’s W&B document varies on this definition, therefore, you should reference their document 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 aircrafts, 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 STC holder.
Par 2.7.1 Page 34 SECTION 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 a load supervisor, to ensure:
• All cargo is properly built up and weighed;
• Vendor’s cargo scales have current calibration certificates;
• Planning and calculation of cargo and passenger placement maintains the aircraft within permissible CG and structural load limits;
• Cargo is properly secured with the appropriate type(s), quantity and placement of cargo restraint, and all pallet locks are engaged when used;
• The aircraft is correctly loaded and unloaded using the operator’s procedures;
• Cargo is placed on the aircraft in such a way as to prevent overloading sensitive sections of the airframe and cargo floor;
• CLS, ULDs, and other restraint devices are in serviceable condition and properly used;
• Standard average weight or actual baggage weights are confirmed (refer to AC 120-27);
• Flightcrew members or authorized maintenance personnel are notified of damaged, missing, or inoperative cargo compartments, CLSs, installed cargo nets, or smoke barrier components;
• All cargo-related documents are accurate and properly completed before submission to flightcrew members; and
• The load manifest is signed by a trained, qualified, and authorized person.
NOTE: Operators may use different terminology to identify person who has the duty of supervising the loading of aircraft or the load supervisor function, such as loadmaster, load lead, and load chief. The load supervisor may physically load the aircraft, but primarily supervises loading crews and procedures.
NOTE: The signature of the person supervising the load, on the load manifest, indicates the aircraft is loaded correctly.
2.7.2 How to Verify Cargo was Loaded Properly. Operators should designate personnel to provide information to (1) the PIC, or (2) 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.
Operators should note that this information does not impact the requirements for a load manifest per § 121.665.
Par 2.7.3 Page 35
2.7.3 Information Needed to Verify Cargo is Loaded Properly. The information indicating that cargo is properly loaded should include:
2.7.3.1 The flight date.
2.7.3.2 The flight number.
2.7.3.3 The aircraft registration number.
2.7.3.4 The origin of the flight leg.
2.7.3.5 The destination of the flight leg.
2.7.3.6 The ULD numbers (for cargo carried in ULDs).
2.7.3.7 The weight of each ULD loaded aboard the aircraft.
2.7.3.8 The weight of the bulk cargo, by compartment or position, as applicable.
2.7.3.9 The load schematic for special cargo.
2.7.3.10 A certification statement verifying that:
2.7.3.10.1 All ULD locks are up;
2.7.3.10.2 All installed nets or smoke barriers are properly attached;
2.7.3.10.3 All ULDs loaded are in an operational condition;
2.7.3.10.4 All cargo was loaded using operator cargo loading procedures;
2.7.3.10.5 Tail stand or post was removed, as applicable; and
2.7.3.10.6 All cargo was loaded aboard the aircraft as depicted on the load plan form, verification form, or other similar documents.
2.7.3.11 The signature, or electronic equivalent, of the load supervisor or other authorized, trained, and qualified loading personnel.
2.7.4 Maintaining Records of Cargo Loading Verification Information. Operators must have procedures to retain a completed and signed copy, or electronic equivalent, of the document(s) containing the information listed in paragraph 2.7.3 above with the load manifest, per § 121.695 or § 121.697, as applicable.
2.7.5 Performing Cargo Buildup and Loading Audits. Operators should have a program acceptable to the FAA for periodic audits of cargo planning, building, and loading. The audits should be of sufficient scope and frequency to ensure that all cargo handling personnel are following operator’s cargo procedures. (See Section 2.2, Operator’s Evaluation System for W&B Control.
Par 2.8.1 Page 36 SECTION 2.8. TRANSPORT OF SPECIAL CARGO
2.8.1 What is Special Cargo? Cargo that is not contained in a ULD certified for the airplane CLS or enclosed in a cargo compartment certified for bulk loading is special cargo. This type of cargo requires special handling and securing/restraining procedures.
2.8.2 Special Cargo Analysis Function (SCAF). The operator should identify a person who has overall responsibility for the SCAF. Operators should develop policies and procedures for the identification, acceptance, and carriage of special cargo. If an operator carries special cargo, it must comply with the TC/STC WBM. Operators should use the SCAF to determine if the cargo is indeed special cargo, evaluate associated risks, and develop a plan to ensure a safe flight using TC/STC WBM data. The operator should ensure participants are trained, qualified, and authorized to perform functions listed below in paragraph 2.8.3.
2.8.2.1 Person with Overall Responsibility. Examples of a person with overall responsibility of the SCAF that do not require the technical expertise of SCAF functions may be:
2.8.2.1.1 Director of Safety (DOS);
2.8.2.1.2 Chief pilot;
2.8.2.1.3 Director of Operations (DO); or
2.8.2.1.4 Director of Maintenance (DOM);
2.8.2.2 SCAF Participants. Examples of SCAF participant(s) who will require technical expertise in SCAF functions may include:
2.8.2.2.1 Loadmaster;
2.8.2.2.2 Engineering; or
2.8.2.2.3 Other trained and qualified persons.
2.8.3 Procedures for Planning a Special Cargo Transport. The operator should develop policies and procedures for transporting special cargo. Procedures must be based on approved data from the aircraft manufacturer/STC WBM.
2.8.3.1 SCAF Responsibilities. Based on the operator’s procedures, the SCAF will:
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 in assisting the SCAF in determining 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
Par 2.8.3 Page 37 load’s restraint capability in each direction. 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 demonstrate restraints are distributed in accordance with the airplane/STC WBM.
2.8.3.1.3 Construct a Load Schematic. Construct a diagram/pictorial schematic based on FAA-approved airplane WBM/supplement. The schematic should:
2.8.3.1.3.1 Illustrate restraint calculations and a proposed tiedown scheme for each special cargo item.
2.8.3.1.3.2 Include the number and angle of 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.
2.8.3.1.3.3 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. Refer to Appendix H, Example Proposed Tiedown Scheme.
NOTE: The special cargo tiedown scheme will comply with the FAA-approved airplane WBM/supplement and can be incorporated into the operator’s manuals. A separate load schematic will not be necessary for the items incorporated in the operators’ manuals. However, when using this procedure, the operator should reference the manual and page number on a cargo loading document and retain it with load manifest.
2.8.3.2 Operator’s Responsibilities. The operator should:
2.8.3.2.1 Loading. Make load schematic and any necessary instructions available to the loadmaster, 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 utilizes schematic and instructions during cargo loading.
2.8.3.2.2 Record Retention. File the load schematic as outlined above in subparagraph 2.8.3.1.3 with the load manifest.
2.8.4 Characteristics Associated with Special Cargo. Anytime restraint is attached directly to the aircraft floor, the cargo should be classified as special cargo. This includes supplemental restraints because it creates parallel load paths. 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:
Par 2.8.4 Page 38
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 Overweight Cargo. Cargo that exceeds the maximum allowable weight as defined by the aircraft WBM for aircraft ULD position.
2.8.4.3 Overhang 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.
2.8.4.4 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.
2.8.4.5 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.
2.8.4.6 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:
2.8.4.6.1 Can roll and shift during transportation due to their shape;
2.8.4.6.2 Hard to lift and move without damaging the edges;
2.8.4.6.3 Can be bundled together and require blocking and bracing techniques to prevent cargo shift;
2.8.4.6.4 Can become projectiles if not handled and secured properly; and
2.8.4.6.5 The weight is concentrated in a very small area and often exceeds the floor-bearing weight capacity of the aircraft.
2.8.4.7 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:
2.8.4.7.1 Fuel levels,
2.8.4.7.2 Load shoring and restraint,
2.8.4.7.3 Blocking and bracing (chocking) wheels to restrict movement, and
2.8.4.7.4 Tiedown attachment points.
DATE DRAFT AC 120-85A Par 2.9.1 Page 39
2.8.4.8 Tall Cargo and TRC. Currently, TRC only applies to the B-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.
2.8.4.9 Cargo 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.
2.8.4.10 Cargo Using a Sandwich Pallet. A sandwich pallet is the practice of placing a pallet on top of another pallet for various reasons such as additional shoring, the upper pallet being damaged, or when stacking empty pallets. 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.
2.8.4.11 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.
Par 2.9.1 Page 40 SECTION 2.9. USE OF MULTIPLE ENTITIES
2.9.1 Interlining. Interlining is considered when cargo is transferred from one operator to another, whether using the same or different aircraft types. The receiving operator must ensure that all 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 their policies and procedures, which include, at a minimum:
2.9.1.1.1 Cargo check (visual examination) including serviceability of ULDs;
2.9.1.1.2 ULD compatibility with aircraft (see paragraph 2.4.6, Determining ULD Compatibility); and
2.9.1.1.3 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, Definitions Related to Air Cargo Operations, and paragraph 2.9.2, Vendors, for additional information on vendors.
2.9.2 Vendors.
2.9.2.1 Vendors Performing ULD Handling or Buildup.
2.9.2.1.1 As previously mentioned, the operator is ultimately responsible for the security of the cargo and safety of flight. There are multiple entities involved in the movement of cargo. Examples of these entities 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 must ensure that:
2.9.2.1.1.1 Requirements are met in accordance with the instructions of the operator;
2.9.2.1.1.2 Sufficient and proper ULD storage capacity is available for all units handled;
2.9.2.1.1.3 All staff and supervising staff receive training appropriate to the tasks performed; and
2.9.2.1.1.4 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.
Par 2.9.2 Page 41
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:
2.9.2.2.1 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.
2.9.2.2.2 Designate a trained, qualified, and authorized person to oversee the vendor services to ensure the vendor performs the services in accordance with the operator procedures.
2.9.2.2.3 Audit vendors for compliance with operator procedures and training programs.
2.9.2.2.4 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 by authorized, trained, and qualified personnel must meet operator standards before being loaded.
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.
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 multiple entities are trained, qualified, and authorized to perform duties, audit third party operations, and ensure adherence to the operator’s procedures, when applicable.
Par 2.10.1 Page 42 SECTION 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 ensure the following:
• Proper security of all cargo is maintained;
• Proper special handling of cargo is provided;
• Proper storage of cargo that is also safe from natural elements;
• Appropriate climate control for cargo is provided, if applicable (e.g. refrigerated);
and
• Proper documentation of all cargo is maintained.
2.10.2 Transporting Stored/Staged Cargo. Prior to loading the aircraft, the operator should ensure when transporting cargo that has been stored or staged, an acceptance check is performed to ensure:
• Documentation and cargo weights are accurate;
• Cargo is clear of debris such as sand, snow, or water; and
• Cargo meets Transportation Security Administration (TSA) and Customs clearance requirements.