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.
Par 2.11.1 Page 43 SECTION 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 their processes and procedures. In other words, checks and restraints 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:
2.11.1.1 Cargo Acceptance:
2.11.1.1.1 Documentation;
2.11.1.1.2 Visual check;
2.11.1.1.3 Special cargo (Contact SCAF); and
2.11.1.1.4 Hazmat (See Hazardous Materials Acceptance Checklist).
2.11.1.2 ULD Serviceability:
2.11.1.2.1 Receiving check; and
2.11.1.2.2 Damage limits.
2.11.1.3 Cargo Buildup:
2.11.1.3.1 CG;
2.11.1.3.2 Cargo contour; and
2.11.1.3.3 Marking and labeling.
2.11.1.4 Aircraft Pre-loading, Loading, and Unloading:
2.11.1.4.1 Pre-loading: Visual check of CLS for broken missing components;
2.11.1.4.2 Loading: Adequate restraint used to secure cargo; and
2.11.1.4.3 After loading: Check that all locks are in the up position.
2.11.1.5 Flightcrew Predeparture and Post-Flight Cargo:
2.11.1.5.1 Final check that cargo is secured properly;
2.11.1.5.2 Load manifest signed and supporting documentation available; and
2.11.1.5.3 After flight, were any broken restraint devices identified?
Par 2.11.1 Page 44
2.11.1.6 Hazmat:
2.11.1.6.1 Hazardous Materials Acceptance Checklist accomplished; and
2.11.1.6.2 Notification to PIC.
2.11.1.7 Live Animal: Dry ice not compatible with live animal.
2.11.1.8 Special Cargo:
2.11.1.8.1 SCAF; and
2.11.1.8.2 Cargo restraint schematic.
2.11.1.9 Vehicle Inspection:
2.11.1.9.1 Leaking fluids; and
2.11.1.9.2 Gas tank levels.
2.11.1.10 Station Audit:
2.11.1.10.1Documentation;
2.11.1.10.2Training records;
2.11.1.10.3Scale calibration;
2.11.1.10.4Operators manuals; and
2.11.1.10.5Vendor audits.
Par 2.12.1 Page 45 SECTION 2.12. OPERATOR’S EVALUATION SYSTEM FOR W&B CONTROL
2.12.1 Overview. An operator should establish and maintain a closed-loop system for the continuing analysis, evaluation, and surveillance of the performance and effectiveness of its W&B control program. The closed-loop system should include at least: surveillance, root cause analysis, corrective action, and followup. This system periodically monitors the performance and effectiveness of the W&B control program, which includes cargo operations, to ensure constant compliance. (These elements can be found in the current edition of AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.) Operators can add this system to their CASS or they can develop their own closed-loop 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 similar parallel closed-loop system.
2.12.2 System List. The system should define how and when the operators/applicants 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.
Par 2.13.1 Page 46 SECTION 2.13. TRAINING PROGRAMS
2.13.1 Training Programs. Operators should develop a cargo operations and W&B training programs. Training should explain employee functions (commensurate to 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, as applicable. Personnel performing cargo operation functions must be trained, qualified, and authorized, as defined in the operator’s manual. This training must be easily identified by documentation in training records and authorization documents readily available.
2.13.2 Training Program Components. The operator’s training program should include:
2.13.2.1 A curriculum acceptable to the FAA.
2.13.2.2 Procedures for maintaining training records using the operator’s policy or applicable regulations.
2.13.2.3 Recurrent training requirements and intervals not to exceed 24 months.
NOTE: In accordance with part 121 regulatory requirements, pilots and aircraft dispatchers require recurrent W&B training every 12 calendar-months.
2.13.2.4 A description of the training program methods. The program may consist of one or more of the following methods:
2.13.2.4.1 Classroom sessions;
2.13.2.4.2 On-the-job training (OJT);
2.13.2.4.3 Computer-based training (CBT); or
2.13.2.4.4 Other training methodologies operators consider appropriate;
2.13.2.5 A periodic review and update of the program.
2.13.2.6 Proper identification of employees authorized to provide the training.
2.13.2.7 General awareness and familiarization with hazmat training.
2.13.2.8 Content, application, and use of OEM/STC WBMs (source documents).
2.13.3 Identifying Individuals Who Need Training. An operator should have procedures to properly identify those individuals who need training. An operator should provide training to operator and vendor loading personnel. These individuals may include:
• Aircraft loading personnel;
Par 2.13.3 Page 47
• Maintenance personnel;
• Crewmembers;
• Dispatchers/flight followers;
• Purchasing agents;
• Receiving personnel;
• Freight forwarders and shippers;
• Cargo sales employees and general cargo sales agents;
• Supervisory loading personnel;
• Personnel whose job function entails control of the amount and placement of fuel on board the aircraft;
• Ground handlers;
• Cargo buildup personnel;
• Load planners; and
• Persons involved with W&B and CG calculations.
2.13.4 Curriculum for W&B Training and Cargo Operations.
2.13.4.1 W&B.
2.13.4.1.1 W&B Fundamentals. All operator and vendor personnel involved in a cargo program should receive fundamental W&B training at a general subject matter level to include:
2.13.4.1.1.1 Familiarization with varying aircraft weights based on manufacturer requirements;
2.13.4.1.1.2 The importance of conforming to and applying aircraft manufacturer and TC/STC requirements and zone or compartment limits;
2.13.4.1.1.3 The importance of accurate W&B calculations; and
2.13.4.1.1.4 The importance of proper communication among various personnel.
2.13.4.1.2 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:
2.13.4.1.2.1 Conforming and applying weight limitations by position, zone, or compartment of an aircraft using the aircraft manufacturer’s requirements;
2.13.4.1.2.2 Determining CG limits for the aircraft;
2.13.4.1.2.3 Loading the aircraft per CG limits;
2.13.4.1.2.4 Calculating W&B and CG using operator procedures, to include automated or manual calculation systems;
2.13.4.1.2.5 Notifying the flightcrew of the W&B of the aircraft;