AC 120-85A

U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Air Cargo Operations Date: 6/25/15 Initiated by: AFS-300 AC No: 120-85A Change:

This Flight Standards Service (AFS) advisory circular (AC) contains guidance on cargo loading.

It is intended for air operators, Original Equipment Manufacturers (OEM), Supplemental Type Certificate (STC) holders, Parts Manufacturer Approval (PMA) holders, Technical Standard Order (TSO) holders, and aircraft owners and operators who manufacture their own parts.

This AC responds to a recent aircraft accident involving a part 121 air carrier that was transporting heavy military vehicles, known as “special cargo.” It was revised after evaluating special cargo operations, load planning, restraint calculations, restraint methods, freight staging, freight forwarding, and interlining of cargo. It enhances the safety of flight operations by clearly identifying responsibilities of parties and enhances guidance concerning the operator’s Weight and Balance (W&B) control program and procedures for cargo restraint and aircraft loading; unit load devices (ULD) and restraint devices; and the transport of special cargo. It also provides clarity regarding cargo handling training requirements. Adhering to the recommendations in this AC is one means, but not the only means, for air carriers to better manage their cargo operations.

ORIGINAL SIGNED BY /s/ John S. Duncan Director, Flight Standards Service

CONTENTS Paragraph Page

CHAPTER 1. GENERAL INFORMATION

1.1.1 Purpose1

1.1.2 Audience1

1.1.3 Background1

1.1.4 Document Organizations2

1.1.5 Where You Can Find this AC2

CHAPTER 2. OPERATIONAL PROCESSES AND PROCEDURES

Section 2.1. General3

2.1.1 Purpose3

2.1.2 Airplane W&B Manual3

2.1.3 Company Operating Manuals3

2.1.4 Process and Procedure Recommendations3

Section 2.2. Weight and Balance Control Program5

2.2.1 Develop a W&B Control Program5

2.2.2 Contents of an Operator’s W&B Manual5

Section 2.3. Classifying Cargo Compartment for Fire Suppression, Cargo Loading

System Components, Installed Nets and Smoke Barriers8

2.3.1 Classification of Cargo Compartments for Fire Suppression8

2.3.2 Cargo Compartments Designed to Accept ULDs8

2.3.3 Cargo Compartments Not Designed to Accept ULDs8

2.3.4 Substituting CLS Components8

2.3.5 Substituting PMA Products9

2.3.6 Substituting TSO Products9

2.3.7 Substituting PC, TC, Amended TC, and STC Products9

2.3.8 Substituting Owner-Produced Parts9

2.3.9 Addressing CLS Component Discrepancies10

2.3.10 Replacing a CLS Component10

2.3.11 Repairing a CLS Component10

2.3.12 CLS Components in the Minimum Equipment List (MEL)11

2.3.13 Installed Nets in the Maintenance Program12

2.3.14 Smoke Barriers12

Section 2.4. Unit Load Devices and Cargo Restraint Devices13

2.4.1 Restraints13

2.4.2 Primary Restraint13

2.4.3 Supplemental Restraint13

2.4.4 ULDs and Other Cargo Restraint Devices14

2.4.5 Determining ULD Compatibility16

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2.4.6 Responsibilities for the Maintenance and Repair of ULDs, Pallets, and Nets18

2.4.7 Responsibilities of an Operator After Purchasing/Leasing a ULD18

2.4.8 ULD and Restraint Damage Limits21

2.4.9 Establishing Usage Limits for Cargo Straps21

2.4.10 Additional Procedures for Cargo Nets22

2.4.11 Temporary Installation of Restraints on a Cargo Net22

2.4.12 Performing Operation Checks on ULDs or Other Cargo Restraint Devices23

Section 2.5. Cargo Weigh Scales24

2.5.1 Responsibility for Ensuring the Weight of Loaded Cargo is Accurate24

2.5.2 Ensuring Weigh Scales are Accurate24

2.5.3 Ensuring Weigh Scales are Calibrated24

2.5.4 Maintaining Records of Calibration Checks24

2.5.5 Performing Functional Checks on Weigh Scales24

2.5.6 Items for which an Operator Should Know the Tare Weight25

2.5.7 Reweighing Loading Equipment for Tare Weight After Maintenance, Repair,

or Modification25

Section 2.6. Operations for Cargo Handling and Aircraft Loading26

2.6.1 Overview26

2.6.2 Operator Procedures on ULD Buildup and Cargo Restraint26

2.6.3 Operator Procedures on Cargo Loading and Unloading27

2.6.4 Use of Cargo Restraint Devices Other than ULDs31

2.6.5 Procedures for Use of Primary Restraint Devices Other than the CLS31

2.6.6 Operator Procedures for Supplemental Cargo Restraint Devices32

2.6.7 Procedures for Cargo Shoring33

2.6.8 Blocking and Bracing Techniques33

2.6.9 Frangible (Compressible) Cargo33

2.6.10 Cargo Loading Procedures for Combi-Configured Aircraft33

Section 2.7. Load Supervision, Load Verification, and Operator Audits34

2.7.1 Supervising Cargo Loading34

2.7.2 How to Verify Cargo was Loaded Properly34

2.7.3 Information Needed to Verify Cargo is Loaded Properly35

2.7.4 Maintaining Records of Cargo Loading Verification Information35

2.7.5 Performing Cargo Buildup and Loading Audits35

Section 2.8. Transport of Special Cargo36

2.8.1 What is Special Cargo?36

2.8.2 Special Cargo Analysis Function (SCAF)36

2.8.3 Procedures for Planning a Special Cargo Transport36

2.8.4 Characteristics Associated with Special Cargo38

Section 2.9. Use of Multiple Entities40

2.9.1 Interlining40

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2.9.2 Vendors40

2.9.3 Freight Forwarding41

2.9.4 Responsibility for Multiple Entities41

Section 2.10. Freight Staging42

2.10.1 Staging Cargo at Different Operating Locations42

2.10.2 Transporting Stored/Staged Cargo42

Section 2.11. Checklists and Job Aids43

2.11.1 Using Checklists and Job Aids43

Section 2.12. Operator’s Evaluation System for W&B Control45

2.12.1 Overview45

2.12.2 System List45

2.12.3 System Performance45

2.12.4 System Effectiveness45

Section 2.13. Training Programs46

2.13.1 Training Programs46

2.13.2 Training Program Components46

2.13.3 Identifying Individuals Who Need Training46

2.13.4 Curriculum for W&B Training and Cargo Operations47

2.13.5 Accident/Incident Reporting52

2.13.6 Providing Air Cargo Information to Flightcrew Members52

2.13.7 Use of Vendors to Provide Training52

2.13.8 Evaluation of Training52

2.13.9 Training Records52

2.13.10 Training Record Contents53

CHAPTER 3. CERTIFICATION

Section 3.1. General55

3.1.1 Purpose55

3.1.2 Information Provided55

Section 3.2. Aircraft Configuration56

3.2.1 Certification Requirements for Cargo-Carrying Aircraft56

3.2.2 Differences Between a Bulk Load and Nonbulk Load Cargo Compartment56

3.2.3 Freighter Conversions56

3.2.4 Features of Cargo Restraint Systems57

3.2.5 Ensuring the Integrity of a Cargo Restraint System57

3.2.6 Fire Protection Design Features of Aircraft that are Essential to

Operational Safety58

3.2.7 Installing Accommodations for Supernumeraries on Aircraft Certificated

Under Part 2558

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3.2.8 Modifications and Alterations that Could Impact W&B59

3.2.9 Design Elements that Could Affect the Cargo Location59

3.2.10 Design Approval Projects that Require ICAs59

3.2.11 Design Approvals59

Section 3.3. Unit Load Devices61

3.3.1 Classification of ULDs61

3.3.2 Using Certified Nets and Straps61

3.3.3 CG Offset Limits62

CHAPTER 4. ADMINISTRATIVE INFORMATION

4.1.1 How to Obtain Copies of Publications63

4.1.2 Additional Information63

APPENDIX A. RELATED REGULATIONS (4 pages)1

APPENDIX B. GUIDANCE MATERIAL (4 pages)1

APPENDIX C. DEFINITIONS RELATED TO AIR CARGO

OPERATIONS (4 pages)1

APPENDIX D. ACRONYMS AND ABBREVIATIONS (2 pages)1

APPENDIX E. SUGGESTED STRUCTURAL DATA FOR PASSENGER-TO-CARGO

CONVERSION PROJECT (4 pages)1

APPENDIX F. PASSENGER-TO-CARGO CONVERSIONS SUPPLEMENTAL

TYPE CERTIFICATE DATA PACKAGE FOR SYSTEMS AND

EQUIPMENT (4 pages)1

APPENDIX G. DESIGN CRITERIA FOR OUTWARD OPENING

DOORS (2 pages)1

APPENDIX H. EXAMPLE PROPOSED TIEDOWN SCHEME FOR A SINGLE

SPECIAL CARGO ITEM (2 pages)1

APPENDIX I. ACTIVE UNIT LOAD DEVICE MARKING (2 pages)1

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CHAPTER 1. GENERAL INFORMATION

1.1.1 Purpose. This advisory circular (AC) provides operators with recommended procedures for managing cargo operations. Developing and using these comprehensive procedures is key to establishing a safe and efficient cargo operation. The AC provides guidance for aircraft cargo loading systems (CLS), restraints, special cargo, and unit load devices (ULD)This AC is not mandatory and does not constitute a regulation. This AC describes an acceptable means, but not the only means, of complying with applicable regulations to manage cargo operations.

• The terms must and will are used in this AC to reflect regulatory requirements.

• When this AC uses suggestive and permissive language (e.g., should and may), it is used to describe recommended or acceptable means, but not the only means, to comply with this AC.

1.1.2 Audience. Air operators, Original Equipment Manufacturers (OEM), Supplemental Type Certificate (STC) holders, Parts Manufacturer Approval (PMA) holders, Technical Standard Order (TSO) holders, and aircraft owners and operators who manufacture their own parts.

1.1.3 Background. This air cargo operations AC was developed in 2005, after an accident involving a McDonnell Douglas DC-8 aircraft, in response to National Transportation Safety Board (NTSB) safety recommendations. Those recommendations detailed training requirements for cargo handling personnel, and development of advisory material for Title 14 of the Code of Federal Regulations (14 CFR) part 121 carriers and principal operations inspectors (POI). That curriculum content includes but is not limited to Weight and Balance (W&B), cargo handling, cargo restraint, hazards of misloading, and training for cargo handling personnel.

1.1.3.1 Revision. In April 2013, a Dubai-bound Boeing 747-400 crashed just after takeoff from Bagram Air Base, Afghanistan. It was transporting heavy military vehicles, known as “special cargo” loads. Following that accident, this AC was revised after evaluating W&B personnel training, special cargo operations, load planning, restraint calculations, restraint methods, freight staging, freight forwarding, and interlining of cargo.

1.1.3.2 Cargo Operations Program. An operator’s cargo operations program constitutes the foundation for safely transporting air cargo. This program includes such features as:

• Acceptance of cargo by the operator;

• Associated engineering analysis supporting the carriage of that cargo, as applicable;

• Maintenance and airworthiness of CLS components;

• Processes for the buildup, handling, loading and restraint of cargo by ground personnel; and

• Calculations and verification of the W&B of an aircraft by ground and flight personnel.

1.1.4 Document Organization. This AC has four chapters and several appendices. Chapter 1 contains general information about the AC. Chapter 2 addresses operational processes and

Par 1.1.4 Page 2

procedures, and Chapter 2 address separate operational processes and procedures of cargo operations, with individual sections that address separate operational aspects. Chapter 3 details background information for the certification and continued airworthiness of ULDs, restraint devices, and CLSs installed on aircraft. Chapter 4 describes how to get more information regarding this AC. The appendices contain information related to regulations supporting the AC, a list of related publications, related definitions, acronyms, passenger-to-cargo conversion information, and outward-opening cargo door information, example of a tiedown scheme for single item, Active ULD marking, and a flow chart for special handling as it relates to ULD and special cargo.

1.1.5 Where You Can Find This AC. You can find this AC on the Federal Aviation Administration (FAA)’s Web site at http://www.faa.gov/regulations_policies/advisory_circulars.

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Par 2.1.1 Page 3 CHAPTER 2. OPERATIONAL PROCESSES AND PROCEDURES SECTION 2.1. GENERAL

2.1.1 Purpose. This chapter informs operators of the importance of providing necessary guidance to loading personnel for proper cargo buildup, weighing and restraint, and aircraft loading and unloading.

2.1.2 Airplane W&B Manual. The Weight and Balance Manual (WBM) is part of the operating limitations section of the Airplane Flight Manual (AFM). In accordance with 14 CFR part 21, § 21.41, the operating limitations are part of the airplane type certificate (TC) and, therefore, can be modified only by changing that certificate; that is, by obtaining an amended TC or Supplemental Type Certificate (STC). Revisions to the AFM are approved as AFM supplements, and the approval is based on a finding that, with the AFM revisions, the airplane continues to meet the applicable airworthiness standards. Operators are required to comply with the operating limitations by 14 CFR part 91, § 91.9(a). The aircraft WBM is often a separate document, but remains part of the AFM. Title 14 CFR part 25, § 25.1583(c) authorizes the WBM as a separate document.

2.1.3 Company Operating Manuals. If the procedures provided by the aircraft manufacturers do not have sufficient detail and guidance, an operator may develop supplemental procedures and submit it to the FAA for approval. Any time the operator develops a procedure it can not contradict regulation. Regulation always supercedes company manuals. Supplemental procedures ensures that cargo handling personnel have the guidance necessary to maintain safety of flight operations. An operator should have a training program in place for cargo buildup, cargo loading system (CLS) configuration, aircraft loading/unloading, carriage of hazardous materials (hazmat), and special cargo. Personnel associated with these job functions and the supervising of cargo loading operations should be trained and qualified in these positions.

NOTE: Appendix B lists guidance materials that can be used as a resource to develop your supplemental procedures. However, the FAA may still request additional data based on the submitter’s operation.

2.1.4 Process and Procedure Recommendations. The FAA recommends the following be included in an operator’s manual that is essential to air cargo operations. These recommendations are discussed in more detail throughout this chapter. This is not an all-inclusive list.

2.1.4.1 Have procedures for control of Weight and Balance (W&B) for both aircraft and cargo.

2.1.4.2 Have procedures to study and evaluate the capability of any aircraft the operator may use to transport any type of cargo, including special cargo. This determination should be made prior to accepting a shipment. Operators may include a reference to the source document for this evaluation.

2.1.4.3 Have procedures for loading and unloading all types of cargo, including Company Material (COMAT).

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2.1.4.4 Have procedures to restrain cargo in aircraft compartments, including main deck, lower deck, fore and aft compartments, or pods, in accordance with the requirements of the Original Equipment Manufacturer (OEM)’s WBM, Supplemental Type Certificate (STC) W&B supplement for certified ULDs, non-certified ULDs, bulk loaded cargo, and special cargo.

2.1.4.5 Have procedures for the use, storage and evaluation of the condition of cargo restraints

(e.g. straps, netting, and ropes) used to restrain bulk, ULD, or special cargo. Procedures should provide for routine serviceability checks and the identification and removal of any unserviceable restraint devices. Procedures should also provide the process to follow if failed restraints are identifed while in use.

2.1.4.6 Have procedures to control the use, calibration, or verification of weigh scales for operators and vendors.

2.1.4.7 Have procedures to control the repair of ULDs, aircraft cargo loading systems (CLS), cargo restraint devices, and other miscellaneous aircraft cargo handling equipment required for loading or unloading aircraft. This also includes installed nets and installed smoke barriers.

2.1.4.8 Have procedures in its manual system for the control of all manuals and manual revisions applicable to air cargo operations. These procedures should ensure the operator:

• Has current versions of the manuals, and

• Provides authorized maintenance personnel and vendors with current manuals and manual revisions.

2.1.4.9 Have procedures to assure that all personnel are properly trained, qualified, and authorized to perform their job function(s).

2.1.4.10 Have procedures for reconfiguring the CLS and document that the appropriate personnel have been notified. This ensures maintenence, flightcrew, and the loading crew are aware that center of gravity (CG) limits may have changed for current and future flights.

2.1.4.11 Have procedures and processes for determining the carriage of special cargo.

2.1.4.12 Have procedures for freight forwarding, interlining, and freight staging.

2.1.4.13 Have procedures for the carriage of hazardous materials (hazmat).

2.1.4.14 Have procedures for incorporating a Continuing Analysis and Surveillance System (CASS) to verify the performance and effectiveness of its CLS maintenance program and provide corrections to any deficiencies discovered in the program.

2.1.4.15 Have procedures for incorporating a closed-loop system that monitors the elements of surveillance, analysis, corrective action, and follow-up to verify the performance and effectiveness of its W&B control program (including cargo operations) and provide corrections to any deficiencies discovered in the program.

NOTE: Under 14 CFR part 121, § 121.137, all manuals must be under the control of the operator even if they are located at a remote site.

Par 2.2.1 Page 5 SECTION 2.2. WEIGHT AND BALANCE CONTROL PROGRAM

2.2.1 Develop a W&B Control Program. Type-certificated (TC) aircraft have an FAA-approved WBM provided by the OEM. The OEM WBM for an aircraft is the basis for an operator’s W&B control program. Operating instructions may be used to achieve the limitations in the WBMs.

2.2.1.1 Modified Aircraft. For aircraft with a passenger-to-cargo conversion, or other modifications—such as an aircraft CLS—a W&B supplement describing the modification’s effect on the aircraft is FAA approved and is issued as part of an STC or amended TC.

2.2.1.2 W&B Control Program. An operator’s W&B control program should include at a minimum:

2.2.1.2.1 Loading limitations, including limitations on empty or unoccupied positions with missing or damaged restraints;

2.2.1.2.2 Information on aircraft cargo restraint systems, such as aircraft CLSs, installed nets, ULDs, and other restraint devices;

2.2.1.2.3 Requirements for special cargo loads;

2.2.1.2.4 A list of ULDs compatible with the CLS;

2.2.1.2.5 Aircraft operating weights;

2.2.1.2.6 Information for the determination of an aircraft’s CG;

2.2.1.2.7 Weight limitations for each compartment and zone, when applicable;

2.2.1.2.8 Procedures for incorporating fuel loading and usage into the aircraft’s W&B calculations;

2.2.1.2.9 Instructions for, and samples of, load documents and manifests, to include special cargo loading documents;

2.2.1.2.10 Aircraft loading schedules; and

2.2.1.2.11 Processes and procedures to monitor the W&B control program.

2.2.2 Contents of an Operator’s W&B Manual. Operator WBMs must be based on an aircraft’s W&B data, amended TCs, and applicable STCs.

2.2.2.1 Aircraft Basic Operating Weight Control. An aircraft must conform to the basic operating weight determined by the operator.

2.2.2.2 Zone and Compartment Weight Limitations. An operator’s aircraft must conform to all zone weight limitations and compartment weight limitations under the aircraft manufacturer, TC holder and STC holder W&B requirements.

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2.2.2.3 CG Range Limitations. The operator must include reference charts and tables in its W&B manual, or other manual that provide the FAA-approved weight and CG range limitations.

2.2.2.4 Aircraft Weight. An operator’s aircraft must conform to the aircraft manufacturer’s W&B requirements, and should establish procedures for weighing the aircraft using the manufacturer’s WBM requirements or other FAA-approved or accepted methods. One accepted method is contained in the current edition of AC 120-27, Aircraft Weight and Balance Control.

2.2.2.5 Aircraft Major Alteration Requirements.

2.2.2.5.1 A major alteration to an aircraft that changes the W&B requirements and/or limitations must be accomplished utilizing approved data.

2.2.2.5.2 The operator must have a procedure in place to ensure all supplemental information developed, issued, and approved for that aircraft is incorporated into the operator’s W&B control program. An operator should apply the most restrictive ranges of the alteration incorporated to the operation of that aircraft. For example, if multiple STCs apply, the operator should use the STC with the most restrictive W&B limitations when incorporating the supplemental information into the operator’s W&B control program.

2.2.2.5.3 In cases of multiple STCs applied to a single aircraft, the STCs should be evaluated for effect on each other and the appropriate limitations applied. At a minimum, an operator should include the supplemental information described above and cross-reference the supplemental information in the operator’s WBM. In addition, the operator should organize the supplemental information in a way that facilitates use by loading personnel. Finally, the operator should include the supplemental information in the operator’s WBM and any charts or tables that indicate proper weight and CG range limitations. The operator must incorporate CLS STCs into its maintenance program.

2.2.2.6 Aircraft CLS Limitations. The operator must conform to, and apply, the W&B and CG limitations of the aircraft CLSs, as established by the OEM/STC WBM. The operator should apply the most restrictive limitations considering all major alterations made to the aircraft.

Reconfiguration of the CLS, such as re-positioning pallet locks, should only be accomplished using the OEM/STC WBM. The operator must have a method to determine W&B calculations for any reconfiguration of a CLS.

2.2.2.7 Carriage of Other Persons (Other than Flightcrew). The regulations (§ 121.583) allow for the carriage of certain persons aboard an airplane without complying with certain passenger-carrying requirements of part 121. These persons are commonly referred to as supernumeraries. They may be carried aboard an airplane because of their necessity for the safety of the flight, their relationship with the air carrier, or by virtue of certain knowledge and abilities attributed to them through selection and mandatory training. An operator must establish procedures for the carriage of supernumeraries. See Chapter 3, Certification, for further discussions of supernumeraries. At a minimum, the procedures must address: