AC 120-85 

Date: 6/20/05 

ADVISORY CIRCULAR 

AIR CARGO OPERATIONS 

Flight Standards Service 

Washington, D.C. 

Initiated By: AFS-300

6/20/05 AC 120-85 

PREFACE 

Proper cargo loading is essential for safe flight operations. The air carrier must have procedures 

in place to ensure that employees and vendors are properly trained in the process, the loading is 

properly completed, and that cargo restraints and loading devices are properly maintained. The 

loading personnel, flightcrew, and flight engineer must all take responsibility to ensure that the 

process is completed correctly. 

This advisory circular (AC) responds to safety recommendations made by the National 

Transportation Safety Board after an accident in which basic steps were not followed during the 

loading of the accident flight. Adhering to the recommendations in this AC is one means (but 

not the only means) for air carriers to better manage their air cargo operations. 

/s/ 

James J. Ballough 

Director, Flight Standards Service 

Page i (and ii)

6/20/05 AC 120-85 

CONTENTS 

Page 

CHAPTER 1. GENERAL INFORMATION..................................................................................1 

CHAPTER 2. OPERATIONAL PROCESSES AND PROCEDURES..........................................3 

Section 1. General...................................................................................................................... 3 

Section 2. Weight and Balance Procedures............................................................................... 4 

Section 3. Cargo Handling System Components, Smoke Barriers, and Installed Nets............. 6 

Section 4. Maintenance of ULDs and Other Cargo Restraint Devices.................................... 11 

Section 5. Cargo Weigh Scales................................................................................................ 18 

Section 6. Cargo Restraint and Airplane Loading and Unloading .......................................... 20 

Section 7. Load Supervision, Load Verification, and Air Carrier Audits .............................. 29 

Section 8. Training................................................................................................................... 31 

CHAPTER 3. CERTIFICATION.................................................................................................37 

Section 1. General.................................................................................................................... 37 

Section 2. Airplane Configuration........................................................................................... 37

Section 3. Unit Load Devices (ULD) ...................................................................................... 41 

CHAPTER 4. ADMINISTRATIVE INFORMATION................................................................45 

APPENDIX 1. RELATED REGULATIONS (2 pages).............................................................1 

APPENDIX 2. REGULATORY AND GUIDANCE MATERIAL (2 pages)...........................1

APPENDIX 3. DEFINITIONS RELATED TO AIR CARGO OPERATIONS (2 pages) .....1 

APPENDIX 4. ACRONYMS AND ABBREVIATIONS (1 page) ............................................1 

APPENDIX 5. SUGGESTED STRUCTURAL DATA FOR PASSENGER-TOCARGO CONVERSION PROJECT (3 pages)...........................................................................1 

APPENDIX 6. PASSENGER-TO-CARGO CONVERSIONS SUPPLEMENTAL 

TYPE CERTIFICATE DATA PACKAGE FOR SYSTEMS AND 

EQUIPMENT (3 pages).................................................................................................................1 

APPENDIX 7. DESIGN CRITERIA FOR OUTWARD OPENING DOORS (1 page) .........1 

APPENDIX 8. TRANSPORT CATEGORY AIRPLANE ICA CHECKLIST (4 pages)......1

Page iii (and iv)

6/20/05 AC 120-85 

CHAPTER 1. GENERAL INFORMATION 

100. PURPOSE. 

a. This AC provides air carriers with recommended procedures for managing air carrier 

cargo operations. It provides recommendations about what items should be included in an air 

carrier cargo operations system. Developing and using these comprehensive procedures is key to 

establishing a safe and efficient cargo management system. This AC contains recommendations 

for Original Equipment Manufacturers (OEM), Parts Manufacturer Approval (PMA) holders, 

Technical Standard Order (TSO) holders, and airplane owners and operators who manufacture 

their own parts. The AC provides guidance for the certification of unit load devices (ULD), 

restraints, and airplane cargo handling systems. 

b. This AC is not mandatory and does not constitute a regulation. This AC presents 

recommendations for an acceptable means, but not the only means, to manage air cargo 

operations. 

101. BACKGROUND. 

a. This air cargo operations AC was developed after considering the following National 

Transportation Safety Board (NTSB) safety recommendations, and specifically in response to 

A-98-47. 

(1) A-98-44. Require all Title 14 Code of Federal Regulations (14 CFR) part 121 air 

carriers to provide flightcrews with instruction on mistrim cues that might be available during 

taxi and initial rotation, and require air carriers using full flight simulators in their training 

programs to provide flightcrews with special purpose operational training that includes an 

unanticipated pitch mistrim condition encountered on takeoff. 

(2) A-98-45. Conduct an audit of all part 121 supplemental cargo operators to ensure 

that proper weight and balance documents are being used, that the forms are based on

manufacturer’s data or other approved data applicable to the airplane being operated, and that 

Federal Aviation Administration (FAA) principal inspectors confirm that the data are entered 

correctly on the forms. 

(3) A-98-46. Require carriers operating under part 121 to develop and use loading 

checklists to positively verify that all loading steps have been accomplished for each loaded 

position on the airplane and that the condition, weight, and sequencing of each pallet is correct. 

(4) A-98-47. Require training for cargo handling personnel and develop advisory 

material for carriers operating under part 121 and principal operations inspectors that addresses 

curriculum content that includes but is not limited to, weight and balance, cargo handling, cargo 

restraint, and hazards of misloading, and require all operators to provide initial and recurrent

training for cargo handling personnel consistent with this guidance. 

b. This AC also incorporates resolutions to those categories of concern in the Cargo 

Strategic Action Plan and the follow on Air Cargo System Implementation Plan. A group 

chartered by the Aircraft Maintenance Division, AFS-300, to address the issues detailed in the 

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AC 120-85 6/20/05 

NTSB Safety Recommendations, developed these plans. The categories and issues identified 

include: 

(1) Certification of airplane cargo handling systems, ULDs, and alteration of airplanes 

for the carriage of cargo. 

(2) Maintenance of airplane cargo handling systems and ULDs. 

(3) FAA oversight of air carriers and their procedures when carrying cargo both in 

passenger and all cargo operations. 

102. DISTRIBUTION. 

If you are— You should review— Also note that— 

An air carrier carrying cargo 

under part 121, or a vendor 

All chapters, but specifically 

Chapter 2. 

Cargo includes passenger 

checked baggage, freight, 

hazardous materials (hazmat), 

dangerous goods, and 

company materials. Cargo 

does not include passenger 

carry-on baggage. 

An OEM, PMA, or TSO 

holder 

All chapters, but specifically 

Chapter 3. 

An entity repairing, altering, 

or modifying airplanes for the 

carriage of cargo 

All chapters, but specifically 

Chapter 3. 

103. DOCUMENT ORGANIZATION. This AC consists of four chapters and several 

appendixes. Chapter 1 contains general information about the AC. Chapter 2 addresses 

operational processes and procedures. Each section within Chapter 2 addresses a separate 

operational aspect of air carrier air cargo operations. Chapter 3 addresses issues related to 

regulatory certification requirements of ULDs, restraint devices, and cargo handling systems 

installed on airplanes. Chapter 4 tells how to get more information regarding this AC. Finally, 

the appendixes contain information such as the regulatory basis of the AC, a list of related 

publications, related definitions, acronyms, passenger-to-cargo conversion information, outwardopening cargo door information, and a checklist for developing Instructions for Continued 

Airworthiness (ICA). 

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6/20/05 AC 120-85 

CHAPTER 2. OPERATIONAL PROCESSES AND PROCEDURES 

Section 1. General 

200. PURPOSE. This chapter informs air carriers of the importance of providing necessary 

guidance to loading personnel for proper cargo buildup, weighing and restraint, and airplane 

loading and unloading. 

201. RECOMMENDATIONS GIVEN. 

a. The FAA considers the following a recommended minimum level of detail that should 

be included in an air carrier’s manual that is essential to air cargo operations. These 

recommendations are discussed in more detail throughout this chapter. This is not an allinclusive list. To safely transport cargo an air carrier must: 

(1) Have procedures in its manual for control of weight and balance for both airplanes 

and ULDs. 

(2) Have procedures in its manual for loading and unloading all types of cargo, 

including bulk loaded cargo and cargo contained in ULDs. 

(3) Have procedures to restrain cargo in airplane compartments, including main deck, 

lower deck, fore and aft compartments, or pods, in accordance with the requirements of the 

airplane manufacturer’s weight and balance manual, Supplemental Type Certificate (STC) 

weight and balance supplement, or other FAA-approved weight and balance document for 

certified ULDs, uncertified ULDs, or bulk loaded cargo. 

(4) Have procedures in its manual for the use of miscellaneous restraint devices in 

cases that may not be specified by the applicable airplane manufacturer weight and balance 

manual, approved STC supplement, or other FAA-approved data. 

(5) Have procedures in its manual to control the use and calibration of weigh scales. 

(6) Have procedures in its manual to control the repair of ULDs, airplane cargo loading 

systems, cargo restraint devices, and other miscellaneous airplane cargo handling equipment 

required for loading or unloading the airplanes. This also includes installed nets and installed 

smoke barriers. 

(7) Have procedures in its manual system for the control of all manuals, manual 

revisions, and service bulletins (SB) applicable to air cargo operations. These procedures should 

ensure the air carrier: 

(a) Communicates (supplies address and contact) to equipment manufacturer, STC 

holders, and other necessary entities, where to send manuals, manual revisions, SBs, and letters. 

(b) Has current versions of the manuals. 

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(c) Has all applicable SBs, letters, and manual revisions incorporated into its 

maintenance and repair procedures. 

(d) Provides authorized maintenance personnel and vendors with current manuals, 

manual revisions, SBs, and letters. 

NOTE: Under part 121, section 121.137, all maintenance manuals must be 

under the control of the air carrier even if they are located at a remote site. 

b. An air carrier should recognize that its airplane manufacturer weight and balance 

manuals, STC supplements to the weight and balance manual, or other FAA-approved data may 

not provide the information required for the air carrier to adequately manage carriage of cargo. 

This AC contains minimum guidelines for air cargo operations. If the procedures provided by 

the airplane manufacturers do not contain sufficient detail and guidance, an air carrier may 

incorporate supplementary FAA-accepted procedures to ensure loading personnel have the 

guidance necessary to maintain safety of flight. An air carrier should also have a training 

program in place for cargo buildup, airplane loading, and airplane unloading. 

Section 2. Weight and Balance Procedures 

202. USING AN AIRPLANE’S WEIGHT AND BALANCE MANUAL TO DEVELOP A 

WEIGHT AND BALANCE CONTROL PROGRAM. Each type-certificated, transport 

category airplane has an FAA-approved weight and balance manual that contains information 

that enables an air carrier to develop a weight and balance control program. This information 

may include, but is not limited to: 

a. Loading limitations, including limitations on empty or unoccupied positions with 

missing or damaged restraints. 

b. Information on airplane cargo restraint systems, for example, the airplane cargo 

handling system, installed nets, ULDs, and other restraint devices. 

c. Requirements for special cargo loads, such as cargo that is frangible, crushable, 

incompressible, sharp, or outsized. 

d. A list of ULDs compatible with the cargo handling system. 

e. Airplane operating weights. 

f. Information for the determination of an airplane’s center of gravity (CG). 

g. Weight limitations for each compartment and zone, when applicable. 

h. Fuel loading data. 

i. Samples of load sheets and manifests, and how to use those documents. 

j. Load schedules. 

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203. OTHER CONSIDERATIONS WHEN DEVELOPING A WEIGHT AND BALANCE 

CONTROL PROGRAM. The airplane manufacturer weight and balance manual for a 

particular airplane is the basis for an air carrier weight and balance control program. For 

airplanes converted to cargo from passenger operations and for airplanes with other 

modifications, such as an airplane cargo handling system, a weight and balance supplement 

describing the modification’s effect on the airplane is FAA-approved and issued as part of an 

STC or amended type certificate (TC). Air carrier weight and balance manuals should be based 

on airplane’s weight and balance data or, if applicable, equivalent STC, amended TC, or other 

FAA-approved data. 

204. CONTENTS OF AN AIR CARRIER’S WEIGHT AND BALANCE MANUAL.

a. Airplane Basic Operating Weight Control. Air carrier airplanes must conform to the 

basic operating weight provided by the airplane manufacturer, STC holder, TC holder, and 

buyer-furnished equipment weight and balance requirements, and airplane operations and 

maintenance manuals. 

b. Zone and Compartment Weight Limitations. Air carrier airplanes must conform to 

all zone weight limitations and compartment weight limitations under the airplane manufacturer, 

TC holder, and STC holder weight and balance requirements, other FAA-approved weight and 

balance requirements, and any other information provided. 

c. CG Range Limitations. The air carrier must include in its weight and balance manual, 

or other manual, reference charts and tables that provide FAA-approved weight and CG range 

limitations. 

d. Airplane Weight. Air carrier airplanes must conform to the airplane manufacturer’s 

weight and balance requirements. The air carrier also should establish procedures on how to 

weigh the airplanes in accordance with the airplane manufacturer’s weight and balance manual 

requirements or other FAA-approved or accepted methods, such as the current edition of 

AC 120-27, Aircraft Weight and Balance Control. 

e. Airplane Major Alteration Requirements. 

(1) When an air carrier accomplishes a major alteration to an airplane that changes the 

weight and balance requirements and/or limitations, the FAA will approve a weight and balance 

supplement or other control document, such as an STC, FAA Form 337, Major Repair and 

Alteration, or other weight and balance reports. This supplementary information describes the 

effect of the alteration on the airplane. 

(2) The air carrier should have a procedure in place to ensure all supplemental 

information developed, issued, and approved for that airplane is incorporated into the air carrier 

weight and balance control program. An air carrier should apply the most restrictive ranges of 

the alteration incorporated to the operation of that airplane. For example, if multiple STCs 

apply, the air carrier should use the STC with the most restrictive weight and balance limitations 

when incorporating the supplemental information into the air carrier weight and balance control 

program. 

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AC 120-85 6/20/05 

(3) In cases of multiple STCs applied to a single airplane, the STCs should be evaluated

for effect on each other and the appropriate limitations applied. At a minimum, an air carrier 

should include the supplemental information described above and cross-reference the 

supplemental information in the air carrier’s weight and balance manual. In addition, the air 

carrier should organize the supplemental information in a way that facilitates use by loading 

personnel. Finally, the air carrier should include the supplemental information in the air carrier’s 

weight and balance manual and any charts or tables that indicate proper weight and CG range 

limitations. 

f. Airplane Cargo Handling System Limitations. The air carrier must conform to and 

apply the weight and balance and CG limitations of the airplane’s cargo handling systems, as 

established by the TC holder, STC holder, or other FAA-approved data. The air carrier should 

apply the most restrictive limitations considering all major alterations made to the airplane. 

g. Supernumeraries. An air carrier should establish procedures for carrying 

supernumeraries, where applicable. See Chapter 3 for further discussions of supernumeraries. 

At a minimum, the procedures should address the following: 

(1) A method for calculating the weight of the supernumeraries and their carry-on and 

checked baggage, such as actual weight or average weight (see AC 120-27, as amended, for 

guidance on how to calculate weights). 

(2) Any special procedures or limitations the air carrier may require when carrying 

supernumeraries aboard an airplane. These limitations may be specified as part of the type 

design in the type certificate data sheet or a limitation associated with the 14 CFR part 25 

exemption for the carriage of supernumeraries. 

(3) Instructions for documenting the weight of supernumeraries and for communicating 

the information to the pilot in command or other authorized, trained, and qualified personnel for 

determining weight and balance. 

Section 3. Cargo Handling System Components, Smoke Barriers, 

and Installed Nets 

205. CLASSIFICATION OF CARGO COMPARTMENTS DESIGNED TO ACCEPT 

AND RESTRAIN CARGO. Airplane cargo compartments are designed to accept and restrain 

cargo in various ways. Cargo compartments are classified as class A, B, C, or E in parts 25 

and 121, depending on accessibility and fire protection requirements. Some cargo compartments 

accept ULDs and some do not. In general: 

a. Class A compartments are accessible to the flightcrew for fire fighting, usually from the 

flight deck or from areas adjacent to the flight deck. 

b. Class B compartments are accessible to the flightcrew for fire fighting. Such 

compartments are usually on smaller airplanes such as business jets that have been altered for 

all-cargo operations. 

Page 6 Par 204 
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c. Class C compartments are used on passenger airplanes for the carriage of baggage or 

other cargo. These compartments require a fire suppression and detection system that is 

controlled from the pilot or flight engineer station; the compartment is not accessible to the 

flightcrew during flight. 

d. Class E compartments are on all-cargo airplanes. These compartments are on both the 

main deck and lower lobe areas and require fire detection systems, and are not accessible to the 

flightcrew during flight. 

206. CARGO COMPARTMENTS DESIGNED TO ACCEPT ULDs. Cargo compartments 

designed to accept ULDs are equipped with an airplane cargo handling system designed to 

restrain ULDs in the airplane. Cargo handling systems are also designed as a conveyance for 

ULDs, allowing them to move easily in and out of the airplane. The cargo handling system

comprises various assemblies such as restraint locks, side rails, and ball and roller conveyors. In 

addition, some cargo handling systems are powered. Cargo handling systems may be installed in 

main deck and/or lower deck compartments. When the flightcrew and/or supernumeraries are 

seated on the same deck forward of the cargo handling system, a smoke barrier and 9G net or 

rigid 9G bulkhead is installed between the cargo handling system and the flightcrew and 

supernumeraries. 

207. CARGO COMPARTMENTS THAT ARE NOT DESIGNED TO ACCEPT ULDs. 

Cargo compartments not designed for ULDs are called bulk compartments. Bulk compartments 

may have vertical or horizontal nets. Depending on the design and purpose of the net, it may 

restrain cargo from shifting vertically, longitudinally, and laterally within the compartment or 

from shifting onto the cargo door or cargo door area within the compartment. Bulk 

compartments are designed to provide inherent protection for airplane systems and structure 

against damage from shifting cargo for all flight and landing conditions. 

208. SUBSTITUTING CARGO HANDLING SYSTEM COMPONENTS. An air carrier 

may substitute airplane cargo handling system components under several different procedures, 

depending on the certification method for the components being substituted. Substitution also 

may involve the replacement of cargo handling system components with those of another design, 

or replacement of subcomponents of an airplane cargo restraint assembly with those of another 

design. 

209. PROCEDURES FOR SUBSTITUTING A CARGO HANDLING SYSTEM 

COMPONENT. In cases in which an air carrier substitutes a cargo handling system component, 

the air carrier should have a procedure that addresses the following: 

a. The load bearing components that the air carrier may substitute. 

b. The level of substitution, such as a complete assembly or parts of an assembly, the air 

carrier allows and the conditions that support each process. 

c. The FAA-approved data used. 

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NOTE: Cargo handling system components are certificated under the following 

methods: PMA, TSO, Production Certificate (PC), TC, amended TC, STC, and 

under rules governing owner-produced parts.

210. SUBSTITUTING PMA PRODUCTS. An air carrier may substitute airplane cargo 

handling system components manufactured under a PMA, provided the PMA holder has 

established eligibility for installation on the airplane and provides resulting airplane limitations. 

Installation data and any limitations may be found in the following sources: 

a. Component maintenance manual (CMM); 

b. Manufacturer’s illustrated parts catalog;

c. Air carrier instructions based on approved data from the FAA, the airplane 

manufacturer, or STC holder; and 

d. Manufacturer’s SBs or service letters. 

211. SUBSTITUTING TSO PRODUCTS. An air carrier may substitute cargo handling 

system components manufactured under a TSO, provided the air carrier has procedures to 

determine whether the unit is eligible for installation. An air carrier may substitute products 

approved under TSO using information from the following sources: 

a. SBs. 

b. STC. 

c. Airplane manufacturer’s TC. 

d. CMM. 

e. Manufacturer’s illustrated parts catalog. 

212. SUBSTITUTING PC, TC, AMENDED TC, AND STC PRODUCTS. Parts can be 

approved through the PC, TC, amended TC, and STC processes. Instructions for 

interchangeability of cargo handling system components are covered under the instructions 

accompanying these processes. An air carrier may substitute these components using the 

following source documentation for these processes: 

a. Type certificate data sheets. 

b. SBs, service letters, or equivalent FAA-approved data. 

c. Manufacturer’s ICA. 

Page 8 Par 209 
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213. SUBSTITUTING OWNER-PRODUCED PARTS. Part 21 permits an owner to 

manufacture parts for use on its own airplane. In such cases, an air carrier should have processes 

in place to: 

a. Identify in its maintenance program components manufactured for the airplane cargo 

handling system. 

b. Ensure the parts it manufactures are not sold or distributed for use by another air carrier 

or vendor. 

c. Show its owner-produced parts meet the equipment manufacturer cargo handling 

system type design. 

d. Maintain the continued airworthiness of the owner-produced part. 

214. ADDRESSING CARGO HANDLING SYSTEM COMPONENT DISCREPANCIES. 

An air carrier may address airplane cargo handling system component discrepancies by replacing 

or repairing the applicable component. If the air carrier discovers systemic problems with the 

reliability of its components, the air carrier should report such problems to the component 

manufacturer. 

215. REPLACING A CARGO HANDLING SYSTEM COMPONENT. An air carrier may 

replace a cargo handling system component with a new, rebuilt, overhauled, or repaired 

serviceable component. This component should be eligible for installation on the particular 

airplane. 

216. REPAIRING A CARGO HANDLING SYSTEM COMPONENT. 

a. An air carrier may repair a component on the airplane, in its own shops, or at a repair 

vendor using FAA-approved or -accepted data, per the requirements of 14 CFR part 43. The 

repair vendor may be under the direct control of an air carrier or a vendor the air carrier 

designates. The air carrier has primary responsibility for determining that the component meets 

applicable regulatory requirements and the repair vendor is authorized to repair the component. 

b. Cargo handling system components repaired by a vendor should undergo a receiving 

inspection in accordance with air carrier procedures. Documentation also should accompany the 

component to (1) confirm each component is certified as serviceable and (2) provide traceability 

to the data used for repair. The documentation should include the following: 

(1) Identity of the company that owns the component; 

(2) FAA repair station certificate number, if applicable, and vendor name; 

(3) Component part number; 

(4) Component serial number, if applicable; 

(5) Component nomenclature; 

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AC 120-85 6/20/05 

(6) Component times and/or cycles (if applicable); 

(7) Quantity of components; 

(8) Specifications used for repair; 

(9) Certification statement of procedures used; 

(10) Traceability documentation; and 

(11) Signature of an authorized agent. 

c. The air carrier should retain its repair records in accordance with its established 

procedures to comply with the requirements of part 121, section 121.380. 

217. CARGO HANDLING SYSTEM COMPONENTS IN THE MINIMUM 

EQUIPMENT LIST (MEL). 

a. Dispatch Deviation Procedures. An air carrier must ensure the airplane MEL contains 

adequate instructions or references the appropriate manual for dispatch deviation procedures that 

describe the following: 

(1) Total number of items installed and minimum number required for dispatch; 

(2) Loading limitations because of missing or defective equipment; 

(3) References showing where loading restrictions are found; 

(4) The appropriate category for repair; and 

(5) Instructions for ensuring MEL limitations are included in weight and balance 

computations and the load plan. 

b. Procedures for Inoperative or Missing Cargo Handling System Components. An 

air carrier must include procedures within the air carrier MEL for inoperative or missing cargo 

handling system components. These procedures should include any requirements for: 

(1) Reconfiguration of the airplane, if necessary; 

(2) Voiding of adjacent positions, if necessary; 

(3) Accounting for limitations; 

(4) Notification to flight crewmembers of the missing components; and 

(5) Instructions for ensuring MEL limitations and/or restrictions are included in weight 

and balance computations and the load plan. 

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218. INSTALLED NETS IN THE MAINTENANCE PROGRAM. An air carrier 

maintenance program should contain procedures for the maintenance and inspection of installed 

vertical and horizontal cargo compartment nets and 9G barrier nets. 

a. The program should encompass: 

(1) In-house or third-party vendor repair procedures; 

(2) Receiving inspection procedures; and 

(3) Serviceability limitations. 

b. The air carrier should list third-party vendors on its approved vendor listing and include 

any required inspection item requirements. 

Section 4. Maintenance of ULDs and Other Cargo Restraint Devices 

219. CATEGORIZATION OF ULDS AND OTHER CARGO RESTRAINT DEVICES. 

ULDs and other airplane cargo restraint devices are composed of two general categories, primary 

and supplemental. An air carrier should have procedures to control the airworthiness and 

subsequent operational serviceability of ULDs and other restraint devices whether used as a 

primary or a supplemental restraint. 

220. TYPES OF ULDS AND OTHER RESTRAINT DEVICES. 

a. Certified ULDs. Certified ULDs should meet the requirements of TSO-C90, Cargo 

Pallets, Nets, and Containers; STC requirements, if applicable; or other FAA-approved 

certification requirements. The air carrier should have on file an FAA approval letter, certificate, 

or other certifying document, such as a conformance certificate provided by the ULD equipment 

manufacturer, for all of its certified ULDs. 

b. Uncertified ULDs. The air carrier should have documentation from the 

ULD equipment manufacturer stating to which design criteria the ULD is manufactured. These 

design criteria may be industry standards such as Society of Automotive Engineers (SAE) 

Aerospace Standard (AS) 1677, General Requirements for Uncertified Cargo/Baggage

Containers; International Standards Organization (ISO) publication no. 4118, Non-certified 

Lower-deck Containers for Air Transport; International Air Transport Association (IATA) ULD 

Technical Manual (UTM) 50; or other FAA-accepted standard. 

c. Cargo Nets. Most air carrier weight and balance manuals recognize a TSO cargo 

pallet/net as a primary restraint for unitized cargo. A cargo net is the only restraint device that 

conforms to the shape of the cargo while providing restraint in all directions so that the load is 

spread to the net fittings and pallet edge rails. Deviation from the use of approved cargo 

pallet/net as a primary restraint may require the cargo to be airplane compartment restrained, if 

loaded in a compartment certified for compartment restraint, or restrained by cargo straps or 

other approved devices as provided in the airplane’s weight and balance manual or STC 

supplemental weight and balance manual. The air carrier manual should have policies and 

procedures in place to address this issue. 

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d. Other Cargo Restraint Devices. Cargo restraints such as straps, chains, ropes, and 

nets not part of pallet/net combinations that are approved for use by the airplane manufacturer 

weight and balance documentation, STC holder documentation, or other FAA-approved data 

may be used by the air carrier. Their use should be addressed in the air carrier’s manual. 

221. DETERMINING IF A ULD IS COMPATIBLE WITH THE AIRPLANE IT IS TO 

BE LOADED ON. It is critical to the safety of flight for the air carrier to have procedures in 

place to confirm that each ULD loaded aboard an airplane is compatible with the airplane 

regardless of whether the air carrier or a vendor of the air carrier owns the ULD. Not all ULDs 

are FAA-approved as compatible with all airplanes. Therefore, an air carrier should have 

procedures to: 

a. Ensure certified and uncertified ULDs are compatible with the airplane and do not 

present a hazard to the airplane. 

b. Ensure uncertified ULDs meet either UTM 50, AS 1677, or ISO 4118, or another FAAaccepted standard. 

c. Inform employees and vendors loading airplanes converted from passenger to all-cargo 

by an STC that it could be subject to ULD requirements that differ from other STC conversions 

or production airplane configurations in the air carrier fleet. 

d. Ensure personnel understand that compatibility and limits or restrictions may exist 

between the same type of airplanes that have STC conversions and may have also been produced 

by a TC holder as a freighter. The following list is an example of the differences that may be 

found between production freighters and converted freighters. 

(1) Airplane weight limits. 

(2) Cargo zone index changes forward/aft body. 

(3) CG limits. 

(4) Forward and aft body structure loading limits. 

(5) Fuel index tables. 

(6) Individual compartment maximum loads. 

(7) Lateral cargo unbalances. 

(8) Main deck door opening variances. 

(9) Maximum allowable loads limited by restraint. 

(10) Maximum allowable takeoff weight limits. 

(11) Maximum area load limits. 

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(12) Maximum cargo zone load limits (includes cumulative loads above and below 

deck). 

(13) Maximum cumulative loads aft to forward. 

(14) Maximum floor landing limits. 

(15) Maximum ramp weight limits. 

(16) Maximum ULD gross weight restrictions by airplane position. 

(17) Missing inoperative cargo restraint limits. 

(18) Reduced over wing zone capabilities. 

(19) ULD height restrictions. 

(20) Asymmetrical load limits. 

(21) Zero fuel weight restrictions. 

e. Compare the size of the main and lower deck compartment door openings with the 

contour and dimensions of ULDs to be loaded. An air carrier should take into consideration any 

height restriction within the airplane cargo compartments. 

f. Ensure approved ULD limitations are maintained in the manual. An air carrier should 

base these limitations on data from applicable airplane weight and balance manuals, STC 

supplemental weight and balance manuals, or other FAA-approved sources. The limitations 

should identify which ULDs are compatible with specific airplanes and should be easily 

accessible by all affected persons. 

NOTE: The limitations section of the aircraft flight manual (AFM) or AFM 

supplement may include information from the airplane weight and balance 

manual. 

g. Ensure its airplane weight and balance manual or other appropriate manual states which 

ULDs may be carried aboard the airplane on the main deck or lower lobes, as appropriate. In 

certain instances, particularly with an airplane’s lower lobes, certain compartments may be 

certified to carry bulk or restrained cargo or both. The weight and balance manual or other 

appropriate manual should identify the ULDs by the type qualified to be carried aboard the 

airplane in consideration of the airplane and cargo handling system capabilities. 

h. Ensure uncertified ULDs are not used in any compartment of all-cargo or combination 

airplane unless they are authorized or if tiedown instructions are provided on how to restrain 

them as bulk cargo. 

i. Ensure employees and vendors do not combine a net and pallet that are not compatible 

with each other. 

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222. INSPECTIONS AN AIR CARRIER PERFORMS AFTER PURCHASING A 

CERTIFIED ULD. 

a. New Certified ULDs. When an air carrier purchases new certified ULDs, it should 

perform a first article inspection (see Appendix C) of the ULD received to ensure it conforms to 

type design and is eligible for installation on the air carrier’s airplanes. The equipment 

manufacturer should issue conformity certificates on subsequent deliveries of new ULD 

equipment. 

b. Used Certified ULDs. When an air carrier purchases used certified ULDs, it should 

perform an airworthiness inspection conducted by appropriately trained FAA-certificated airman 

if records are not provided to determine airworthiness of the ULD. Upon completion of the 

inspection, the air carrier issues a serviceable tag verifying the airworthiness of the ULD before 

placing it into service. After the initial inspection, the air carrier should then maintain its own 

maintenance inspection and repair records for the ULD. If the ULD has appropriate records to 

verify its airworthiness, then the air carrier should perform a receiving inspection in accordance 

with its procedures. 

223. PURCHASE OF AN UNCERTIFIED ULD. When purchasing new or used uncertified 

ULDs, the air carrier should: 

a. Obtain the manufacturer’s current CMMs and illustrated parts list, subsequent manual 

revisions, service letters, or SBs. 

b. Verify that the manufacturer establishes clearly defined and tested serviceability limits 

in accordance with IATA, SAE, or ISO standards, or other standard acceptable to the FAA. 

c. Provide a trained, qualified, and authorized person to perform a quality audit of 

manufacturing sites where the ULDs are manufactured and assembled. 

d. Check that the manufacturer designs all ULD equipment to allow venting during 

changes in air pressure, if required. 

e. Check that only Original Equipment Manufacturer (OEM)-approved parts were used 

during manufacturing. 

f. Check that the manufacturer issues spare part conformity certificates. 

g. Perform a first article inspection of the ULD received is performed to ensure its 

airworthiness. 

224. CHECKS TO PERFORM WHEN RECEIVING ANY ULD. An air carrier should 

have a trained, qualified, and authorized person perform a receiving inspection check on all 

ULDs it receives in accordance with the air carrier’s procedures. The receiving acceptance 

check procedures should include a process, instructions, and guidelines to: 

a. Check each ULD before it is put into service. 

Page 14 Par 222 
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b. Review the required documentation for new and repaired items to ensure the item is 

airworthy. 

c. Conduct a visual inspection of the ULD. 

NOTE: FAA-certificated personnel do not need to conduct receiving 

acceptance checks. The air carrier may designate a person to conduct the 

checks, provided he or she is trained, authorized, and qualified. Receiving 

acceptance checks are not used to determine the airworthiness of a ULD. A 

repair vendor or the ULD equipment manufacturer already determined the 

airworthiness of the ULD when it was returned to service. 

225. RESPONSIBILITY FOR ULD MAINTENANCE AND REPAIR. An air carrier is 

responsible for ULD maintenance and repair regardless of whether it is performed internally by 

the air carrier or by a vendor. 

226. MAINTAINING ULD REPAIR RECORDS. An air carrier should have procedures for 

retaining ULD (certified and uncertified) repair records to comply with the regulations. An air 

carrier may maintain its own records, or allow repair vendors to maintain the records provided 

the air carrier can access them upon request within a reasonable period of time. 

227. PROCEDURES FOR MAINTAINING AND REPAIRING ULDs. An air carrier

should have procedures for the maintenance and repair of certified and uncertified ULDs. The 

procedures should be the same for both types of ULDs, except for establishing appropriate 

damage limits and specific repair procedures. The procedures should: 

a. Clearly state the data upon which maintenance and repair are based. 

b. Address transporting damaged ULDs aboard its airplane to a repair station, provided 

they do not pose a hazard to the safety of flight. This would include restraining the ULD as bulk 

cargo if necessary. 

c. Address how frequently the air carrier or repair vendor should check ULD tare weights 

and how it should mark updated tare weights on ULDs. The air carrier should manage control of 

ULD tare weights by documenting them and retaining the documentation in accordance with air 

carrier procedures. 

228. STANDARDS FOR REPAIR OF ULDs. An air carrier should have procedures to 

ensure that: 

a. Personnel are qualified to repair its ULDs. 

b. Repair of its ULDs is done in accordance with its maintenance program. 

c. Parts for ULD repair meet or exceed equipment manufacturer standards and are 

approved by the airplane manufacturer or by the air carrier’s processes using FAA-approved 

data. 

Par 224 Page 15
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d. The appropriate current data is available to repair the ULD, including, but not limited 

to, air carrier maintenance manuals, airplane manufacturer maintenance manuals, SBs, 

Airworthiness Directives, or other FAA-approved data. 

e. The tare weight of each ULD is checked in accordance with the air carrier’s procedures. 

f. The new tare weight is marked on each ULD in accordance with the air carrier’s 

procedures. 

g. The repair of ULDs and associated components or articles is in accordance with 14 CFR 

Part 43, whether the air carrier or a repair vendor performs the repairs. 

h. Provide the air carrier with appropriate repair documentation. 

229. USE OF A REPAIR STATION/VENDOR TO REPAIR ULDs. 

a. An air carrier should conduct audits of the repair stations it uses to ensure they comply 

with its maintenance program requirements. 

b. An air carrier should provide its repair vendors with written authorization to repair its 

ULDs and all necessary data and manuals for repair of its ULDs. 

230. RETURNING A ULD TO SERVICE. An air carrier should have procedures for 

repairing unserviceable ULDs and approving them for return to service. As required by part 43, 

only appropriately trained and FAA-certificated airmen are authorized to return a ULD to 

service. The airmen should return ULD equipment to service under the requirements of the 

applicable CMM or air carrier instructions. FAA-approved repair stations operating under 

14 CFR part 145 should return ULDs to service in accordance with air carrier procedures. 

a. An air carrier may use FAA-approved or -accepted data in place of the requirements of 

the manufacturer’s CMM or an air carrier may choose to strictly follow the manufacturer’s 

maintenance procedures. An air carrier also may choose to use a combination of FAA-approved 

or -accepted data and the manufacturer’s maintenance procedures. Regardless, an air carrier 

should make it clear in its manual system which data is to be used. 

b. An air carrier’s continuing analysis and surveillance system (CASS) should be used to 

verify the performance and effectiveness of its cargo handling system maintenance program and 

provide corrections to any deficiencies discovered in the program.

231. IDENTIFYING OR REVISING DAMAGE LIMITS. It is important that the air carrier 

specify damage limits for ULDs and any related restraint equipment. The air carrier may use the 

damage limits provided by the manufacturer or may develop its own damage limits with FAA 

acceptance. If the air carrier chooses to develop its own damage limits, it should: 

a. Establish a procedure for developing the new damage limits. 

b. Provide the FAA with data to support its new damage limits. 

Page 16 Par 228 
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c. Obtain FAA acceptance before using the new damage limits. 

232. STANDARDIZATION OF DAMAGE LIMITS ACROSS AN AIR CARRIER’S 

FLEET OF AIRPLANES. An air carrier may standardize damage limits across its fleet of 

airplanes. FAA approval is not required if the air carrier applies the most restrictive damage 

limits categorized by the type of ULD in its fleet. An air carrier publishing less restrictive 

damage limits should provide the FAA with engineering data to support its decisions. 

233. EXCEEDING ALLOWABLE DAMAGE LIMITS. A container with damage to the 

shell that exceeds allowable damage limits may be accepted for use by installing an approved net 

over the shell and using it as a pallet/net combination provided it is approved for use in this 

configuration. A reduced weight requirement may be necessary when an air carrier uses this 

procedure. The air carrier should develop procedures for using the damaged ULD with a net. 

234. ESTABLISHING USAGE LIMITS FOR CARGO STRAPS. A cargo strap 

manufacturer may not necessarily provide damage limits. If this information is not provided, an 

air carrier should use the following guidance for a 5,000-pound cargo strap. Do not use if: 

a. A buckle latch mechanism will not lock or stay engaged. This allows the web to slip 

while under tension, or may result in the web binding or being out of alignment; 

b. Attached fittings, hooks, and rings are bent, cracked, broken, or missing; and 

c. Webbing is partially cut or torn, knotted, unraveling, or has loose or missing sewn 

stitches. 

235. ADDITIONAL PROCEDURES FOR CARGO NETS. An air carrier may want to have 

additional procedures for cargo nets such as: 

a. Assigning a unique marking or serial number to nets and placarding that marking or 

number on the nets; 

b. Placarding nets with their damage limits; 

c. Attaching an identification tag to the air carrier’s nets; and 

d. Ensuring proper storage when not in use to prevent damage. 

236. TEMPORARY INSTALLATION OF RESTRAINTS ON A CARGO NET. 

a. An air carrier may temporarily install restraints on a cargo net provided that: 

(1) The temporary restraints are airplane manufacturer or STC-approved. 

(2) The air carrier has a process in the manual system that addresses the use and limits 

of temporary restraints. 

(3) The personnel that install the temporary restraints are trained, qualified, and 

authorized. 

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b. The air carrier may install temporary restraints to address items such as, but not limited 

to: 

(1) Using a bridge strap to bridge cut or otherwise damaged ropes, or missing or 

damaged fittings; 

(2) Installing temporary fittings and hooks to compensate for damaged or missing 

fittings, in accordance with equipment manufacturer or air carrier procedures; and 

(3) Installing net corner lashing lines and supplemental lashing lines. 

237. PERFORMING CHECKS BEFORE USING ULDS OR OTHER CARGO 

RESTRAINT DEVICES. An air carrier should perform an operational check for damage 

before using ULDs (that is, movement or buildup) and other restraint devices, and a final 

serviceability check before loading cargo aboard the airplane.

238. PURPOSE OF OPERATIONAL CHECKS. Operational checks are not intended to 

determine a ULD’s airworthiness. Instead, they are performed to ensure the ULD or other 

restraint devices do not have obvious damage greater than their damage limits. An air carrier 

should not use ULDs or other restraint devices with damage greater than damage limits 

specified. 

239. INDIVIDUALS WHO MAY PERFORM OPERATIONAL CHECKS. FAAcertificated airmen do not have to perform operational checks. Air carriers should train, qualify, 

and authorize personnel to perform serviceability checks. The air carrier procedures should 

identify who performs these checks and when. 

240. ULDs THAT FAIL AN OPERATIONAL CHECK. An air carrier should have a 

procedure for clearly marking or identifying ULDs and other restraint devices that fail 

operational checks. The method for identifying equipment that failed should clearly distinguish 

these items from serviceable equipment so the air carrier or cargo loading vendor does not 

inadvertently place them into service. A procedure should be in place for individuals to report 

damage to the persons responsible for maintaining the ULD. 

NOTE 1: Clerical, data entry, or other errors of omission resulting in the 

misidentification or removal from service of a ULD may be corrected and the 

ULD returned to service, provided the air carrier has a procedure in its manual 

system for identifying and correcting such errors. 

NOTE 2: Operational checks are not intended to be part of an air carrier CMM 

inspection program. 

Section 5. Cargo Weigh Scales 

241. RESPONSIBILITY FOR ENSURING THE WEIGHT OF LOADED CARGO IS 

ACCURATE. An air carrier is responsible for ensuring the weight of cargo loaded aboard its 

airplane is accurate. Scale tolerances established by scale equipment manufacturers or tolerances 

Page 18 Par 236 
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based on FAA-accepted data may be used. The air carrier’s weight and balance program should 

account for allowed tolerances to maintain the certified weight and balance limitations. 

242. ENSURING WEIGH SCALES ARE ACCURATE. An air carrier should have a 

program to ensure the periodic check of the accuracy of scales used for weighing cargo. A 

periodic functional check should be performed using weights that approximate the weight typical 

of the loads usually placed on the air carrier’s airplane. As an alternative, the air carrier should 

use the weight recommended by the scale manufacturer for a periodic functional check (see 

“Periodic functional checks” below). Frequent checks and periodic calibrations are necessary to 

ensure an air carrier accurately weighs the cargo loaded on its airplane (see “Periodic 

calibrations” below). 

243. ENSURING WEIGH SCALES ARE CALIBRATED. An air carrier should conduct 

periodic calibration of scales to ensure they are appropriately serviced and accurate to a known 

standard. Calibration records should show that scales are calibrated in accordance with a 

standard established by the appropriate country, state, or local government regulations, such as 

the standards of the National Institute of Standards and Technology (NIST) or an equivalent 

standard acceptable to the FAA. An air carrier may also use the standards recommended by the 

scale manufacturer. 

NOTE: For more information on the standards provided by NIST, visit NIST’s 

Web site at http://www.nist.gov/. 

244. MAINTAINING RECORDS OF CALIBRATION CHECKS. An air carrier should 

keep a record of its scale calibrations. These records should meet the following criteria: 

a. The records should be in the English language. If the records are not in the English 

language, air carriers should have the records interpreted, when necessary. If the air carrier 

cannot provide an English language interpretation of air carrier records, that air carrier should 

allow those individuals using the scales to inspect the scales and perform a functional check 

onsite to ensure scale accuracy. 

b. The air carrier should establish procedures to maintain the records. 

245. PERFORMING FUNCTIONAL CHECKS ON WEIGH SCALES. 

a. Procedures. An air carrier should have procedures to ensure that scales used for 

weighing cargo undergo a functional check between scale calibrations. A functional check 

should consist of field-testing the scale’s accuracy with a specific item of a known weight. 

b. Frequency. At a minimum, the air carrier should ensure that functional checks are 

performed at the intervals specified in the air carrier’s procedures or the scale manufacturer’s 

recommendations. However, the air carrier also should conduct the functional checks at 

intervals commensurate with the frequency of scale use; that is, conduct functional checks more 

often for scales that are more frequently used. 

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c. Recordkeeping. An air carrier should have a method of recording when functional 

checks are performed. The air carrier should maintain functional check records in accordance 

with accepted procedures. These records should include the following information: 

(1) The identification number of the scale; 

(2) The date and time of the functional check; 

(3) The name or the initials of the person who performed the functional check; 

(4) The applied known weight of the item used for the functional check; 

(5) The weight registered by the scale for the applied known weight; and 

(6) The difference between the applied known weight and the registered weight. 

NOTE: If the registered weight recorded for the item of an applied known

weight is outside the tolerances specified for the scale in the air carrier’s 

procedures, the air carrier should not use the scale until it is inspected and 

calibrated.

246. ITEMS FOR WHICH AN AIR CARRIER SHOULD KNOW THE TARE WEIGHT. 

Authorized loading personnel using equipment such as dollies, slave frames, containers, and 

carts to weigh cargo on a scale should know the tare weight of this equipment so they can 

subtract this weight from the total weight to arrive at the cargo weight. An air carrier should 

determine the tare weight of this equipment by weighing it on a calibrated scale. 

247. REWEIGHING LOADING EQUIPMENT FOR TARE WEIGHT AFTER 

MAINTENANCE, REPAIR, OR MODIFICATION. Immediately following any repair, 

maintenance, or modification of equipment such as dollies, slave frames, containers, and carts, 

the air carrier should provide a new tare weight by reweighing the equipment. Air carriers 

should establish a method to communicate new tare weights to air carrier loading personnel 

before they use the equipment to weigh cargo on a scale. An air carrier may communicate the 

tare weight by stenciling it on the equipment or by providing notices to air carrier loading 

personnel. 

Section 6. Cargo Restraint and Airplane Loading and Unloading 

248. AIR CARRIER PROCEDURES FOR CARGO RESTRAINT AND AIRPLANE 

LOADING AND UNLOADING. 

a. An air carrier should have accepted procedures for ULD buildup, loading and 

unloading, and restraining cargo in its manuals system. The procedures should include the 

bulk loading and unloading of cargo, both compartment restrained and restrained by 

other devices, if the air carrier permits. The procedures should be in accordance with 

the air carrier weight and balance manual and be based on airplane manufacturer, STC, or other 

FAA-approved data. 

Page 20 Par 245 
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b. An air carrier should have specific procedures for all types of cargo restraint devices the 

air carrier is authorized to use (for example, installed nets, the cargo handling system, certified 

ULDs, uncertified ULDs, and other restraints). 

249. AIR CARRIER PROCEDURES ON ULD BUILDUP AND CARGO RESTRAINT. 

An air carrier’s procedures regarding ULD buildup and cargo restraint should address the 

following topics. 

a. ULD CG Limits. The procedures should address how to maintain the longitudinal, 

lateral, and vertical CG limits of a built-up ULD. The air carrier should consider the following 

guidelines when developing the procedures: 

(1) Place sturdier, heavier, and larger cargo pieces on the bottom of the load and evenly

distribute them over the length and width of the pallet base. 

(2) Place smaller, lighter, and fragile cargo pieces on top and evenly distribute them

from the center over the length and width of the ULD. 

(3) Level off the cargo loaded in the ULD when less than full. 

(4) Interlock or overlap small pieces when practical.

NOTE: From Compliance Document for ULD Center of Gravity Control 

on B-727 P-F Aircraft, dated October 2000. 

b. Voided Space in ULD. To minimize voided space within a ULD and between cargo 

pieces, the air carrier should consider using the following: 

(1) Supplemental restraint devices to restrain cargo within a container when less than 

full; and 

(2) Dunnage in voided spaces. 

c. Cargo Contours. The air carrier should have procedures on how to contour cargo 

loads for the airplane’s interior dimensions when using a pallet/net combination, pallet/strap 

combination, or other restraint methods/devices. The air carrier should consider using 

techniques such as contour templates or charts. Also, the air carrier should consider procedures 

for operational conditions in which variance in contouring might occur, for example, when an 

aisle to access hazmats or to ensure the integrity of a particular load is needed. The air carrier 

also should account for height restrictions if required by the airplane’s weight and balance 

manual, supplemental weight and balance manual, or other FAA-approved data. 

NOTE: Unique loading and restraint procedures may apply when handling 

specialized cargo such as animals, outsized cargo, cargo overhangs, uniquely 

shaped cargo, unstable cargo, or cargo unable to be loaded in ULDs or bulk 

compartments. 

Par 248 Page 21
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d. ULD Identification Tags. The procedures should include the use of tags to identify 

ULDs loaded aboard air carrier airplanes, especially when using pallet/net or pallet/strap 

combinations because their identification is not always visible. The air carrier may use 

electronic tagging if it is approved for use by a STC or other FAA-approved means for the 

particular airplane. 

NOTE: Electronic tagging may present a concern about interference with 

onboard avionics equipment. The air carrier should ensure that if it carries 

electronically tagged ULDs, they are FAA-approved for use on the particular 

airplane on which the ULD is loaded. 

e. ULD Weight Limits. The air carrier should include procedures to ensure the weight of 

cargo does not exceed the ULD gross weight or area load limits if stated by the ULD 

manufacturer. 

f. Operational Checks. The procedures should include how to check the condition of 

ULDs and other restraint devices for damage before using them, and how to perform the 

operational checks to ensure any damage does not exceed damage limits. The air carrier should 

base the serviceability checks on the information from the equipment manufacturer, in the STC, 

or other data acceptable to the FAA. 

g. Fastening Container Components. The air carrier’s procedures should address the 

correct method of positive closure and locking of container nets, curtains, and rigid or flexible 

doors after buildup. The air carrier should base these procedures on information provided by the 

container manufacturer, STC holder, or other source with information acceptable to the FAA. 

h. Fastening a Cargo Net to a Pallet. The air carrier’s procedures should address how to 

fasten a cargo net to a pallet properly after buildup. The air carrier should base these procedures 

on information supplied by the pallet/net manufacturer, STC holder, or other source with 

information acceptable to the FAA.

250. AIR CARRIER PROCEDURES ON CARGO LOADING AND UNLOADING. An 

air carrier’s procedures regarding airplane loading and unloading should address the following 

topics: 

a. Sill Guards (If Applicable). The air carrier’s procedures should address the use of sill 

guards and instructions for attaching and detaching them. If an air carrier stows sill guards in the 

airplane when they are not in use, the procedures should include the proper stowage in the 

airplane. 

b. Tail Post (If Applicable). The air carrier’s procedures should address the use of a tail 

post (nonstructural device), if the air carrier requires its use to measure the distance between the 

airplane’s tail section and the ground during loading and unloading. The procedures should 

include instructions on attaching, detaching, and using it. If an air carrier stows the tail post in 

the airplane when it is not in use, the procedures should include the proper stowage in the 

airplane. 

Page 22 Par 249 
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c. Tail Stand (If Applicable). The air carrier’s procedures should address the use of a tail 

stand (structural device), if the air carrier requires its use to prevent the airplane from tipping on 

its tail during loading and unloading. The procedures should include instructions on attaching, 

detaching, and using it.

d. Tail Tipping Avoidance. The air carrier’s procedures should address the methods to 

ensure the airplane will not tip on its tail during loading and unloading (for example, step loading 

and unloading of cargo, or nose gear tethering). 

e. Airplane Doors, Nets, and Smoke Barriers. The air carrier’s procedures should 

address the proper use of cargo compartment and bulkhead doors, installed nets, and smoke 

barriers. 

f. Airplane Floor and ULD Base Load Limits. The air carrier’s procedures should 

address the airplane’s floor load limits (area load or linear-running load limits) if the air carrier 

allows cargo to be loaded directly on the airplane’s floor. The procedures also should address 

floor load limits for a ULD base if the ULD manufacturer has a limit. An air carrier should base 

these procedures on information from the airplane manufacturer, STC weight and balance 

manual or supplement, or other FAA-approved data. In addition, the procedures should address

how to distribute (shore) the weight of cargo having a load bearing weight greater than a floor 

load limit. For more information, see paragraph 9 of this Section. 

g. Airplane Weight Limits. The air carrier’s procedures should address the weight limits 

for airplane cargo positions, floors, zones, and compartments, and measures to ensure the air 

carrier does not exceed them. The air carrier should base these limits on information from the 

airplane manufacturer, STC weight and balance manual or supplements, or other FAA-approved 

data. 

h. Airplane CG Range Limits. The air carrier’s procedures should address the CG range 

limits for the airplane as well as longitudinal, lateral, and vertical CG limits for cargo positions. 

The procedures also should address measures to ensure an air carrier does not exceed these 

limits. The air carrier should base these procedures on information from the airplane 

manufacturer, or STC weight and balance manual or supplements, or other FAA-approved data. 

i. Cargo Access Aisle. The air carrier’s procedures should address a method for creating 

a flightcrew access aisle to cargo requiring access during flight, such as certain hazmats or live 

animals. 

j. Airplane Damage Avoidance. The air carrier’s procedures should address the 

measures to ensure damage does not occur to the cargo handling system, cargo liners, smoke 

detectors, light fixtures, fire retardant flow nozzles, and other similar devices during loading and 

unloading. 

k. Airplane Damage Notification. The air carrier’s procedures should address the 

methods to notify flight crewmembers or authorized maintenance personnel of a damaged, 

missing, or inoperative cargo compartment, cargo handling system, installed net, or smoke 

barrier and related components. These procedures should include a general guideline or list of 

what specific items cargo loaders should report to flight crewmembers or authorized 

Par 250 Page 23
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maintenance personnel, such as holes in the cargo compartment liner, and damaged or missing 

cargo handling system restraints and rollers, and installed nets and smoke barriers. 

l. Cargo Clearance. The air carrier’s procedures should address the minimum clearance 

(distance) requirements between cargo and cargo compartment liners, light fixtures, smoke 

suppression systems, smoke detectors, and other similar devices. 

m. Cargo Handling System. The air carrier’s procedures should address the proper use 

of the airplane’s cargo handling system to restrain ULDs. All cargo handling system restraints 

must be engaged for loaded ULDs and in voided positions. Engaging cargo restraints in voided 

positions is essential to prevent cargo shift resulting from floor lock failure. 

NOTE: Only FAA-certificated airmen may adjust cargo handling system 

components by physical removal and reinstallation. However, if adjustment or 

repositioning of a component is part of the operational instructions of the cargo 

handling system, trained, qualified, and authorized loading personnel may 

accomplish the adjustment. 

n. Bulk Loaded Cargo. The air carrier’s procedures should address the measures to 

ensure it properly loads bulk cargo in cargo compartments and pods authorized for bulk cargo. 

The air carrier should not bulk load cargo in a cargo compartment or pod unless the airplane 

manufacturer’s weight and balance manual or STC authorizes it and it is included in the air 

carrier manual system. If the airplane manufacturer’s weight and balance manual or STC does 

not contain sufficiently detailed guidance for bulk loading cargo, the air carrier should establish 

procedures to ensure the safety of flight that address: 

(1) Cargo clearance. The minimum clearance (distance) requirements between cargo 

and light fixtures, smoke detectors, and other similar devices. 

(2) Load distribution. Evenly distributing (spreading) the cargo within compartments 

and pods over their length, width, and height. 

(3) Airplane nets. The proper use of installed nets. 

(4) Airplane smoke barriers. The proper use of installed smoke barriers between 

cargo and flight crewmembers and passengers. 

o. Special Cargo Loads. The air carrier’s procedures should address that special cargo 

loads may require special handling or restraint with restraint devices other than a ULD. These 

loads may require supplemental or primary restraints with straps or other restraint devices. See 

the following sections on primary and supplemental restraints other than ULDs. The air carrier 

should consider establishing procedures for the following types of special cargo loads, based on 

procedures approved for the airplane manufacturer, STC holder, or procedures developed by 

other persons and FAA-approved: 

(1) Rigid cargo; 

(2) Frangible cargo; 

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(3) Sharp cargo; 

(4) Oversized or overhang cargo; 

(5) Reels, spools, or pipes; 

(6) Motor vehicles and other wheeled cargo; 

(7) Human remains; 

(8) Foodstuff, feed, and postal mail; 

(9) Live animals; and 

(10) Dangerous goods. 

p. Small Live Animals. The air carrier’s procedures should address the carriage of 

animals such as mice, rats, dogs, and cats typically shipped in self-contained boxes or containers 

and typically loaded with other cargo in bulk compartments and ULDs. The procedures should 

address measures to: 

(1) Reduce the risk of animals escaping their containers while in the airplane. 

(2) Identify animals that have escaped from their containers in the airplane.

(3) Remove escaped animals from the airplane. 

q. Large Live Animals. The air carrier’s procedures should address the carriage of 

animals such as horses and cattle typically shipped in special containers, stalls, or penning 

systems that are STC-approved or approved by other FAA means. The procedures should 

address measures to: 

(1) Verify the special containers, stalls, or penning systems are approved for 

the airplane.

(2) Ensure special containers, stalls, or penning systems are properly installed in the 

airplane. 

(3) Protect the airplane from damage by animal waste (urine or solid waste).

(4) Manage out-of-control animals in the airplane. 

(5) Remove animal waste from the airplane. 

NOTE 1: Under 14 CFR part 382, the Department of Transportation 

distinguishes between service animals, such as seeing-eye dogs, and all other 

animals kept as cargo, such as pets. Under part 382, an animal that a 

passenger can properly identify as a service animal must be permitted to 

accompany the passenger at the passenger’s seat. Treat animals not 

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classified as service animals under part 382 as pets and handle them as a 

special cargo load as discussed above. 

NOTE 2: Under the revised 14 CFR part 119, 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. For this AC, 

“live animals” refers to all animals transported as cargo, regardless of 

whether they are kept as pets as defined in part 119. The air carrier should, 

however, be aware of the new incident reporting requirements of part 119, 

section 119.72. 

251. USE OF CARGO RESTRAINT DEVICES OTHER THAN ULDs AS PRIMARY 

RESTRAINT DEVICES. An air carrier may use other restraint devices as the primary restraint 

of cargo to a pallet or airplane floor seat track or rings if it is authorized by the airplane

manufacturer weight and balance manual and/or STC supplementary weight and balance manual, 

or other FAA-approved means. The approved document also should include serviceability limits 

and operational and repair procedures, and meet the flammability requirements of part 25. 

252. PROCEDURES FOR USE OF DEVICES OTHER THAN ULDs. If an air carrier 

allows the use of straps and other restraint devices as primary cargo restraints, it should have 

procedures for their use. These procedures should be based on the information provided by the 

airplane manufacturer, STC holder, or by other sources acceptable to the FAA, such as SAE 

standards, IATA standards, or the standards used by the U.S. Armed Services. These procedures 

should address: 

a. Installing straps or other restraint devices to airplane floor tracks, rings, or hardware. 

An air carrier should recognize in its procedures that there might be reduced load limits and 

minimum separation requirements between tiedown points if using the same airplane floor track, 

ring, or hardware for multiple tiedowns. 

NOTE: Avoidance of minimum separation requirements may over stress the 

airplane floor attachments. 

b. Using and attaching straps or other restraint devices to the pallet base tiedown track 

(commercial pallets) and rings (military pallets).

c. Installing straps or other restraint device to the pallet base tiedown track (commercial 

pallets) and rings (military pallets) in accordance with ULD manufacturer requirements, if 

applicable. 

NOTE: The air carrier 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 air carrier should 

engage the lock mechanism so the strap is taut. However, the strap should not 

be overtightened. Air carriers should address minimum tiedown separation 

requirements for pallets because most airplane manufacturers do not address 

the use of primary or supplementary tiedowns in their manuals. 

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d. Calculating the number of other restraint devices required for a given cargo load based 

on the restraint criteria provided in the airplane’s weight and balance manual or in other FAAapproved data.

e. Calculating the number of straps or restraint devices required should be based on the 

device’s rated strength and limiting factors that may be specified in the airplane’s weight and 

balance manual or its supplement. The weight and balance manual or its supplement may 

require strength reductions of the strap or other restraint devices based on limiting factors such as 

airplane 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. 

f. Properly arranging straps or other restraint devices around the cargo or attached to the 

cargo. The instructions should include how to correctly clinch adjacent net panels together with 

the net corner lashing rope and secure the end of the rope to the net panel to prevent 

disengagement. 

g. The requirement to restrain cargo in accordance with the airplane’s ultimate load 

conditions described by the airplane weight and balance manual or its supplement. The air 

carrier should consider that these devices have to provide restraint in the forward, aft, vertical, 

and side directions. 

NOTE: The FAA does not recommend that an air carrier 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 should be loaded singly on a pallet. 

253. USE OF SUPPLEMENTAL CARGO RESTRAINT DEVICES. An air carrier may use 

other restraint devices to supplement the primary restraint of cargo to a pallet or airplane floor 

provided the supplemental restraints do not prevent the primary restraints from restraining the 

cargo as designed and applied. 

254. AIR CARRIER PROCEDURES FOR SUPPLEMENTAL CARGO RESTRAINT 

DEVICES. If the use of other restraint devices as supplemental cargo restraints is allowed, an 

air carrier should have procedures for their use. These procedures should be based on the 

information provided by the airplane manufacturer, STC holder, or by other sources acceptable 

to the FAA, such as SAE, IATA, or the standards used by the U.S. Armed Services. These 

procedures should address: 

a. Using and attaching other restraint devices to the airplane’s installed seat track (tiedown 

track) and/or tiedown rings; 

b. Using and attaching other restraint devices to the pallet base tiedown track (commercial 

pallets) and rings (military pallets); and 

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c. Properly arranging other restraint devices around the cargo or attached to the cargo. 

255. PROCEDURES FOR CARGO SHORING. Airplane floors and some pallet bases have 

a load bearing weight limit (also called a floor load limit). Shoring is a technique used to 

distribute the weight of a cargo piece over a greater area than its load bearing area (also called a 

footprint or contact area). Cargo pieces with a load bearing weight greater than a load bearing 

weight limit require shoring. The air carrier should have procedures that address the: 

a. Materials (for example, wood planks and plywood) acceptable for use in shoring; 

b. Calculations or methods for determining the amount and thickness of shoring materials; 

and 

c. Methods for applying shoring material to the cargo piece. 

256. BLOCKING AND BRACING TECHNIQUES. An air carrier may need to stabilize 

some cargo pieces (for example, large cable reels, motor vehicles and other wheeled cargo, and 

odd-shaped cargo pieces) before applying cargo restraints (nets, straps, and other restraint 

devices). The air carrier should use blocking and bracing techniques to stabilize such cargo 

pieces. The air carrier’s procedures should address the: 

a. Materials (for example, wood planks and plywood) acceptable for blocking and bracing; 

b. Calculations or methods for determining the amount and thickness of blocking and 

bracing materials; and

c. Methods for applying blocking and bracing materials to the cargo piece.

257. CARGO LOADING PROCEDURES FOR COMBI-CONFIGURED AIRPLANES. 

Airplanes configured for carrying passengers and cargo on any deck that contains both cargo and 

passengers (combi-configured airplanes) may require special cargo loading procedures. The 

air carrier should have procedures to load such airplanes. These special procedures should be 

based on the requirements established by the airplane manufacturer, STC holder, or other FAAapproved data. 

258. USING VENDORS (EXCLUDING MILITARY) TO INTERLINE OR BUILD UP 

ULDS. The FAA recognizes that it is common practice for an air carrier, either foreign and/or 

domestic, to interline built-up ULDs (see Appendix C). The originating air carrier’s employees, 

forwarders, contractors, and customers may have built up interlined ULDs. The FAA also 

recognizes it is common practice for an air carrier’s foreign and domestic forwarders, 

contractors, and customers to build up ULDs and perform other services, such as airplane 

loading and unloading, and handling. The use of third parties reduces the need for the air carrier 

to employ loading personnel or to contract directly for these services at a particular location. 

259. AIR CARRIER PROGRAM FOR VENDORS (EXCLUDING MILITARY) TO USE 

IN ULD BUILDUP OR LOADING. Given that it is common practice for an air carrier to carry 

cargo loads that vendors have built up or loaded, an air carrier should have a program that 

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ensures vendors perform cargo buildup and loading in accordance with the air carrier’s 

procedures. Under such a program, an air carrier should have procedures to: 

a. Train vendor employees, 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 air carrier training program and procedures. 

b. Designate a trained, qualified, and authorized person to oversee the vendor services to 

ensure the vendor performs the services in accordance with the air carrier procedures. 

c. Audit vendors for compliance with air carrier procedures and training programs. 

NOTE: An air carrier accepts full responsibility to ensure vendor employees 

are sufficiently trained and qualified and adhere to air carrier procedures. 

Section 7. Load Supervision, Load Verification, and 

Air Carrier Audits 

260. SUPERVISING CARGO LOADING. An air carrier should designate a trained, 

qualified, and authorized person or persons, such as an employee or vendor, as a load supervisor 

to ensure: 

a. All cargo is properly built up, weighed, and restrained. 

b. Average baggage weights are accounted for (Ref. AC 120-27). 

c. ULDs and other restraint devices are in serviceable condition and properly used. 

d. The airplane is correctly loaded and unloaded in accordance with its procedures. 

e. All documents, such as load plans or load verification forms, are accurate and properly 

completed before submission to flight crewmembers or other authorized, trained, and qualified 

personnel. 

f. Flight crewmembers or authorized maintenance personnel are notified of damaged, 

missing, or inoperative cargo compartment, cargo handling system, installed cargo net, or 

smoke barrier components. 

261. HOW TO VERIFY CARGO WAS LOADED PROPERLY. Air carriers should 

designate personnel to provide information about how the airplane was loaded to the pilot in 

command, or to air carrier’s authorized, trained, and qualified loading personnel. The designated 

loading personnel may provide loading information on one or more forms, and may present it in 

hardcopy or electronic form. They may include additional information and certifications based 

on air carrier-specific requirements, such as carrying hazmats or live animals. Air carriers 

should note that this information does not impact the requirements for a load manifest required 

under section 121.665 of the regulations. 

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262. INFORMATION NEEDED TO VERIFY CARGO IS LOADED PROPERLY. The 

information submitted to the pilot in command or the air carrier’s authorized, trained, and 

qualified loading personnel should include: 

a. The flight date. 

b. The flight number. 

c. The airplane tail number. 

d. The origin station of the flight leg. 

e. The destination of the flight leg. 

f. For cargo carried in ULDs, the ULD numbers. 

g. The weight of each ULD loaded aboard the airplane. 

h. The weight of the bulk cargo, by compartment or position, as applicable. 

i. The location of special cargo loads. 

j. A certification statement verifying that: 

(1) All ULD locks are up. 

(2) All installed nets or smoke barriers are properly attached. 

(3) All ULDs loaded are in an operational condition. 

(4) All cargo was loaded in accordance with air carrier cargo loading procedures. 

(5) Tail stand or post was removed, as applicable. 

(6) All cargo was loaded aboard the airplane as depicted on the load plan form, 

verification form, or other similar documents. 

k. The signature, or electronic equivalent, of the load supervisor or other authorized, 

trained, and qualified loading personnel. 

263. MAINTAINING RECORDS OF CARGO LOADING VERIFICATION 

INFORMATION. Air carriers must have procedures to retain a completed and signed copy, or 

electronic equivalent, of the document(s) containing the information listed in paragraph 3 above 

with the load manifest in accordance with sections 121.695 or 121.697 of the regulations, as 

applicable. 

264. PERFORMING CARGO BUILDUP OR LOADING AUDITS. Air carriers should 

have a program acceptable to the FAA for periodic cargo buildup and loading audits. This 

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program should include audits of sufficient scope and frequency to ensure that loading personnel 

are following air carrier cargo loading procedures. 

Section 8. Training 

265. AIR CARGO TRAINING PROGRAMS. Air carriers should develop an air cargo 

training program. The employee training should, at a minimum, explain how the individuals are 

to handle their functions according to the air carrier’s procedures. 

266. TRAINING PROGRAM COMPONENTS. The air carrier’s training program should 

include: 

a. A curriculum acceptable to the FAA. 

b. Procedures for maintaining training records in accordance with the air carrier’s policy 

or applicable regulations. 

c. Recurrent training requirements and intervals. 

d. A description of the training program elements. The program may consist of one or 

more of the following elements: 

(1) Classroom sessions; 

(2) On-the-job training; 

(3) Computer-based training; or 

(4) Other training methodologies air carriers consider appropriate. 

e. A periodic review and update of the program. 

f. Proper identification of the individuals authorized to provide the training. 

g. General awareness and familiarization with hazmats training.

267. IDENTIFYING INDIVIDUALS WHO NEED TRAINING. An air carrier should have 

procedures to properly identify those individuals who need training. An air carrier should 

provide training to its own loading personnel as well as vendor loading personnel. These 

individuals typically include: 

a. Airplane loading personnel; 

b. Maintenance personnel; 

c. Flight crewmembers; 

d. Dispatchers; 

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e. Purchasing agents; 

f. Receiving personnel; 

g. Freight forwarders and customers; and 

h. Cargo sales employees and general cargo sales agents. 

268. INDIVIDUALS WHO SHOULD RECEIVE ULD TRAINING. All air carrier and 

vendor personnel involved in the loading of cargo should receive ULD training. 

269. ELEMENTS THE ULD TRAINING PROGRAM SHOULD CONTAIN. The air 

carrier should develop a training program that: 

a. Ensures all loading personnel are aware that each ULD has set damage limits and are 

aware of individual ULD damage limits. 

b. Ensures that if a ULD’s damage limits are modified, the air carrier notifies all 

appropriate loading personnel and the training program is modified to reflect the new limits. 

c. Includes ULD identification. This should include a review of unique ULDs and identify 

the risks of loading a ULD that is not authorized for loading aboard the airplane. 

d. Includes recurrent training for all loading personnel involved in ULD buildup. Air 

carriers should determine the time and type of recurrent training appropriate to type of operation. 

Air carriers should require requalification and reauthorization training if loading personnel 

involved in ULD buildup are no longer considered properly trained, qualified, and authorized. 

270. STANDARDS TO WHICH AIRPLANE AND GROUND HANDLERS SHOULD BE 

TRAINED. An air carrier should have procedures to train all its airplane, ground handlers and 

contract vendors to its standards. 

271. USE OF OUTSIDE COMPANIES TO PROVIDE TRAINING. An air carrier may 

designate an individual employed by a third-party airplane or ground handling company or 

freight forwarder who is authorized to train that company’s employees. The air carrier should 

have procedures to approve the program.

272. TRAINING VENDORS. An air carrier should have procedures in place to ensure each 

repair vendor trains its maintenance personnel on the air carrier’s ULD repair procedures. The 

air carrier’s procedures should include an audit of the repair vendor’s training program. 

273. OTHER TRAINING FOR LOADING PERSONNEL. An air carrier should have 

procedures to ensure it trains its loading personnel in accident/incident reporting procedures. 

274. DETERMINING WHICH AIR CARRIER EMPLOYEES SHOULD RECEIVE 

WEIGHT AND BALANCE TRAINING. All air carrier loading personnel involved with 

weight and balance calculations for airplane and CG control, and all air carrier loading personnel 

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involved in cargo buildup and cargo loading should receive general awareness training on weight 

and balance principles. 

275. TRAINING TOPICS FOR LOADING PERSONNEL AWARENESS WEIGHT AND 

BALANCE TRAINING. The air carrier’s awareness training should be at a general subject 

matter level and include the following: 

a. Familiarization of varying airplane weights based on the manufacturer’s requirements;

b. The importance of conforming to and applying airplane manufacturer, TC holder, 

STC holder, or other FAA-approved requirements and zone or compartment limits; 

c. The importance of accurate weight and balance calculations; and 

d. The importance of proper communication among various personnel. 

276. TRAINING TOPICS FOR PERSONNEL OR CONTRACTORS INVOLVED WITH 

WEIGHT AND BALANCE AND CG CALCULATIONS. The air carrier’s training course 

for personnel or contractors involved with weight and balance and CG calculations should 

include, at a minimum, the following: 

a. Conforming and applying weight limitations by position, zone, or compartment of an 

airplane in accordance with the airplane manufacturer requirements; 

b. Determining CG limits for the airplane; 

c. Loading the airplane in accordance with CG limits; 

d. Calculating weight and balance and CG in accordance with air carrier procedures to 

include automated or manual calculation systems; 

e. Notifying the flightcrew of the weight and balance of the airplane; 

f. Accounting for the effect of weights of crews, supernumeraries, and baggage; and 

g. Communicating weight and balance or CG issues to personnel involved with cargo 

loading. 

277. DETERMINING WHICH AIR CARRIER EMPLOYEES SHOULD RECEIVE 

CARGO HANDLING SYSTEM TRAINING. An air carrier should provide cargo handling 

system training to its maintenance personnel, load personnel, and managers. 

278. CARGO HANDLING SYSTEM TRAINING TOPICS. Air carriers should have a 

program that provides adequate instruction to maintenance personnel who perform cargo repair 

duties. Personnel who supervise loading should have sufficient training to ensure passenger 

baggage and cargo is loaded and restrained in accordance with procedures. Air carriers should 

qualify all personnel including management under a training program that includes, at a 

minimum, the following subject matter in the training process for load managers and supervisors: 

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a. Loading procedures and their effect on airplane performance consequences; 

b. Potential hazards to flight caused by improper loading; 

c. Airplane cargo handling system procedures and serviceability, including accounting for 

damaged or missing restraint devices; and 

d. The purpose and use of various restraint systems authorized for each airplane type the 

air carrier operates. 

279. TRAINING FOR PERSONS RESPONSIBLE FOR INSPECTION AND REPAIR OF 

ULDS AND CARGO HANDLING SYSTEMS. Persons responsible for the inspection and 

repair of ULDs and cargo handling systems should undergo training that includes the following: 

a. Company policies and procedures for the inspection and repair of ULDs and cargo 

handling systems; 

b. Receiving inspection requirements for ULDs before acceptance for use; and 

c. MEL and configuration deviation list procedures related to the removal or deferral of 

restraint components from the airplane. 

280. INFORMATION THE AIR CARRIER SHOULD PROVIDE TO ITS 

FLIGHTCREW ABOUT AIR CARGO. Applicable to the type of operator, an air carrier’s 

flight operations training should adequately inform the flightcrew, at a minimum, of the 

following: 

a. Potential hazards to flight caused by improper loading; 

b. Procedures used to ensure the airplane weight is correct; 

c. Procedures to report unserviceable ULDs; 

d. Loading and weight limitations for the removal or deferral of cargo restraint 

components; 

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

f. Special requirements when loading and restraining unusual loads; and 

g. General awareness and familiarization hazmats training. 

281. REVIEWING THE AIR CARGO TRAINING PROGRAM IN AIR CARRIER 

SAFETY MANAGEMENT PROGRAMS. An air carrier’s continuing analysis and 

surveillance system (CASS) should include an evaluation of the air carrier’s cargo training 

program performance and effectiveness. The air carrier also may use an internal evaluation 

program to review its training program. The air carrier should ensure it has procedures to 

periodically review the training program and make changes as necessary. 

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282. RETAINING TRAINING RECORDS. 

a. An air carrier should determine the appropriate time for retaining its training records, in 

accordance with the type of operation, frequency of recurrent training, and accepted training 

program. The air carrier should have procedures that require it to keep such records. 

b. If an air carrier conducts the training, the air carrier should maintain the records. If the 

vendor conducts the training, the vendor should maintain the records if the air carrier approves. 

The air carrier or the vendor may maintain the training records in electronic form or hardcopy. 

283. TRAINING RECORD CONTENTS. At a minimum, an air carrier’s training records

should contain the following information: 

a. The name of the person trained; 

b. The initial training date and most recent recurrent training date; 

c. A description, copy, or the location of training material used; 

d. The name and location of the person that provided the training; and 

e. Certification that the person was tested and successfully completed training. 

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CHAPTER 3. CERTIFICATION 

Section 1. General 

300. PURPOSE. This chapter provides guidance for demonstrating compliance with 14 CFR 

requirements pertaining to the certification and continued airworthiness of transport category 

airplanes (for example, combi, passenger, all-cargo, commuter, regional) used for the carriage of 

cargo, including cargo handling systems, ULDs, and other primary restraints. 

301. INFORMATION PROVIDED. This chapter includes guidance on data and information 

for the conversion of passenger airplane to freighters or combi service and content of applicable 

information in relevant weight and balance documents. 

Section 2. Airplane Configuration 

302. CERTIFICATION REQUIREMENTS FOR CARGO-CARRYING AIRPLANES. 

An airplane designed to carry cargo, whether it is an all-cargo airplane, combination 

cargo-passenger airplane, or passenger airplane, has special access requirements, structural 

modifications to accommodate unique loading conditions, restraint devices, appliances, and 

measures to ensure the security of cargo throughout the operational envelope of the airplane. If 

an air carrier incorporates any of these design features or modifications into the airplane design, 

it needs to meet the certification requirements of the appropriate airworthiness standards 

(14 CFR part 25 or CAR 4b, as applicable), and have documents providing ICA. Appendix H 

provides an ICA checklist. 

303. DIFFERENCES BETWEEN A BULK LOAD AND NONBULK LOAD CARGO 

COMPARTMENT. A cargo compartment will be categorized or defined as bulk load or 

nonbulk load. 

a. Bulk Load. An airplane with a bulk load cargo compartment should have provisions 

inherent in the design and construction that prevent bulk cargo from: 

(1) Shifting and damaging airplane systems and structures, and 

(2) Shifting to the extent that the airplane CG exceeds the certified limits. The 

provisions inherent in the design include the requirement that the construction of the airplane 

ensures that unrestrained cargo, when subjected to the flight, ground, and landing loads of the 

appropriate airworthiness standards, cannot damage airplane systems and structure by impact. 

b. Nonbulk Load. An airplane’s systems and structures are protected with a nonbulk load 

cargo compartment by ULDs and the cargo restraint system. The ULDs and other load restraints 

will ensure that the cargo structural loads are only applied to the airplane through the 

ULD-airplane interface of the cargo restraint system. The ULDs and cargo restraint system must 

meet the airplane certification requirements with regard to the retention of cargo (e.g., TSOC90c, which provides certification requirements for the specification of the ULDs). 

Par 300 Page 37
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304. FREIGHTER CONVERSIONS. The FAA has issued STCs to convert the configuration 

of certain transport-category airplanes from passenger carrying to cargo carrying. These 

freighter conversions entail modifications such as: 

a. Removing the passenger interior; 

b. Modifying the structure to accommodate changes in structural loading resulting from

the carriage of cargo and the installation of cargo restraint systems; 

c. Installing a cargo interior; 

d. Installing main deck cargo doors; and 

e. Altering hydraulic, pneumatic, and electrical systems. 

305. FEATURES OF CARGO RESTRAINT SYSTEMS. 

a. The cargo restraint system installed in an airplane is a critical design feature. The cargo 

restraint system is the primary means of ensuring the cargo loads introduced into the airplane 

structure are properly distributed, and all items of mass are restrained from movement or from

damaging critical airplane systems when subjected to flight, landing, and ground operational 

loads, and from the loads resulting from emergency landing conditions. The cargo restraint 

system may include barriers, ULDs, nets, straps, chains, tiedowns, and floor locks. A cargo 

restraint system must have sufficient strength under the certification requirements to restrain the 

cargo safely and must ensure the cargo will not shift and block or reduce access to emergency 

exits, obstruct the flow of required fire retardants, and interfere with other design features, such 

as flight controls, that are critical to the safety of flight. The minimum requirements are defined 

in the appropriate Airworthiness Standards. An air carrier should determine whether the 

protection of passengers and crew from shifting cargo during emergency landing conditions is to 

be accomplished by the cargo restraint system or provided by a barrier. This decision affects the 

airplane’s structural requirements, ULDs, and cargo restraint system. Guidance and restraint 

system configurations are provided in AC 25-5, Installation Approval on Transport Category 

Airplanes of Cargo Unit Load Devices Approved as Meeting the Criteria in NAS 3610; 

AC 25-18, Transport Category Airplanes Modified for Cargo Service; and TSO-C90c. 

b. The cargo restraint system and the devices used to restrain the cargo to the airplane 

structure are appliances.

306. ENSURING THE INTEGRITY OF A CARGO RESTRAINT SYSTEM. Even though 

the original design of a cargo restraint system may be in compliance with the applicable 

certification regulations, the installation of the system may not be adequately defined. 

Inspections of some airplanes have revealed wrong part number locks installed, missing locks, 

damaged equipment needing repair or replacement, and modifications made to the cargo restraint 

system that appeared to compromise its integrity. To maintain the integrity of the cargo restraint 

system, the air carrier should ensure that replacement parts are approved for the cargo restraint 

system components on which they are installed. It is important also to note that the operating 

environment for cargo restraint systems is generally more severe than what most airplane 

structures ensure. Many traditional marking methods are not permanent in this environment. To 

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ensure the integrity of its system, an air carrier should ensure that its cargo restraint system

markings are permanent. 

307. FIRE PROTECTION DESIGN FEATURES OF AIRPLANES THAT ARE 

ESSENTIAL TO OPERATIONAL SAFETY. While AC 25-18 discusses the various classes 

of cargo compartments and associated fire protection requirements, for the purpose of this AC, it 

is important to emphasize the dependence on the continued airworthiness of certain FAAapproved design features in cargo compartments that are essential to operational safety. For 

class A and B compartments, ensuring accessibility by a crewmember and availability of an 

approved fire extinguisher is critical to safety in the event of hazardous quantities of smoke or 

fire. For the class C and E compartments, the functions of specific design features must be 

preserved to ensure operational safety. The integrity of the cargo compartment liner, as it often 

serves the dual purpose of fire and smoke containment while providing ventilation paths for 

decompression events, must be maintained and the decompression features must be 

uncompromised. Smoke detectors, and for class C compartments, fire suppression equipment, 

are the essential equipment required for operational safety. 

308. DEFINITION OF A SUPERNUMERARY. Section 121.583 allows 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. 

309. INSTALLING ACCOMMODATIONS FOR SUPERNUMERARIES ON 

AIRPLANES CERTIFICATED UNDER PART 25. 

a. Part 25 does not contain provisions similar to part 121 for installing accommodations 

for supernumeraries. Therefore, a TC holder or an air carrier must petition for and receive an 

exemption under 14 CFR part 11 from the sections of part 25 to install accommodations for 

supernumeraries. The FAA reviews each petition for exemption on its own merits. The 

enhanced capabilities of supernumeraries over passengers allows the FAA to issue an exemption 

in certain instances from selected type design requirements normally imposed for the safety of

passengers. In all cases, however, the desired result is the retention of all passenger safety 

features to the maximum extent reasonable, when all factors are considered, and an overall level 

of safety for supernumeraries comparable to that afforded to passengers. Under part 11, the FAA 

grants an exemption if it finds the exemption is in the public interest and will provide a level of 

safety equivalent to that provided under the regulations. 

b. The FAA has granted exemptions from part 25 to allow air carriers to install 

accommodations for supernumeraries. In addition to persons necessary for the safe conduct of 

the flight (for example, large animal handlers), exemptions have been granted for the 

transportation of personnel. The exemptions usually involve only a few supernumeraries and the 

accommodations are located immediately aft of the flight deck, which is consistent with the 

intent of section 121.583. In granting the exemptions, the FAA had concerns with allowing 

accommodations for supernumeraries outside the flight deck. The FAA wants exemption 

holders to: 

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(1) Provide a suitable means for preventing smoke penetration into this occupied area. 

(2) Find each supernumerary physically fit. 

(3) Brief each supernumerary on emergency equipment and procedures. 

(4) Ensure each supernumerary’s willingness to use the emergency equipment and 

means of emergency egress provided. 

(5) Comply with any other requirements of the exemption. 

c. The FAA may have additional concerns based on the particular airplane configuration 

or other features and may require an exemption holder to provide palletized flightcrew rest 

modules and access to the cargo compartment to care for live animals. 

310. MODIFICATIONS AND ALTERATIONS THAT COULD IMPACT WEIGHT AND 

BALANCE. While the impact of a modification or alteration may be evident with many 

changes to weight and balance, the impact of some modifications are not readily evident, for 

example: 

a. A modification to incorporate a winglet may change the cargo loading limitation over 

the wing box. 

b. The change in zero fuel weight may alter airplane fore and aft CG limits. 

c. The conversion of class D cargo compartments to class C heightens the concern of the 

potential for damage to certain design features in the class C compartment intended to sense 

smoke and discharge a fire retardant when necessary. 

d. The addition of an auxiliary fuel tank depending on its installation may or may not 

change the zonal payload weight limits on the structure above the tank. 

311. DESIGN ELEMENTS THAT COULD AFFECT THE CARGO LOCATION. The 

cargo airplane design should accommodate expected uncertainties in cargo center of mass 

location normally associated with operational accuracies and tolerances. The effect on structural 

loads resulting from the expected variations in cargo CG location expected in operation must be 

considered in computing cargo restraint system and cargo deck loads. Unless the CG of the 

cargo is actually measured, the assumed location of cargo CG is based on the envelope that is 

achieved in operation. This expected variation should be accommodated in the design and is 

normally identified as a CG position loading limitation on the airplane. These limitations are 

normally selected so that they can be achieved by the application of loading procedures. Cargo 

loading procedures for bulk and nonbulk (e.g., contained in a ULD) should be reviewed to ensure 

the cargo CG is within the assumed envelope to avoid safety issues with the cargo restraint 

system and the affected airplane structure. 

312. DEFINITION OF ICAs. ICAs are a set of instructions as referenced in part 21, 

section 21.50 and part 25, section 25.1529 of the regulations that provide information on how to 

properly maintain a product in an airworthy condition, including any inspections or other 

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procedures, as necessary, to prevent catastrophic failure of the product. Without acceptable 

ICAs, a product cannot be maintained in an airworthy condition. Appendix G provides 

additional information on the scope of the ICA to be considered as a function of the original 

design and/or modifications to a transport airplane. 

313. DESIGN APPROVAL PROJECTS THAT REQUIRE ICAs. In accordance with 

section 21.50(b), all design approval applicants must submit an ICA as part of the type design for 

approval. 

314. DESIGN APPROVALS. A design approval is any approved change or amendment of the 

type design granted by the FAA or its designees that defines or alters the approved configuration 

of an airplane, airplane engine, propeller, part, or appliance. The following are classified as 

design approvals and are subject to the requirements of section 21.50(b): 

a. TCs. 

b. Amended TCs. 

c. STCs. 

d. Amended STCs. 

e. PMAs. 

f. TSO authorizations. 

g. Major repairs and alterations approved by FAA Form 337. 

Section 3. Unit Load Devices (ULD) 

315. CLASSIFICATION OF ULDS. While ULDs (that is, containers or pallets/net 

combinations) are part of the cargo restraint system, they deserve some special emphasis 

regarding associated issues. Apart from obtaining an STC for the design approval for a ULD, 

TSO-C90 provides the certification requirements for the specification of the ULD by reference to 

National Aerospace Standard (NAS) 3610, Cargo Unit Load Devices. This specification 

provides a formal means for classification of ULDs for which certain strength capabilities have 

been demonstrated. This does not, however, approve the installation or use of the ULD in an 

airplane where the protection of the airplane’s systems and structure depends upon the integrity 

of the ULD. Implicit in the classification of a ULD is the vertical restraint configuration used to 

establish the ULD type and strength capabilities. As appropriate to the type design, the 

specification of which ULDs are compatible with the particular airplane should be identified in 

the airplane weight and balance or cargo loading document. This is the primary means for 

ensuring the proper ULDs are used in the operation of the airplane. 

316. USING QUALIFIED NETS AND STRAPS. 

a. Net and pallet combinations are defined as ULDs by NAS 3610. NAS 3610 also 

defines load capability for particular net and pallet combinations. If nets other than those 

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approved for use with particular pallets under TSO-C90 are used to restrain cargo on pallets, they 

must be properly qualified and approved regarding the type of cargo being restrained and the 

effects of shoring the payload on the pallet. If approved for use, the arrangement and the number 

of straps and their attachment to airplane structure should also be qualified in the OEM reference 

documents. The strength capability of tiedown hardware should be provided along with any 

limitations on use or acceptable configuration. Failure by the OEM to include sufficient 

information for the proper use of nets and straps may impose the burden of obtaining approval 

for use on the operator and may result in a failure by an air carrier to ensure proper restraint of 

the cargo and a possible unsafe condition. 

b. Some approved cargo restraint systems permit the use of tiedown straps as a primary 

restraint means. These systems generally provide the instructions for determining the quantity 

and arrangement of straps required to properly restrain the cargo. In many cases the strap 

specification provided by the OEM may be provided only as a required strap rating, for example, 

“5,000-Pound Rated Straps.” In this situation, the operator is responsible for obtaining FAA 

approval for the particular straps that it is using. The operator should have procedures for 

selecting or defining straps that meet the requirements of the approved cargo restraint system, 

ensuring that the purchased or manufactured straps meet the OEM requirements, and have 

procedures in place that ensure the continued airworthiness of the straps. The straps approved 

for use by the operator should be uniquely identified (i.e., manufacturer part number) in the 

operator’s operating manuals. 

c. With cargo restraint systems that permit the use of tiedown straps as a primary means of 

restraint, typically the approval is for tiedown to the airplane’s structure, through installed tracks 

and fittings. These systems do not generally address the use of straps to restrain cargo to pallets, 

nor does approval to TSO-C90 standards address this issue. If an operator does wish to use 

straps as a primary means of restraint to a TSO-C90 pallet, the FAA must approve this. In 

obtaining approval, the operator must provide the data necessary to demonstrate compliance with 

the appropriate regulations. This would include, but is not limited to: 

(1) Establishing strap rating requirements. 

(2) Providing a method to determine the appropriate quantity of straps and their 

arrangement. In determining this, it must be demonstrated that the orientation of the straps 

secures the load for all loading conditions and that the loads in the straps do not exceed the strap 

rating, nor do the strap loads exceed the capability of the pallet tiedown fittings or tracks. It must 

also be demonstrated that the use of tiedown straps does not introduce loads into the pallet that 

would exceed the approved strength of the pallet with regard to distributing the load from the 

pallet tiedown to the cargo restraint system latches, or the strength of the latches. 

(3) Provide the limitations for use of the straps. For example, a limitation might be that 

the use of the straps as a primary restraint of cargo to a TSO-C90 pallet may only be applicable 

to a single piece of cargo, or packaged or crated goods, where the cargo or package container is 

inherently strong enough to be restrained by straps or keep the contents from dispersing. 

Page 42 Par 316 
6/20/05 AC 120-85 

317. CG OFFSET LIMITS. 

a. A ULD specification document, like NAS 3610, specifies in part the CG offset for 

which a ULD should have demonstrated the specific strength requirements. Failure to adhere to 

the CG offset limits in operation jeopardizes the ability of the ULD to restrain the load and the 

ability of the airplane to safely react to the loads imposed by the ULD. 

b. The design of the cargo floor and cargo restraint system is based on the assumption of 

what loads would be applied to the floor beams. The assumptions used in the design of the floor 

may not necessarily be the same as the ULD limits, and ULD CG offset limits for some airplanes 

are more restrictive than the TSO-C90 limits. The floor loads should include the total distributed 

load of the cargo in the ULD and the CG offset that may apply. 

c. If the designer of the airplane structural system and cargo loading systems has assumed 

only a limited CG offset that the systems must react to, the air carrier must ensure the loaded 

cargo is within these design assumptions. Failure of an air carrier to adhere to the limitations of

the design will impact the safety of operation. 

Par 317 Page 43 (and 44)

6/20/05 AC 120-85 

CHAPTER 4. ADMINISTRATIVE INFORMATION 

400. HOW TO OBTAIN COPIES OF PUBLICATIONS. 

a. The CFRs and those ACs for which a fee is charged may be obtained from the 

Superintendent of Documents at the following address. A listing of the CFRs and current prices 

is located in AC 00-44, Status of Federal Aviation Regulations, and a listing of all ACs is located 

in AC 00-2, Advisory Circular Checklist. 

Superintendent of Documents 

P.O. Box 371954 

Pittsburgh, PA 15250–7954 

b. To order free ACs, contact: 

U.S. Department of Transportation 

Subsequent Distribution Office 

M-30 

Ardmore East Business Center 

3341 Q 75th Avenue 

Landover, MD 20785 

c. You may view and print the CFRs and Aircraft Certification Service and Flight 

Standards Service ACs on the FAA Web page located at http://www.airweb.faa.gov/rgl. 

401. ADDITIONAL INFORMATION. For information concerning this AC, contact the Air 

Carrier Maintenance Branch, AFS-330, at (202) 267-3546. Submit direct comments regarding 

this AC to: 

U.S. Department of Transportation 

Federal Aviation Administration 

Aircraft Maintenance Division, AFS-300 

800 Independence Avenue, SW. 

Washington, DC 20591 

Par 400 Page 45 (and 46)

6/20/05 AC 120-85 

Appendix 1 

APPENDIX 1. RELATED REGULATIONS 

1. Title 14 of the Code of Federal Regulations (14 CFR) part 21, Certification Procedures 

for Products and Parts. Part 21, Subpart E, Supplemental Type Certificates. Part 21, 

Subpart K, Approval of Materials, Parts, Processes, and Appliances. Part 21, Subpart O, 

Technical Standard Order Authorizations. 

a. 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. 

 b. Section 21.50, Instructions for continued airworthiness and manufacturers 

maintenance manuals having airworthiness limitations sections. 

 c. Section 21.101, Designation of applicable regulations. 

d. Section 21.303, Replacement and modification parts. 

2. Part 25, Airworthiness Standards: Transportation Category Airplanes. 

 a. Section 25.23, Load distribution limits. 

b. Section 25.301, Loads. 

 c. Section 25.787, Stowage compartments. 

 d. Section 25.853 Compartment interiors. 

 e. Section 25.855, Cargo or baggage compartments. 

 f. Section 25.857, Cargo compartment classification. 

 g. Section 25.858, Cargo or baggage compartment smoke or fire detection systems. 

 h. Section 25.1519, Weight, center of gravity, and weight distribution. 

 i. Section 25.1529, Instructions for continued airworthiness. 

 j. Section 25.1581, Airplane flight manual, general. 

 k. Section 25.1583(c), Weight and loading distribution. 

l. Appendix F to part 25. 

 m. Appendix H to part 25, Instructions for Continued Airworthiness. 

3. Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration. 

4. Part 45, section 45.15, Replacement and Modification Parts. 

5. Part 119, Certification: Air Carriers and Commercial Operators. 

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AC 120-85 6/20/05 

Appendix 1 

 a. Section 119.49, Contents of operations specifications. 

 b. Section 119.72, Reports by air carriers on incidents involving animals during 

air transport.

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

Part 121, Subpart G, Manual Requirements. 

 a. Section 121.153, Aircraft requirements: General. 

 b. Section 121.363, Responsibility for airworthiness. 

 c. Section 121.367, Maintenance, preventive maintenance, and alteration programs. 

 d. Section 121.373, Continuing analysis and surveillance. 

 e. Section 121.375, Maintenance training programs. 

 f. Section 121.419, Pilots and flight engineers: Initial, transition, and upgrade ground 

training. 

 g. Section 121.422, Aircraft dispatchers: Initial and transition ground training. 

 h. Section 121.693, Load manifest: All certificate holders. 

7. Part 145, Repair Stations. 

8. Part 382, Nondiscrimination on the Basis of Disability in Air Travel. 

Section 382.55(a)(1), Miscellaneous provisions. 

Page 2 
6/20/05 AC 120-85 

Appendix 2 

APPENDIX 2. REGULATORY AND GUIDANCE MATERIAL 

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 21-1, Production Certificates. 

4. AC 25-5, Installation Approval on Transport Category Airplanes of Cargo Unit Load 

Devices Approved as Meeting the Criteria in NAS 3610. 

5. AC 25-9, Smoke Detection, Penetration, and Evacuation Tests and Related Flight Manual 

Emergency Procedures. 

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

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

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

9. AC 121-27, Guide for Air Carriers, Freight Forwarders, and Shippers in Obtaining 

Information Dealing With the Transportation of Hazardous Material by Air. 

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

Manuals. 

Federal Aviation Administration (FAA) Orders, Forms, Bulletins, And Technical Standard 

Orders (current editions) 

1. FAA Order 8120.2, Production Approval and Certificate Management Procedures, as 

amended. 

2. FAA Form 337, Major Repair and Alteration. 

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

4. Technical Standard Order (TSO)-C90, Cargo Pallets, Nets, and Containers. 

Cargo AC Development Information 

1. Air Cargo System Implementation Plan, March 2003. 

2. Cargo Strategic Action Plan, April 2002. 

3. Compliance Document for ULD Center of Gravity Control on B-727 Aircraft, 

October 2000. 

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

Industry Information 

1. International Air Transport Association (IATA) Aerospace Recommended Practice 

(ARP) 1334, 5486, 5595, and 5597. 

2. IATA Airport Handling Manual. 

 Page 1 
AC 120-85 6/20/05 

Appendix B 

3. IATA ULD Technical Manual (UTM). 

4. International Standards Organization (ISO) Publication No. 4118, Non-certified Lowerdeck Containers for Air Transport. 

5. National Aerospace Standard (NAS) 3610, Cargo Unit Load Devices. 

6. Society of Automotive Engineers (SAE) Aerospace Standards: 

• AS 1677, General Requirements for Uncertified Cargo/Baggage Containers 

• AS 1131C, Pallet Net 

• AS 1491B, Interline pallet (NAS 3620 Class II) 

• AS 1492B, Pallet Net 

• AS 4041, Air Mode General Purpose Containers 

• AS 4041A, Intermodal Container AS 1130F, Air-Surface Pallet 

• AS 5385A, Cargo Restraint Straps—Design Criteria and Testing Methods 

• AS 5896A, Lower Deck Certified Containers 

• AS 36101, ULD Load Distribution Model 

7. Society of Automotive Engineers (SAE) Aerospace Recommended Practice (ARP): 

• ARP 1334, Ground Equipment Requirements for Compatibility with Aircraft Unit 

Load Devices 

• ARP 1554B, Automobiles Transport Device 

• ARP 1621B, Horses Transport Stall 

• ARP 1840A, Aircraft Engine Transport Device 

• ARP 5486, Air Cargo Pallets—Utilization Guidelines 

• ARP 5595, Cargo Restraint Straps—Utilization Guidelines

• ARP 5596, Cargo Shoring Guidelines 

Page 2 
6/20/05 AC 120-85 

Appendix 3 

APPENDIX 3. DEFINITIONS RELATED TO AIR CARGO OPERATIONS 

1. Approved Parts. Unless used with reference to another person, means parts approved 

by the Administrator. 

2. Cargo. For the purpose of this advisory circular (AC), cargo refers to passenger 

checked baggage, freight, hazardous materials, dangerous goods, and company 

materials. Cargo does not include passenger carry-on baggage. 

3. Cargo Handling System/Cargo Restraint System. A system installed in an aircraft 

and used to convey and restrain unit load devices (ULD) in the aircraft. 

4. Company Materials. Company material, commonly called COMAT, is an industry 

term used by air carriers to describe nonrevenue materials and supplies owned by the 

air carrier that are shipped by the air carrier in support of its operations. 

5. Certified Unit Load Device (ULD). A ULD meeting the requirements of TSO-C90, 

Cargo Pallets, Nets, and Containers, as amended; STC requirements, if applicable; or 

other FAA-approved certification standards. 

6. 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. 

7. Dynamic Load. Loads imparted on the structure of the aircraft by loaded cargo during 

taxi, takeoff, cruise, and landing. 

8. First Article Inspection. Inspection of the first of a manufactured component to ensure 

compliance with certification and airworthiness requirements.

9. Frangible (Compressible) Cargo. Cargo with a density and structure such that it is

loose in nature and able to absorb energy during an emergency landing situation, as 

defined in the aircraft weight and balance document. Compressible cargo may be 

required in certain positions for protection of the aircraft and its ability to withstand 

emergency landing conditions, as required by the airplane manufacturer weight and 

balance documents. 

10. Hazardous Materials. Materials or substances meeting the definition of hazardous 

material in Title 49 of the Code of Federal Regulations part 171, section 171.8. 

Hazardous materials are also referred to as hazmat, dangerous goods, and DGs. 

11. Interlining. Movement of freight from one air carrier to another. For example, a ULD 

transferred from a domestic air carrier to a foreign air carrier. 

12. Non-Certified Unit Load Device. A ULD not certified or approved by the FAA. 

13. Overhang Cargo. Cargo that is larger in at least one direction than the overall 

dimensions of the pallet. This includes cargo tied down to more than one pallet. 

14. Oversized Cargo. Cargo that overlaps the pallet’s tiedown track but is within the 

overall dimensions of the pallet. 

15. Rigid (Non-Frangible) Cargo. Cargo with a density that is rigid in nature, as defined 

in the airplane manufacturer’s weight and balance document. 

 Page 1 
AC 120-85 6/20/05 

Appendix C 

16. Sharp Cargo. Cargo that has a piercing or penetrating nature, or cargo with sharp 

edges or corners. 

17. Static Load. Loads imparted on the aircraft structure by loaded cargo while the aircraft 

is parked. 

18. Step-Loading. Loading ULDs on an aircraft by specific sequence, position, and stages. 

19. Supernumeraries. Persons that are not members of the crew who are carried on board 

all-cargo aircraft that do not comply with all passenger carrying requirements of 14 CFR 

part 121. 

20. Tare Weight. The weight of the empty ULD, including its normal complement of 

loading restraint devices. Also, the empty weight of other material handling equipment 

(i.e., baggage carts, dollies, etc.) used to weigh cargo on a scale. 

21. 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. 

22. Unit Load Device (ULD). A device for grouping, transferring, and restraining cargo for 

transit. 

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

24. Vendor. Any person or entity performing a service for the air carrier. This includes, 

but is not limited to, a freight forwarder, contractor, customer, and another air carrier 

that performs cargo buildup, airplane loading, and unloading for the air carrier. This 

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

25. Zone Weight. Cumulative weight as loaded within a designated zone within the aircraft 

such as a specific area on the upper deck cargo area plus the cargo loaded on the lower 

deck directly beneath. 

Page 2 
6/20/05 AC 120-85 

Appendix 4 

APPENDIX 4. ACRONYMS AND ABBREVIATIONS 

14 CFR Title 14 of the Code of Federal Regulations 

AC advisory circular 

CASS Continuing Analysis and Surveillance System

CFR Code of Federal Regulations 

CG center of gravity 

CMM component maintenance manual 

COMAT company material 

DG dangerous goods 

FAA Federal Aviation Administration 

hazmat hazardous materials 

IATA International Air Transport Association 

ICA instructions for continued airworthiness

ISO International Standards Organization 

MEL minimum equipment list 

NAS National Aerospace Standard 

NIST National Institute of Standards and Technology

OEM Original Equipment Manufacturer 

PC Production Certificate 

PMA Parts Manufacturer Approval 

SAE Society of Automotive Engineers 

STC Supplemental Type Certificate 

TC type certificate 

TSO Technical Standard Order 

ULD unit load device 

Page 1 (and 2) 

6/20/05 AC 120-85 

Appendix 5 

APPENDIX 5. SUGGESTED STRUCTURAL DATA FOR 

PASSENGER-TO-CARGO CONVERSION PROJECT 

An applicant should submit the following data to the Federal Aviation Administration (FAA) as 

structural substantiation in support of a passenger-to-cargo conversion project. This list is not 

all-inclusive, and each project should be individually evaluated to determine if additional data 

are necessary. The applicant and the approving authority representative should come to an 

agreement on the necessary data early in the program as part of the certification plan.

NOTE: Documents with an asterisk (*) are required by Title 14 of the Code of 

Federal Regulations (14 CFR). 

Aircraft Flight Manual.* Identifies all operating limitations, including operating speeds and 

door operation, and contains allowable aircraft fuel and cargo loading directly or by reference. 

Any additional information necessary to safely operate the aircraft should also be provided. 

Aircraft Loading Document.* Describes the types of cargo containers allowed, how the 

containers are restrained, and loading requirements when latches are missing or broken. This 

may be contained in the weight and balance manual. Ensures compatibility of the cargo handling 

system with the cargo conversion. These modifications have often been incorporated 

independent of each other. In addition, if the use of tiedown fittings is permitted, the tiedown 

strength and limitation data should be provided. 

Assembly/Installation Drawings.* Details how all parts are assembled and identifies the 

number and types of fasteners used. 

Cargo Restraint System. Designed for all critical ground, flight, and emergency landing loads. 

This includes seat tracks, pallet locks, side restraints, and roller trays. The 9G rigid barrier or 

cargo restraint net, if required, and its attachment, and the fuselage surrounding structure must be 

analyzed for critical payloads. 

Certification Plan. Lists all steps necessary to complete FAA certification of the modification. 

At a minimum, the plan should discuss scope of the project, schedule, use of Designated 

Engineering Representatives (DER), data submittals, and conformity issues. 

Compatibility Evaluation. The applicant evaluates each aircraft to be modified to ensure it is 

compatible with the Supplemental Type Certificate (STC) modification. The applicant also 

identifies and evaluates modifications, alterations, or the incorporation of other STCs that change 

the type design of the aircraft to be modified. The applicant notes and makes accommodations 

for differences and necessary drawing changes. 

Compliance Checklist. Lists all applicable rules from the certification basis of the modification 

of the aircraft. Also identifies necessary compliance with outstanding Airworthiness Directives 

(AD) and the methods of compliance. 

Configuration Deviations.* Lists all nonconformities with their engineering dispositions. 

Damage Tolerance Assessment (DTA).* Required for all 14 CFR part 25 post-Amendment45-certified aircraft. The applicant should create a DTA for pre-Amendment-45 aircraft in 

support of a supplement to a standard that is required by an AD. The DTA should evaluate 

 Page 1 
AC 120-85 6/20/05 

Appendix 5 

whether an existing principal structural element has been changed or if one has been created by 

the modification. Fail-safe requirements should be addressed as necessary. 

Decompression Analysis. The substantiation must show that the cargo compartment is designed 

to withstand the effects of a sudden release of pressure. Consider impact of solid 9G barrier in 

decompression scenarios (part 25, section 25.365(e); Civil Air Regulations (CAR) 4b.216(c)(4)). 

Design Criteria. A list of design, analysis, and production methodologies, and requirements 

used in creating the modification. 

Detail Drawings.* There should be a detail drawing for each part manufactured for use in the 

modification and some means of controlling the source of all vendor-supplied items. 

Door Mechanical Systems. The applicant analyzes the door opening, latching, and locking 

mechanisms for most critical loads, which should include maximum hydraulic actuator output 

and possible jam conditions. 

Door Surround Structure. The door surround structure must be analyzed for the redistributed 

loads resulting from the door cutout. This includes the fuselage skin, doublers, sills, headers, 

footers, surrounding frames, and longerons/stringers, latches, and their attachments. An analysis 

of the door and the door hinge should also be included. 

External Loads Analysis.* Should include most critical aircraft weight distribution at both 

minimum and maximum weights and critical loading throughout the center of gravity (CG) 

range, including raised vertical CG, and must consider all points within the operating envelope 

(that is, gust and maneuver). External loads should also include the effects of loads on pallet 

locks, load impingement on main deck floors by lower deck, unrestrained cargo, and shift in unit 

load devices (ULD) or bulk load cargo CG locations consistent with pallet approvals and usage. 

Final Documentation. Documentation showing that all structural margins are positive for the 

critical load case. 

Floors. The floor beams, fuselage frames, and posts/struts should be analyzed for the most 

critical loading conditions. 

Flutter Substantiation.* A cargo conversion can change the fuselage stiffness or change the 

mass distribution, which can have an effect on the aircraft’s flutter characteristics, particularly aft 

cargo doors. 

Functional Check.* Performed to ensure proper operation of the main cargo door. The number 

of open-close cycles are to be decided upon with the aircraft certification office. The test could 

include determining the mean time between failure of components, validating the failure modes 

and effects analyses, and monitoring the wear of latches (14 CFR section 25.1301; CAR 4b.601). 

Identification of Supplemental Type Certificate Team Members. Identify STC team

members and DERs whose experience is commensurate with these kinds of projects (that is, 

external loads, systems safety assessment, finite element modeling, and validation). 

Illustrated Parts Catalog. Catalog of all parts contained in the supplemental type certificate for 

procurement purposes. 

Page 2 
6/20/05 AC 120-85 

Appendix 5 

Installation Instructions. Any installation instructions necessary other than what is listed in the 

installation drawings. Ensure that there are adequate instructions for the installation of cargo 

compartment liners and floor panels to minimize the use of a shop practice that may result in 

blind drilling of holes that could induce damage (double-drilled holes and short-edge margins) to 

floor beam caps and fuselage frames. 

Internal Loads Analysis.* Distribution of loads within the affected airframe structure. Load 

distribution should be validated. 

Maintenance Instructions.* Continued airworthiness requirements for the inspection program, 

which includes the frequency and extent of those inspections. 

Maintenance Manual.* Instructions for continued airworthiness of the modifications. 

Master Data List. Lists all process specifications and reports that substantiate the structural

strength and damage tolerance of the modification, along with all test reports (that is, flutter, 

pressurization, finite element method (FEM) validation). 

Master Drawing List.* Controls all drawings and process specifications that define design of 

the modification. 

Master Minimum Equipment List. Aircraft Evaluation Group (AEG) approval for dispatch 

with inoperative components, that is, cargo system locks and cargo door latches. 

Methodology Description. Describes the methodology used to define (1) the barrier load 

distributions and intensities and distribute the barrier loads to the monocoque, and (2) the ULD 

load distributions and intensities and distribute the loads to the restraint system components and 

floor. 

Pressure Test.* The structure must be designed to withstand (limit load) the maximum pressure 

relief valve setting combined with flight loads (part 25, section 25.365(a); CAR 4b.216(c)(1)), 

and the maximum relief valve setting omitting other loads times a factor of 1.33 or 1.67, as 

appropriate (section 25.365(d); CAR 4b.216(c)(3)). If the modification or conversion involves 

changes to the pressure barrier, such as a new door installation, it must be pressure tested per 

part 25, section 25.843 or CAR 4b.376. 

Structural Repair Manual. Instructions for repair of the modifications. 

Structural Substantiation.* Positive margins of safety should be shown for all modified 

structures. Assumptions used in any analysis or test must be consistent with how the loads are 

applied and the way the structure carries these loads. A margin of safety table should be 

published for each structural analysis. 

Weight and Balance Manual.* Describes aircraft fuel and payload distributions and 

CG restrictions. Defines applicable ULDs. Provides any other relevant information necessary 

for the safe operation of the aircraft.

Page 3 (and 4) 

6/20/05 AC 120-85 

Appendix 6 

APPENDIX 6. PASSENGER-TO-CARGO CONVERSIONS 

SUPPLEMENTAL TYPE CERTIFICATE DATA PACKAGE FOR 

SYSTEMS AND EQUIPMENT 

1. An applicant should submit the following information to the Federal Aviation Administration 

(FAA). 

a. Certification Plan. Helps determine the scope of the conversion project, that is, full 

passenger-to-cargo conversion, cargo door-only conversion, or smoke detection system-only 

conversion, and whether supernumeraries are included. A systems description document may 

have been included in the certification plan, system failure modes, and effects analyses. It is 

likely that safety analyses were not prepared; you may have to learn about the system based on 

drawings and diagrams. 

b. Compliance Checklist. Helps determine methods to comply to all applicable Title 14 

of the Code of Federal Regulations (14 CFR)/Civil Air Regulations (CAR). 

c. Master Data List/Top Drawing List. Helps link the supplemental type certificate 

drawings/reports down to detailed levels. 

2. Based on, or lacking, the above data, the following areas should be reviewed for the 

conversions to determine that the modifications are safe: 

a. Cargo Door. Should include— 

(1) Safety analyses (including any latch/lock/pin failures that could cause door to 

unlock); 

(2) Drawings; 

(3) Wiring qualification (flammability);

(4) Wiring diagrams/schematics; 

(5) Electrical load analysis; 

(6) Hydraulic components qualification test; 

(7) System pressure proof/burst test; 

(8) Any conformity reports (parts, test article, installation); 

(9) Flammable fluid fire protection; 

(10) Aircraft Flight Manual (AFM) and limitations; 

 Page 1 
AC 120-85 6/20/05 

Appendix 6 

(11) Cargo door opening, closing, and locking mechanisms, including vent door design 

with its associated power sources (electrical, hydraulics, mechanical), door opening retention 

system safety during cargo loading, and system isolation during flight; and 

(12) Cargo door warning system and its redundancy features (door control panel and 

cockpit displays, sensors, placards). 

b. Continued Airworthiness. Maintenance/overhaul manual, flightcrew operating 

manual, minimum equipment list (MEL), certification maintenance requirements (if required by 

safety analyses), and any other relevant information for all systems. 

c. Crew Emergency Exit. Interior arrangement drawing and compliance inspection to 

determine crew accessibility under any cargo loading condition. 

d. Critical Component. Drawings, reports, or issue papers addressing means of 

protection of critical controls, lines, and equipment in the cargo compartment. 

e. Smoke Barrier. Should include— 

(1) Drawings/installation; 

(2) Smoke penetration test plan and report (may be included in the smoke detection 

system test report); 

(3) Flight test report; and 

(4) Conformity reports (parts, test article, installation). 

f. Smoke Detection System. Should include— 

(1) Installation drawings; 

(2) A test plan and report (including testing in MEL configuration); 

(3) Wiring qualification (flammability); 

(4) Wiring diagrams/schematics; 

(5) Electrical load analysis; 

(6) Technical Standard Order (TSO)-approved smoke detector (or other testing done 

for a supplemental type certificate); 

(7) System control panel qualification and installation; 

(8) Flight test report; 

(9) Conformity reports (parts, test article, installation); 

Page 2 
6/20/05 AC 120-85 

Appendix 6 

(10) Failure modes and effects analyses; 

(11) AFM and limitations; and 

(12) Compliance inspection to determine cargo interference with fire protection 

features. 

g. Supernumerary Occupants (If Applicable). Data should include exemption 

approvals from the FAA and interior arrangement drawings. This includes all 14 CFR part 25 

regulations applied for carriage of passengers such as emergency egress assist means and escape 

routes, emergency lighting, emergency exit access, seats, safety harness, oxygen equipment and 

supply, portable breathing equipment, safety equipment, markings and placards, and compliance 

inspection. 

h. Ventilation System. The ventilation may have been modified to provide a means to 

shut off ventilation to the cargo compartment in case of a fire. Data should include—

(1) Detailed design/drawings; 

(2) Wiring diagrams; 

(3) Electrical load analysis; 

(4) Safety analyses; 

(5) AFM and limitations; and 

(6) Cockpit smoke evacuation procedures (may be required). 

Page 3 (and 4) 

6/20/05 AC 120-85 

Appendix 7 

APPENDIX 7. DESIGN CRITERIA FOR OUTWARD OPENING DOORS 

The following is an excerpt from a Federal Aviation Administration (FAA) Memorandum to the 

Director of Airworthiness and Technical Standards of the Air Transportation Association of 

America ATA, dated March 20, 1992 that defined criteria for outward opening doors. 

(1) Indication System: 

(a) The indication system must directly monitor the closed, latched, and locked positions. 

(b) The indicator should be amber unless it concerns an outward opening door whose 

opening during takeoff could present an immediate hazard to the airplane. In that case, the 

indicator must be red and located in plain view in front of the pilots. An aural warning is also 

advisable. A display on the master caution/warning system is also acceptable as an indicator. 

For the purpose of complying with this paragraph, an immediate hazard is defined as significant 

reduction in controllability, structural damage, or impact with other structures, engines, or 

controls. 

(c) Loss of indication or a false indication of a closed, latched, and locked condition must 

be improbable. 

(d) A warning indication must be provided at the door operator’s station that directly 

monitors the door latch and lock conditions, unless the operator has a visual indication that the 

door is fully closed and locked. For example, a vent door that monitors the door locks and can 

be seen from the operator’s station would meet this requirement. 

(2) Means to Visually Inspect the Locking Mechanism: There must be a visual means of directly 

inspecting the locks. Where all locks are tied to a common lock shaft, a means of inspecting the 

locks at each end may be sufficient to meet this requirement provided no failure condition in the 

lock shaft would go undetected when viewing the end locks. Viewing latches may be used as an 

alternate to viewing locks on some installations where there are other compensating features. 

(3) Means to Prevent Pressurization: All doors must have provisions to prevent initiation of 

pressurization of the airplane to an unsafe level if the door is not fully closed, latched, and 

locked. 

(4) Lock Strength: Locks must be designed to withstand the maximum output power of the 

actuators and maximum expected manual operating forces treated as a limit load. Under these 

conditions, the door must remain closed, latched, and locked. 

(5) Power Availability: All power to the door must be removed in flight, and it must not be 

possible for the flightcrew to restore power to the door while in flight. 

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Appendix 8 

APPENDIX 8. TRANSPORT CATEGORY AIRPLANE 

ICA CHECKLIST 

Requirement Regulation Location 

( ) ICA for each engine. H25.1(b) 

( ) ICA for each propeller. H25.1(b) 

( ) ICA for each appliance required by this AC. H25.1(b) 

( ) Any required information relating to the interface of the 

( ) appliances, ( ) engines and ( ) propellers with the airplane. 

H25.1(b)

( ) If ICA are not supplied by the manufacturer of an 

( ) appliance, ( ) engine or ( ) propeller installed on the

airplane, the ICA for the airplane must include ( ) the information 

essential to the continued airworthiness of the airplane. 

H25.1(b)

( ) Program showing how changes to the ICA made by the 

applicant or by the manufacturer of products and appliances 

installed on the airplane will be distributed. 

H25.1(c)

( ) ICA in the form of a manual or manuals. 

( ) In a practical arrangement. 

H25.2(a) 

H25.2(b) 

( ) The contents of the manual or manuals must be prepared in the 

English language. 

H25.3

( ) Must include introductory information that includes an 

explanation of the airplane’s features and data to the extend 

necessary for maintenance or preventive maintenance. 

H25.3(a)(1)

( ) A description of the ( ) airplane and its systems and 

installations, ( ) engines and its systems and installations, 

( ) propellers and its systems and installations, ( ) appliances 

and its systems and installations. 

H25.3(a)(2)

( ) Basic control and operating information describing ( ) how 

the airplane components and systems are controlled and ( ) how 

the airplane components and systems are operated including 

( ) any special procedure and limitations. 

H25.3(a)(3)

( ) Servicing information that covers details regarding 

( ) servicing points, ( ) capacities of tanks, ( ) capacities of 

reservoirs, ( ) types of fluids to be used, ( ) pressures applicable 

to the various systems. 

H25.3(a)(4)

( ) Location of access panels for ( ) inspection and 

( ) servicing. 

H25.3 (a)(4) 

( ) Servicing information that covers details regarding 

( ) locations of lubrication points, ( ) the lubricant to be used. 

H25.3(a)(4)

( ) Equipment required for servicing. H25.3(a)(4) 

( ) Tow instructions and limitations. H25.3(a)(4) 

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Appendix 8 

Requirement Regulation Location 

( ) Mooring information. H25.3(a)(4) 

( ) Jacking information. H25.3(a)(4) 

( ) Leveling information. H25.3(a)(4) 

( ) Scheduling information for each part of the ( ) airplane that, 

provides the recommended periods at which they should 

( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

H25.3(b)(1)

( ) Scheduling information for the ( ) airplane’s engine(s) that 

provides the recommended periods at which they should be 

( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

NOTE: This information may be in the FAA-accepted 

engine ICA. 

H25.3(b)(1)

( ) Scheduling information for the ( ) airplane’s auxiliary power 

unit (APU) that provides the recommended periods at which they 

should be ( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

H25.3(b)(1)

( ) Scheduling information for the ( ) airplane’s propellers that 

provides the recommended periods at which they should 

( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

H25.3(b)(1)

( ) Scheduling information for the ( ) airplane’s accessories 

that provides the recommended periods at which they should 

( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

H25.3(b)(1)

( ) Scheduling information for the ( ) airplane’s instruments that 

provides the recommended periods at which they should 

( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

H25.3(b)(1)

( ) Scheduling information for the ( ) airplane’s equipment that 

provides the recommended periods at which they should 

( ) cleaned, ( ) inspected, ( ) adjusted, ( ) tested, 

( ) lubricated and ( ) the work recommended at these periods. 

H25.3(b)(1)

( ) The degree of inspection for each part of the ( ) airplane and 

its ( ) engines, ( ) auxiliary power unit, ( ) propellers, 

( ) accessories, ( ) instruments and ( ) equipment. 

H25.3(b)(1)

( ) The applicable wear tolerances. H25.3(b)(1) 

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Appendix 8 

Requirement Regulation Location 

The applicant may refer to an ( ) accessory, ( ) instrument, or 

( ) equipment manufacturer as the source of this information if the 

applicant shows ( ) that the item has an exceptionally high degree 

of complexity requiring specialized maintenance techniques, test 

equipment, or expertise. 

H25.3(b)(1)

( ) The recommended overhaul periods and necessary cross 

references to the Airworthiness Limitation Section. 

H25.3(b)(1)

( ) An inspection program that includes ( ) the frequency and 

( ) extent of the inspection necessary to provide for the continued 

airworthiness of the airplane. 

H25.3(b)(1)

( ) Troubleshooting information describing ( ) problem

malfunctions, ( ) how to recognize those malfunctions and 

( ) the remedial action for those malfunctions. 

H25.3(b)(2)

( ) Information describing the order and method of ( ) removing 

and ( ) replacing products (Engines and Propellers) with any 

necessary precautions to be taken. 

H25.3(b)(3)

( ) Information describing the order and method of ( ) removing 

and ( ) replacing parts with any necessary precautions to be taken. 

H25.3(b)(3)

( ) Other general procedural instructions including ( ) storage 

limitations and procedures for ( ) testing system during ground 

running, ( ) making symmetry checks, ( ) weighing and 

determining the CG, ( ) lifting, ( ) shoring. 

H25.3(b)(4)

( ) Diagrams of structural access plates and information needed to 

gain access for inspections when access plates are not provided. 

H25.3(c)

( ) Details for the application of special inspection techniques

including radiographic and ultrasonic testing where such process are

specified. 

H25.3(d)

( ) Information needed to apply projective treatment to structure 

after inspection. 

H25.3(e)

( ) All data relative to structural fasteners such as 

( ) identification, ( ) discarded recommendations, and 

( ) torque values. 

H25.3(f)

( ) A list of special tools needed. H25.3(g) 

( ) The ICAs must contain a section titled Airworthiness 

Limitations that is ( ) segregated and ( ) clearly distinguishable 

from the rest of the document. 

NOTE: The Airworthiness Limitations Section in the 

applicant’s ICA will be evaluated and approved by 

the appropriate FAA office. 

H25.4(a)

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Appendix 8 

Page 4 

Requirement Regulation Location 

The Airworthiness Limitations Section must set forth each 

mandatory replacement time, structural inspection interval, and 

related structural inspection procedures approved under 

section 25.571. 

H25.4(a)(1) 

The Airworthiness Limitations Section must set forth each 

mandatory replacement time, inspection interval, related inspection 

procedure, and all critical design configuration control limitations 

approved under section 25.981 for the fuel tank system. 

H25.4(a)(2) 

( ) If the ICAs consist of multiple documents, the Airworthiness 

Limitations Section required by this paragraph must include in the 

principal manual. 

H25.4(b) 

( ) The Airworthiness Limitations Section must contain a legible 

statement in a prominent locations that reads; “The Airworthiness 

Limitations Section is FAA-approved and specifies inspections and 

other maintenance required under 14 CFR sections 43.16 and 91.403 

unless an alternative program has been FAA-approved.” 

H25.4(b)