VOLUME 6 SURVEILLANCE
CHAPTER 2 PARTS
91 SUBPART K INSPECTIONS
Section 5 Safety Assurance System: Conduct a Ramp Inspection on Cargo Loading (Including Part
6-265 REPORTING SYSTEM(S).
A. Program Tracking and Reporting Subsystem (PTRS). Inspectors
of Title 14 of the Code of Federal Regulations (14 CFR) part
91 subpart K (part
91K) and part
document their surveillance in the PTRS using activity codes 1638, 3623, and 5623.
B. Safety Assurance System (SAS). For 14 CFR parts
inspectors will follow and use the associated SAS Data Collection Tools (DCT).
6-266 OBJECTIVE. This section provides guidance for conducting surveillance
and inspection (maintenance and operations) on parts
cargo, combi, and regional passenger aircraft that transport
cargo, passenger baggage, Company Material (COMAT), and hazardous materials
(hazmat) in the upper deck, lower deck, forward and/or aft cargo compartments, or pods.
A. Federal Aviation Administration (FAA) Inspection Personnel.
1) Aviation safety inspectors (ASI) should become familiar with
the type of aircraft to be inspected before performing their surveillance. This
may be accomplished through on-the-job training (OJT), the Air Cargo Operations
Course 21000056, or a formal aircraft systems training.
2) Due to certificate holder’s varying schedules, inspectors
may need to perform their surveillance outside of normal office hours or when time permits.
3) Inspectors will review the certificate holder’s cargo operations procedures.
1) An ASI who needs additional information or guidance on a topic
will coordinate with other ASIs who have experience in that specialty.
2) Geographic units may need to coordinate with the certificate-holding
district office (CHDO) to gain access to a certificate holder’s procedures manual.
In addition, when it finds discrepancies, the geographic unit will communicate
with the CHDO before initiating corrective or enforcement action. In the case
of hazmat discrepancies, inspectors will notify the regional hazmat branch manager
through the appropriate Regional Operations Center (ROC). They will conduct
any required investigation and handle any resulting corrective action.
3) Volume 3, Chapter 47, Section 1,
Table 3-127, Delineation of Responsibilities,
provides an overview of the responsibilities between the ASI disciplines and
aircraft certification. This overview is not a comprehensive list. The intent
of Table 3-127 is to display specific areas of discipline responsibility in
relation to elements of Weight and Balance (W&B), airplane limitations,
and cargo operations, and the overlap between them. Operations and Airworthiness
inspectors should cross-train in areas of responsibility that overlap.
6-268 INITIATION AND PLANNING.
A. Initiation. This task can be scheduled in SAS as part of the Comprehensive
Assessment Plan (CAP) by the principal inspector (PI) or recorded in SAS as
an unplanned inspection initiated by special requirements.
B. Planning. The cargo ramp inspections provides the ASI with
a good opportunity to ensure that the certificate holder’s cargo programs are
adequate and are being followed. To this end, the inspector should review the
certificate holder’s programs to familiarize themselves with the specific details
of these programs. These may include:
1) Review operations specifications (OpSpecs) to verify the hazmat
status of the certificate holder (i.e., will carry or will not carry). A “will
carry” certificate holder will have OpSpec A055 issued.
2) Review certificate holder’s cargo and baggage loading procedures.
3) Review certificate holder’s W&B procedures.
4) Review certificate holder’s procedures for different types
of cargo such as oversized cargo, sports teams and their equipment, military
contract loads (either cargo or troop transport), or special cargo.
5) Review certificate holder’s procedures for loading last-minute
items in cargo, baggage, pod compartments, and so forth. This may include items
such as carry-on bags, plane-side bags or cargo, mail, or COMAT/hazmat.
6) Review the certificate holder’s evaluation system (e.g., Continuing Analysis
and Surveillance System (CASS), Internal Evaluation Program (IEP)) to identify
possible negative trends in their cargo program. The major activities include
surveillance, data analysis, corrective action, and followup.
6-269 MAINTENANCE RECORDS.
A. Cargo-Related Equipment. By regulation, maintenance, when
performed, must be recorded prior to an approval for return to service. This
also holds true for cargo-related equipment. The records should include unit
load devices (ULD), net, or cargo loading system (CLS) component repairs conducted
in house or by outside agencies, and record retention and receiving inspections
of those items. The certificate holder’s manual must describe the procedures
for ensuring that recording requirements are met for cargo-related equipment.
B. Correcting Mechanical Discrepancies. Every mechanical discrepancy
in the maintenance log must be either corrected or deferred (including CLS components)
using the methods identified in the certificate holder’s maintenance procedures manual.
6-270 DEFERRED MAINTENANCE.
A. Minimum Equipment List (MEL), Configuration Deviation List (CDL),
or Nonessential Equipment and Furnishings (NEF) ListDeferred Maintenance.
An approved MEL/CDL/NEF allows the certificate holder to continue a flight or
series of flights with certain inoperative or damaged equipment. Depending on
the type of aircraft, this may affect the CLS or even limit or prevent the carriage
of cargo in one or more positions, or in an entire compartment. The continued
operation must meet the requirements of the MEL/CDL/NEF deferral classification
and the requirements for the equipment loss.
B. Repairing Inoperative Items. The maintenance program accepted
for a certificate holder must provide for prompt and orderly repairs of inoperative items.
6-271 AIRCRAFT INSPECTION GUIDELINES. Ensure the following:
A. Load Manifest. Ensure that the load manifest form is prepared
and signed by employees of the certificate holder or other authorized, trained,
and qualified persons assigned to supervise the loading of aircraft and prepare
the load manifest form.
NOTE: Ensure that the special cargo load schematic is used and retained by the certificate
holder. Refer to Volume 3, Chapter 47, Section 2, and Advisory Circular (AC)
120-85, Air Cargo Operations.
B. Upper Deck Inspection (Cargo/Combi Aircraft).
1) Inspect the main cargo door, door seal, locking mechanism,
and door lock viewing windows (if installed) for damage, deterioration, distortion, and security.
2) Review station weight placards for loading. For all-cargo
aircraft configuration main cargo deck, inspect firefighting equipment, Protective
Breathing Equipment (PBE), and crewmember walkway access if required.
3) Inspect the cargo compartment, paying particular attention
to the condition and security of the ceiling, sidewall linings, and floor panels.
Holes in liners repaired by tape may indicate hidden structural damage. If damage
is found, the MEL/CDL/NEF procedures must be followed (if applicable) or it
must be repaired in accordance with the appropriate instructions for continued
4) Inspect main floor locks, floor tracks, drive wheels, rollers,
side rails, and cargo loading components for security, damage, and general condition.
Ensure compliance with the type certificate (TC)/Supplemental Type Certificate
(STC) and associated supplements.
NOTE: Be aware of possible substitution of load-bearing components of
the CLS. If any substitution of load-bearing components is found, contact the
certificate holder for clarification. After completing the inspection, the ASI
should contact the CHDO to discuss the results, if required.
5) Inspect the main cargo doorsill protector for installation, security, and condition (damage).
C. Main Cargo Compartment Inspection.
1) Inspect the main cargo compartment area for foreign object debris (FOD) and general cleanliness.
2) Inspect the overall condition of the smoke barrier curtain,
if installed, or cockpit door seal, barrier net assembly, or solid bulkhead.
Ensure that the net (if used) has the proper rating for its intended G-loading.
Pay particular attention to the following:
a) The smoke barrier curtain must be free of tears, holes, and cuts to prevent
smoke from entering the forward cabin and flight deck.
b) The cockpit door seal for condition and integrity.
c) The barrier net for condition and security (i.e., check for frayed straps,
hardware integrity, and proper markings).
d) Cargo compartment retention nets for condition and security.
e) The solid bulkhead for condition and security.
f) The required placards, such as loading, fire suppression, and so forth.
D. Lower, Forward, and/or Aft Compartment and Pods.
1) Inspect the compartment or pod to determine its condition,
security, deterioration, and cleanliness.
2) Ensure that the required placards are installed.
3) Ensure that baggage is loaded in accordance with the certificate
holder’s Weight and Balance Program (WBP) and/or other certificate holder procedures.
4) Check the condition and security of tiedown devices/restraints.
5) Check the security of ballast, if installed.
6) If the aircraft is equipped with cargo pods, inspect the area
like any other cargo compartment.
7) Inspect floor locks/CLS, if installed. Inspect door seals
8) Inspect the interior, paying particular attention to the condition
and security of the ceiling/sidewall linings and floor panels, including the
proper installation of repair tape. Repair tape must comply with 14 CFR part
9) Inspect cargo doors, door seals, locking mechanisms, and door
lock viewing windows (if installed) for cleanliness, damage, deterioration,
and security. Ensure that the fire detection/suppression is appropriate for
its classification and that required placards are present.
10) Ensure that cargo is properly secured by appropriate tiedowns
having enough strength to eliminate the possibility of shifting under all normal flight conditions.
11) Inspect retention nets for condition and security.
12) Ensure that loading/unloading is conducted in a safe manner
in accordance with the certificate holder’s procedures.
13) Whenever possible, inspect cargo for proper tagging and/or
identification (e.g., mail, crew bags, equipment, and parts that the certificate holder considers COMAT).
14) Ensure that ceiling smoke detectors are free from obstruction.
15) Ensure that walkway areas are clear (as applicable).
1) Ensure that ULDs are eligible for transport on the aircraft.
NOTE: The Weight and Balance Manual (WBM) determines eligibility, as referenced in
the TC, or STC W&B supplement.
2) Ensure that Technical Standard Order (TSO) markings are attached
to cargo containers, nets, and pallets (if applicable). If active ULDs are present,
ensure they are placarded as certified under FAA Order
Certification of Cargo Containers with Self-Contained Temperature
Control Systems (Active ULDs), and approved under part
A certificate holder must have specific procedures in its manual to carry active ULDs.
3) Inspect ULDs (nets, pallets, and containers) for serviceability
per the certificate holder’s procedures and limitations.
4) Ensure that identification markings are present in accordance
with the certificate holder’s procedures.
5) Evaluate cargo tracking devices, data loggers, radio frequency identification
(RFID), and electronic bag tags in accordance with AC
Use of Portable Electronic Devices Aboard Aircraft.
6) Ensure that ULDs are properly secured.
F. Temperature-Controlled Shipping Containers.
1) Temperature-controlled shipping containers are devices designed
to maintain their contents within strict temperature controls. These devices
may bear a TSO, STC, Parts Manufacturer Approval (PMA), or be allowed by the TC.
2) For a certificate holder to carry these devices, it must incorporate
or reference the pertinent parts of the device’s certification documents into
its manual. This includes training of appropriate personnel on the handling
and maintenance of these devices. These units will be approved in the limitations
section of the certification document for use with certain net and pallet combinations.
Any aircraft that is eligible to carry the approved net and pallet combinations may carry these devices.
NOTE: Hazmat procedures may apply to these devices and/or their contents.
G. Weighing Scales.
1) Inspect current calibration of scales traceable to the National
Institute of Standards and Technology (NIST), or equivalent.
2) Inspect overall condition of scales.
3) Ensure cargo weigh scales are calibrated, and periodically
and functionally checked for accuracy in conformance with the certificate holder’s program.
4) Observe weighing procedures and system integration to the load manifest.
H. Aircraft Loading and Ground Equipment.
1) Ensure that the aircraft is loaded/unloaded in accordance
with the certificate holder’s manual.
2) Ensure special cargo is accepted, loaded, restrained, and
unloaded using a special cargo analysis function (SCAF) and load schematic.
This is all accomplished in accordance with the certificate holder’s manual.
3) Ensure equipment tare weights, such as dollies, slave frames,
containers, and carts, are known and subtracted from the total weight to calculate the cargo weight.
4) Ensure the positioning of appropriate ground equipment is
in accordance with the certificate holder’s manual.
5) Ensure the load sheets, signed load manifest, and/or load
schematic are properly executed.
6) Ensure that hazmat, and/or special cargo load schematic information, or manual
reference is relayed to the crew. Refer to Title 49 of the Code of Federal Regulations (49 CFR) part 175 and AC
7) Observe general safety procedures used during cargo offloading
operations, especially at night, for use of lighting, reflective clothing, flashlights, and wands.
8) Ensure appropriate/applicable personnel authorized by the certificate
holder are trained, qualified, and authorized in accordance with the certificate holder’s WBP.
a) During operations at remote sites, a person trained and authorized by
the company to supervise cargo loading operations must provide oversight for
the cargo loading. The use of local personnel at these sites for loading cargo
does not require certificate holder-specific training. All cargo loading operations,
when using untrained personnel, must be directly supervised during the loading
by a person trained in the certificate holder cargo loading and securing procedures.
The certificate holder designee ensures, and becomes responsible for, all certificate
holder loading policy and procedures.
b) A flightcrew member shall not perform this duty unless properly trained
and authorized by the certificate holder in the duties associated with the loading of cargo.
NOTE: The certificate holder should not use the provisions in the above
for routine operations or frequently transited stations. The provision’s intent
provides flexibility for supplemental operations considered infrequent or one-time airlift events.
I. Transport of Special Cargo. Certificate holders should have
processes, procedures, and controls in place when transporting special cargo,
including implementing a SCAF to help identify special cargo, evaluate special
cargo risks, and develop a plan to ensure a safe flight using the aircraft WBM.
Special cargo requires special procedures for acceptance, handling, loading,
and restraint. ULDs not fully restrained by the aircraft CLS (pallet locks and
side rails) should be considered a special cargo load. An example includes any
time restraining devices (not nets) are directly attached to the aircraft structure.
Based on certificate holder procedures:
1) Ensure the SCAF participants are trained, qualified, and authorized to perform SCAFs.
2) Ensure the special cargo is evaluated for transport.
3) Ensure the special cargo is properly restrained (e.g., has
the appropriate quantity and types of restraint, shoring, and arrangement).
4) Ensure load schematic is constructed and executed for special cargo.
5) Ensure load schematic and any necessary instructions are available
to those personnel involved with or responsible for the loading and securing
of cargo during cargo loading.
6) Ensure the load schematic is retained with the load manifest.
J. Hazmat. The surveillance of hazmat handling is not the primary
function of the Flight Standards Service; however, to carry out their 14 CFR
responsibilities, ASIs must be familiar with the 49 CFR regulations and the
certificate holder’s hazmat programs, including their approved training. If
ASIs witness or suspect irregularities regarding hazmat, they should immediately
contact the regional hazmat branch manager through the ROC. The hazmat branch
manager will investigate all hazmat issues. Refer to
NOTE: Corrosion and structural damage may occur by improper handling of some hazmat.
1) Inquire about proper training for loaders, load supervisors,
and personnel involved in ULD buildup in hazmat recognition.
2) Inquire about proper training in hazmat recognition for maintenance
personnel involved with the movement of COMAT.
3) Ensure proper loading and marking of hazmat. The ASI should
contact the CHDO and the regional hazmat branch manager after noting discrepancies in the handling of hazmat.
4) Inquire about procedures for pilot notification of the amount and location of hazmat.
5) Look for signs of undeclared hazmat (e.g., no shipping papers,
marks, labeling, or emergency response information) or release of hazmat into the environment.
6) Inquire about safety procedures and equipment availability
in case of a hazmat accident, such as a spill (e.g., mercury spill kit, emergency equipment).
K. Civil Reserve Air Fleet (CRAF). A significant number of U.S.
air carriers participate in the Department of Defense (DOD) CRAF program. The
DOD established this program to provide a rapid, organized system to augment
the air lift capability of DOD aircraft during emergency situations.
1) If the operation involves the CRAF program with the Air Force
(AF) Air Mobility Command (AMC), the ASI should ensure the following:
• Title 14 CFR regulations are followed;
• Special cargo procedures, if applicable, are followed;
• Cargo compartment reconfiguration changes are documented in the
maintenance log for informational purposes only;
• All personnel involved with cargo functions are trained, qualified,
and authorized; and
• Cargo weigh scales are calibrated and periodically and functionally
checked for accuracy.
2) Unless granted a deviation by the Administrator under 14 CFR part
all operations supporting the DOD are considered commercial airlift
operations and conducted under applicable 14 CFR regulations.
3) Ensure when military ULDs (pallet and net combinations) are used, they are authorized
by the appropriate TC WBM or STC W&B supplement.
L. Carriage of Passengers Specified in §§
Although some in the industry refer to the persons listed in §§
“supernumeraries,” they are defined in 14 CFR part
of “All-cargo operation” as passengers. Per §
“All-cargo operation means any operation for compensation or hire that is other than a passenger-carrying operation or,
if passengers are carried, they are only those specified in §
121.583(a) or §
135.85 of this chapter.”
1) Inspect the passenger cabin (if equipped) for proper equipment, condition, and security.
2) Ensure the proper installation of emergency equipment and
that each item has an inspection tag affixed.
3) Ensure that escape devices, such as slides, ropes, or descent
devices, are serviceable per the certificate holder’s manual.
4) Ensure proper placarding of the passenger cabin for emergency exit.
5) Ensure that passenger to flight deck communications is serviceable.
6) Inspect the galley area (if installed) for condition and security.
6-272 INSPECTION RESULTS.
A. Common Discrepancies. The ASI must accomplish this inspection without
interfering with the ground time limitations unless safety of flight becomes
an issue. The following items, which are common discrepancies, may cause scheduling
delays if found during a ramp inspection.
• Improper load manifest,
• ULDs are not Airworthy,
• Damage to aircraft loading system,
• Damage to the aircraft,
• Improper positioning of ground equipment,
• Inadequate training,
• Signs of undeclared hazmat, and
• Any other unusual certificate holder activity.
B. Corrective Action. The ASI must bring all noted discrepancies
to the attention of appropriate personnel immediately (including the CHDO) to
allow the certificate holder the opportunity to take corrective action without
interrupting the flight schedule. The ASI must verify that all corrective maintenance
actions taken regarding maintenance discrepancies were in accordance with the
requirements of the certificate holder’s maintenance procedures manual. It is
important to reemphasize that any suspected or known hazmat issues must be reported
to the nearest FAA hazmat branch manager (through the appropriate ROC) for investigation and disposition.
6-273 PREREQUISITES AND COORDINATION REQUIREMENTS.
• Knowledge of the regulatory requirements of parts
135, as applicable.
• Successful completion of the Air Cargo Operations Course 21000056.
• Experience working with similar type aircraft.
• This task may require coordination between Airworthiness and Operations ASIs.
• Geographic units should coordinate with the CHDO.
6-274 REFERENCES, FORMS, AND JOB AIDS.
A. References (current editions):
• Title 14 CFR Parts
• Title 49 CFR Parts 171, 172, 173, and 175.
Transport Airplane Cabin Interiors Crashworthiness Handbook.
Transport Category Airplanes Modified for Cargo Service.
Aircraft Weight and Balance Control.
120-85, Air Cargo Operations.
• Certificate Holder’s Applicable Cargo Procedures Manual.
• Volume 3, Chapter 47, Section 1,
Safety Assurance System: Evaluating a Certificate
Holder/Applicant’s Weight and Balance Program; Section 2, Safety Assurance System:
Evaluating a Certificate Holder/Applicant’s Weight and Balance Program (Operations);
and Section 3, Safety Assurance System: Evaluating a Certificate Holder/Applicant’s
Weight and Balance Program (Airworthiness) (for additional information regarding
surveillance of cargo operations and W&B procedures).
• Volume 10, Safety Assurance System Policy and Procedures.
B. Forms. None.
C. Job Aids. None.
A. Prepare for the Inspection.
1) Review the certificate holder’s flight schedule, select the
flight to be inspected, and note the type of operation (cargo or passenger).
Make certain the selected flight has adequate ground time so that the inspection
can be accomplished without schedule delays.
2) Determine if any recent problem areas have been identified for that type of aircraft.
B. Interview Flightcrew and/or Loading Supervisor. Introduce
yourself to the flightcrew and/or loading supervisor, as appropriate, and describe
the purpose and scope of the inspection. Record flightcrew information as required
for entry into the PTRS or SAS DCT (as applicable).
C. Inspect Aircraft Maintenance Records with Emphasis on Cargo-Related Equipment.
1) Ensure that all open discrepancies from the previous flight
are addressed per the certificate holder’s manual, prior to departure of the aircraft.
2) Review the maintenance records to determine if repetitive
maintenance problems exist, which might indicate a trend.
3) Ensure that all MEL/CDL/NEF items are deferred in accordance
with the provisions of the certificate holder’s approved MEL.
D. Perform Interior Inspection.
1) Perform this inspection, as applicable, in accordance with
Figure 6-18, Interior Inspection Guidelines (located in
Volume 6, Chapter 2, Section 4),
paying particular attention to areas identified in Section 4.
2) Inspectors should plan their ramp inspection so that any inspection of the aircraft’s
interior equipment and furnishings would be conducted either before passengers
are enplaned or after they are deplaned.
E. Examine Maintenance Record Entries. Ensure that the certificate
holder has recorded all discrepancies noted during this inspection. If time
is available, monitor their certificate holder’s corrective actions.
F. Debrief Certificate Holder. Inform the appropriate personnel
of inspection completion. Discuss the discrepancies found during the inspection with appropriate personnel.
G. Analyze Findings. Analyze each finding to determine if the
maintenance-related discrepancies are the result of improper maintenance and/or
missing or inadequate maintenance/inspection procedures.
NOTE: All aircraft ramp inspections must include at least an examination of the aircraft’s
registration, airworthiness certificate, and maintenance logbook.
6-276 TASK OUTCOMES.
A. Complete the PTRS Record. For those not under SAS.
B. Complete the Task. Completion of this task can result in the following:
• Appropriate enforcement action when analysis of the findings discloses improper maintenance.
• Written notification to the certificate holder of the necessary
changes to the manual, when analysis of the findings discloses missing or inadequate maintenance/inspection procedures.
• Communication with the CHDO by the geographic unit finding discrepancies.
• Hazmat issues reported to the regional hazmat branch manager.
C. Follow SAS Guidance. See Volume 10 guidance for Module 4,
Data Collection and Data Reporting; along with Module 5, Analysis, Assessment,
and Action (AAA), for PIs. Outcome tracking may be via the Action Item Tracking Tool (AITT).
D. Document the Task. File all supporting paperwork in the certificate holder’s office file.
6-277 FUTURE ACTIVITIES. Based on inspection findings, determine
if increased surveillance, additional enforcement, other job tasks, and/or additional
coordination between the CHDO and geographic units is required for noncompliant
certificate holders to regain compliance.
RESERVED. Paragraphs 6-278 through 6-292.