{"id":"F2005B00989","name":"Civil Aviation Amendment Order (No. R16) 2004 - Civil Aviation Order 20.16.2 - Air service operations - Loading - General (02/12/2004)","slug":"civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":32388,"registerId":"commonwealth-F2005B00989-current","compilationNumber":null,"startDate":"2026-04-01","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Civil Aviation Amendment Order (No. R16) 2004 - Civil Aviation Order 20.16.2 - Air service operations - Loading - General (02/12/2004)","content":"Civil Aviation Amendment Order\n\n(No. R16) 2004\n\nI, WILLIAM BRUCE BYRON, Director of Aviation Safety, on behalf of CASA, issue the following Civil Aviation Order under subregulation 244 (2) of the Civil Aviation Regulations 1988.\n\n\\[Signed Bruce Byron\\]\n\nBruce Byron\n\nDirector of Aviation Safety and\n\nChief Executive Officer\n\n2 December 2004\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n1 Name of Order\n\nThis Order is the Civil Aviation Amendment Order (No. R16) 2004.\n\n2 Commencement\n\nThis Order commences on gazettal.\n\n3 Replacement of section 20.16.2 of the Civil Aviation Orders\n\nSection 20.16.2 of the Civil Aviation Orders is omitted and a new section substituted as set out in Schedule 1.\n\nSchedule 1 Substitution of section 20.16.2 of the Civil Aviation Orders\n\nSECTION 20.16.2\n\nAIR SERVICE OPERATIONS — LOADING — GENERAL\n\n1 APPLICATION\n\nThis section applies to all Australian aircraft.\n\n2 DEFINITIONS\n\nCargo means things other than persons carried in an aircraft.\n\n3 RESTRAINT\n\n3.1 Cargo stowed on or above the floor line of compartments occupied by persons and behind any person shall be restrained so as to prevent any article from moving under the maximum accelerations to be expected in flight and in an emergency alighting such as a ditching.\n\n3.2 Cargo stowed in areas other than those covered by paragraph 3.1 shall be restrained so as to prevent any article from moving under the maximum accelerations to be expected in flight, in a heavy landing, and in a ground loop.\n\n3.3 The strength of the restraint provisions for compliance with paragraphs 3.1 and 3.2 shall be not less than that approved or accepted by CASA for a particular type of aircraft.\n\n3.4 Cargo restraint equipment shall be flame resistant.\n\n4 STOWAGE\n\n4.1 Cargo shall not be carried in any place where it may damage, obstruct or cause failure of controls, electrical wiring, pipe lines and items of aircraft equipment, essential to the safe operation of the aircraft, unless such items are adequately protected during loading and handling of cargo and during the operation of the aircraft.\n\n4.2 Cargo may obstruct an emergency exit where sufficient other emergency exits are available for the number of occupants carried in accordance with the tables in Part 105 and any cargo aft of these exits is restrained in accordance with paragraph 3.1.\n\n4.2.1 Whenever an emergency exit is obstructed, the emergency exit sign for that exit shall be covered or otherwise made ineffective.\n\n4.2.1 Whenever an emergency exit is obstructed, the emergency exit sign for that exit shall be covered or otherwise made ineffective.\n\n4.3 Cargo shall not obstruct an aisle in accordance with subsection 7 of section 20.16.3.\n\n4.4 Where cargo is carried in an aircraft (other than a single pilot aircraft) in which an aisle is not required by subsection 7 of section 20.16.3, the cargo shall be stowed:\n\n    (a) so as to ensure that crew members are able to move freely through the aircraft in a substantially upright position; or\n    (b) so as to provide access through the aircraft for the crew members in such other manner as may be approved by CASA.\n\n5 CARGO ON A PASSENGER SEAT\n\n5.1 Cargo may be carried on an unoccupied passenger seat. The weight of such cargo shall be evenly distributed over the squab, and shall not exceed 77 kg, except where a seat loading scheme permitting a greater weight is specifically approved by CASA.\n\n5.2 Cargo carried on a passenger seat shall be restrained in accordance with the requirements of paragraph 3.\n\n6 CARGO IN PILOT COMPARTMENT\n\n6.1 Carriage of cargo in pilot compartments is prohibited except that in aircraft having a maximum take-off weight not more than 5 700 kg, cargo may be carried on an unoccupied control seat.\n\n6.2 Cargo carried on a control seat shall not exceed 77 kg in weight unless a seat loading scheme which would permit a greater weight is specifically approved by CASA.\n\n6.3 Cargo shall not be carried on a control seat if the cargo or means of restraint would interfere with the operation of the aircraft.\n\n6.3.1 When cargo is carried on a control seat, the flight controls relevant to that seat shall be removed where they have been designed for easy removal and the remaining fittings protected so as to prevent interference by the cargo to the operation of the aircraft.\n\n6.4 Cargo carried on a control seat shall be restrained in accordance with the requirements of subsection 3.\n\n7 PLACARDING\n\nCargo shall only be carried in a place or compartment placarded with loading instructions.","sortOrder":0}],"analysis":{"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"This instrument expressly substitutes section 20.16.2 with the text in Schedule 1, so it replaces the previous regulatory text and therefore alters the legal requirements insofar as the new text differs. The substituted section applies to all Australian aircraft and defines restraint, stowage, seat and pilot‑compartment rules, flame‑resistance and placarding. The Order itself does not provide a before‑and‑after comparison, so exact policy deltas cannot be determined from this document alone."},"complexity_factors":["Cross-references to other provisions and external tables (e.g. Part 105; subsection 7 of section 20.16.3) increase interpretive steps required to apply rules.","CASA approval or acceptance creates administrative discretion and case-by-case variability (see 3.3; 5.1; 6.2; 4.4(b)).","Different performance requirements depending on cargo location (3.1 vs 3.2) require technical assessment of expected accelerations and restraint strength.","Technical requirements (flame-resistant equipment in 3.4; strength not less than approved in 3.3) impose equipment and certification costs on operators.","Specific operational limits and exceptions (77 kg seat limit in 5.1 and 6.2; single‑pilot aircraft exception in 4.4) create multiple conditional rules to track.","Pilot‑compartment rules (6.1–6.3.1) impose design/handling requirements, including removal/protection of controls where cargo is carried on a control seat.","Placarding requirement (7) adds a compliance and record/label‑keeping burden.","Apparent duplication in the text (duplicate paragraph 4.2.1) may cause minor drafting ambiguity."],"plain_english_summary":"This Order replaces CAO 20.16.2 and sets mandatory loading rules for all Australian aircraft: how cargo must be restrained and stowed, limits and restraint requirements for cargo on passenger and pilot seats, flame‑resistant restraint equipment, and placarding. It affects operators, crew, loaders and CASA, which approves seat‑loading schemes and acceptable restraint strengths. The stated aim is to prevent cargo movement and protect controls and emergency exits; mechanically it shifts equipment, handling and approval costs to operators and gives CASA case‑by‑case discretion over standards."},"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"This amendment replaces an existing section (20.16.2) with updated rules about cargo loading. The scope remains focused on the specific technical matter of aircraft loading safety - it has not expanded beyond the original purpose of regulating how cargo is secured and stowed on aircraft."},"complexity_factors":["Short document (approximately 1,000 words)","Only 1 defined term ('Cargo')","Minimal cross-referencing (only references to Part 105 and section 20.16.3 for aisle requirements)","Clear hierarchical structure with numbered sections and subsections","Straightforward conditional logic (if/then statements without nesting)","Specific numerical thresholds (77kg weight limits, 5,700kg aircraft weight) that are easy to identify","Duplicate text in paragraphs 4.2.1 (appears twice identically) suggesting minor drafting error but not complexity"],"plain_english_summary":"This legislation sets safety rules for how cargo (anything carried in an aircraft that isn't a person) must be loaded and secured on Australian aircraft.\n\n**What it does:**\n- **Restraint requirements**: Cargo must be tied down or secured strongly enough to stay put during normal flight, emergency landings, heavy landings, and ground loops (when an aircraft pivots sharply on the ground). The restraint equipment must be flame resistant and meet safety standards approved by CASA (Civil Aviation Safety Authority).\n\n- **Where cargo can go**: Cargo cannot block emergency exits unless there are enough other exits for everyone on board, and any cargo behind blocked exits must be extra-secure. If an exit is blocked, its sign must be covered. Cargo also cannot block aisles or damage essential controls, wiring, or equipment.\n\n- **Cargo on seats**: Cargo can sit on empty passenger seats (up to 77kg, evenly distributed) or on empty pilot seats in small aircraft (under 5,700kg max take-off weight). If cargo goes on a pilot's seat, the flight controls must be removed if possible, and the cargo must be secured.\n\n- **Placarding**: Cargo can only be loaded in areas that have official loading instructions posted.\n\n**Who it affects:** Airlines, charter operators, and anyone loading cargo onto Australian aircraft.\n\n**Why it matters:** Prevents cargo from shifting during flight or emergencies, which could damage controls, block escape routes, or injure passengers and crew."}},"importantCases":[],"_links":{"self":"/api/acts/civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi","history":"/api/acts/civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi/history","analysis":"/api/acts/civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi/analysis","conflicts":"/api/acts/civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi/conflicts","importantCases":"/api/acts/civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi/important-cases","documents":"/api/acts/civil-aviation-amendment-order-no-r16-2004-civil-aviation-order-20-16-2-air-service-operations-loadi/documents"}}