Civil Aviation Order 20.16.1 - Loading - General (02/12/2004)

Approved Loading System - This is the central concept of the Order. Defined as a system prepared by an operator in accordance with CAO 100.7 and approved either by CASA or by the holder of an appropriate and valid Weight Control Authority. It ensures the aircraft is loaded within approved limits (weight and centre of gravity) at all times during flight. The definition does not prescribe format; acceptable types include placards prominently displayed in the aircraft, or documented procedures described in the CASA publication Weight Control of Aircraft (see Note 2 to section 3). The operator must not assume the loading system is approved merely because it exists; formal approval is required.

Load Sheet - Defined as a form recording the weight and disposition of the disposable load together with other pertinent loading information. It is a formal document, not a casual note. The mandatory content is listed in section 5.3(a) to (h). Importantly, the load sheet must be signed by the pilot in command, the co‑pilot, or an Approved Load Controller. The pilot in command or co‑pilot may act as an approved load controller without any special CASA authorisation, meaning they assume the legal responsibilities of that role by default under the Order. The load sheet must be carried in the aircraft; for regular public transport services, a copy must also be retained on the ground at the aerodrome of departure. The operator must retain each load sheet for three months after the relevant flight.

Approved Load Controller - A person nominated by an operator and approved by CASA to control and supervise loading for a particular aircraft. The definition carves out an notable exception: the pilot in command or the co‑pilot may undertake these duties and assume the responsibilities without any special CASA authorisation. This means that for any flight, the flight crew can perform the load controller function without separate paperwork. In practice, this reduces compliance burden for small operators, but it also means the crew must be competent in weight and balance calculations.

Empty weight - Not defined within the Order itself; the definition is imported from subsection 2 of CAO 100.7. The operator must refer to that separate instrument to determine the empty weight of the aircraft for load sheet purposes.

Aerial application operation - Defined by reference to regulation 61.010 of the Civil Aviation Safety Regulations 1998 (CASR 1998). This is a specific exemption from the load sheet requirement for aircraft with MTOW exceeding 5 700 kg while engaged in crop dusting, fire bombing, or similar operations. The exemption applies only to paragraph 5.1 (load sheets); the approved loading system requirement of section 3 still applies.

Supplementary load sheet and standard load reuse - Two exceptions to the general rule that a load sheet must be completed for each flight stage. Supplementary load sheets (paragraph 5.2.1) allow accounting for load changes across multiple stages on the same day without a completely new load sheet; the original sheet is adjusted. Standard load reuse (paragraph 5.2.2) permits use of the same load sheet for consecutive flights from the same aerodrome provided the load does not change and no condition affecting performance changes. These are cost-saving mechanisms, but the operator bears the risk of incorrectly assuming conditions have not changed.

Passenger list - A separate requirement from load sheets, applicable only to charter and regular public transport flights. It must contain only basic information: aircraft registration, passenger names, date, estimated time of departure, and places of embarkation and destination. It must be left at the departure aerodrome; the operator keeps no retention period specified for the passenger list, only for load sheets.

The Order directly imposes duties on two categories of persons: operators and pilots in command. It indirectly affects approved load controllers, co‑pilots, ground staff, and passengers (through the compilation of passenger lists).

Operators - Any entity or individual that operates an Australian aircraft (excluding balloons). This includes scheduled airlines, charter companies, flying schools, private owners who hire pilots, and corporate flight departments. For small operators with light aircraft (MTOW under 5 700 kg and not engaged in regular public transport), the load sheet requirement of section 5 does not apply, but they must still ensure an approved loading system exists under section 3. For a typical private owner of a Cessna 172, this may be as simple as a placard showing load limits, but the operator must have obtained the approved system from CASA or a Weight Control Authority - a process that imposes an upfront cost. For RPT operators (even with small aircraft like a Dash 8 or a single‑engine aircraft on a scheduled route), the full load sheet regime applies regardless of MTOW, because paragraph 5.1 captures all aircraft engaged in regular public transport operations. This means an RPT operator flying a 2 000 kg aircraft must still prepare load sheets. The cost of this paperwork falls disproportionately on smaller RPT operators compared to large airlines, because the fixed cost of developing procedures and training staff is spread over fewer flights.

Pilots in command - Jointly liable with the operator for ensuring the aircraft is loaded in accordance with the approved loading system (section 3) and for ensuring the load sheet is completed (section 5). The pilot in command may also sign the load sheet and act as an approved load controller without separate CASA approval. This places a direct safety and legal obligation on the PIC, who cannot delegate the responsibility away - even if the operator has a dedicated load controller, the PIC must ensure the system is followed and the load sheet is present.

Approved load controllers - Persons nominated and approved by CASA (other than the PIC and co‑pilot) who take on loading duties. Their existence reduces the burden on flight crew, but they must be formally approved, which imposes a regulatory hurdle. For large operators with dedicated dispatch teams, this is routine; for smaller operators, relying on the PIC is simpler.

Aerial application operators - Specifically exempted from load sheets for aircraft over 5 700 kg MTOW, but still subject to the approved loading system requirement. This is a practical concession given the rapid turnaround nature of agricultural flying, but the operator must still maintain an approved loading system.

Passengers - Indirectly affected because their names must be collected for charter and RPT flights. This creates a privacy cost (the operator retains passenger names at the departure aerodrome), although there is no specified retention period for the passenger list. The list is not required to be carried in the aircraft, only left at the departure point.

CASA - The primary enforcer and approver. CASA must approve loading systems and load controllers, audit compliance, and take enforcement action for breaches. The Order does not prescribe any cost‑recovery mechanism for approval; the administrative cost falls on CASA’s budget, and ultimately on the aviation industry through regulatory fees.

The Order exempts balloons entirely. No provisions apply. This is a meaningful carve‑out that reflects the different loading characteristics of balloons (no discrete compartments, no fuel loading), but it also means balloon operators have no loading documentation obligations under this Order.

Operator and pilot in command - joint duty for loading system (section 3). Both must ensure the aircraft is loaded in accordance with the approved loading system at all times. The duty is continuous throughout flight, not merely at departure. The operator cannot shift this obligation entirely onto ground staff; the pilot in command remains personally liable even if a load controller prepares the aircraft.

Duty to complete and use load sheets (section 5.2). The operator and pilot in command must ensure a load sheet is completed prior to departure for each flight stage of covered aircraft (MTOW > 5 700 kg or engaged in RPT). The duty applies to each stage; however, supplementary load sheets (for multi‑stage flights on the same day) and standard load reuse (consecutive flights same day, same aerodrome, no change) provide limited flexibility. The operator must assess whether conditions have changed for the standard load reuse - this involves an element of discretion that carries risk if the operator gets it wrong.

Duty to include mandatory content (section 5.3). The load sheet must contain eight specific items. The most operationally significant is the requirement to provide evidence that the centre of gravity is within approved limits (paragraph (g)). This is not a simple box‑tick; the operator must perform or calculate the CG position and record it. Paragraph (h) requires the maximum allowable weight for the flight having regard to section 20.7.0 of CAR 1988 (which deals with performance limitations). This cross‑reference means the load sheet effectively requires the pilot to have consulted the aircraft performance manual.

Right of PIC and co‑pilot to act as approved load controller without CASA authorisation. The definition of Approved Load Controller expressly allows the pilot in command or co‑pilot to undertake load controller duties without special authorisation. This is a significant flexibility: the flight crew can sign the load sheet as load controller without needing a separate approval. However, it also means they assume the legal responsibilities of a load controller (control and supervision of aircraft loading), and if they sign a load sheet that is incorrect, they are directly liable.

Duty to carry load sheet and retain ground copy (section 5.4). The load sheet must be in the aircraft for every flight stage. For RPT services only, a copy must be retained on the ground at the departure aerodrome. RPT operators must have a ground‑based copy. The operator must also retain the load sheet for three months after the flight (section 5.4.1). This retention obligation creates storage costs (physical or digital) and compliance risk if sheets are lost.

Duty to compile passenger list (section 7). For charter and RPT flights carrying passengers, the operator (or their representative) must compile a list with specified details and leave it at the departure aerodrome. There is no explicit obligation to retain that list; but leaving it at the aerodrome implies the aerodrome operator (or ground handling agent) must hold it. The list does not need to be carried in the aircraft. This requirement is separate from load sheet obligations and has no specified exemption for small aircraft.

No duty for load sheets for balloons or for aerial application operations. These exemption rights are not discretionary; if the operator qualifies, they are relieved of load sheet obligations. However, the approved loading system duty still applies.

No right of appeal or review in the Order. The instrument does not provide a mechanism for challenging CASA’s refusal to approve a loading system or a load controller. Such rights would arise under the Administrative Appeals Tribunal Act 1975 or the Civil Aviation Act 1988, not within this Order.

The Order itself does not prescribe specific penalties. It is made under the Civil Aviation Regulations 1988, and breaches of a Civil Aviation Order are offences under the CAR 1988 or the Civil Aviation Act 1988. The relevant penalty provisions are not reproduced in this instrument, so the reader must refer to the parent legislation.

Under the Civil Aviation Regulations 1988, regulation 235 (which provides the head of power for this Order) and other general penalty provisions apply. Typically, a contravention of a Civil Aviation Order may attract a maximum penalty of 50 penalty units for an individual or 250 for a body corporate (currently one penalty unit is $313 as of 2025, so an individual could face up to $15,650 and a corporation up to $78,250). These are criminal penalties, not civil fines.

CASA also has the power to issue infringement notices (on‑the‑spot fines) for certain breaches, and to vary, suspend or cancel an Air Operator’s Certificate (AOC) under section 28BC of the Civil Aviation Act 1988. A pattern of loading non‑compliance could threaten the operator’s entire business. The practical risk is therefore not only monetary penalty but loss of the right to operate.

Enforcement is risk‑based. A missing load sheet on a light aircraft RPT flight may result in an infringement notice; a systemic failure to maintain an approved loading system on a large passenger aircraft could lead to AOC suspension and prosecution. The Order does not set a hierarchy of seriousness, but the consequences depend on the safety risk and CASA policy.

The load sheet and passenger list requirements create documentary evidence that CASA inspectors can audit. Non‑retention of load sheets for three months is itself a breach (section 5.4.1) independent of any loading error. An operator who loses load sheets can be penalised even if the aircraft was correctly loaded.

The Order does not contain any civil penalty provisions, safe harbour, or due diligence defence. Liability is strict: if the aircraft is not loaded in accordance with the approved loading system, both operator and pilot in command have breached section 3, regardless of intention or reasonable precautions.

Criminal enforcement requires proof beyond reasonable doubt. But the standard for AOC action is lower - CASA can take administrative action on the balance of probabilities. Enforcement of the Order is therefore likely to occur through administrative means first, with criminal prosecution reserved for serious or repeated breaches.

There is no provision for self‑reporting or voluntary disclosure in the Order. Operators who discover a breach during an internal audit cannot rely on the Order for leniency; they must still comply with any mandatory reporting obligations under the Civil Aviation Act.

The Order sits within a web of civil aviation legislation and cannot be read in isolation.

Civil Aviation Regulations 1988 (CAR 1988). The Order is made under regulations 5 and 235(7) of CAR 1988. It is one of many Civil Aviation Orders that supplement the CAR. Section 5.3(h) of the Order explicitly cross‑references section 20.7.0 of CAR 1988 to determine maximum allowable weight for the flight. This means the load sheet must incorporate performance limitations from the CAR, which in turn refer to aircraft flight manuals and airworthiness standards.

Civil Aviation Order 100.7 (Weight Control of Aircraft). The concepts of Approved Loading System and empty weight are defined by reference to CAO 100.7. Any operator subject to CAO 20.16.1 must already have a loading system complying with CAO 100.7. CAO 100.7 is the parent regime; CAO 20.16.1 adds load sheet and passenger list obligations on top. The two orders must be read together: an approved loading system under CAO 100.7 is a prerequisite for compliance with section 3 of this Order.

Civil Aviation Safety Regulations 1998 (CASR 1998). The definition of aerial application operation is imported from regulation 61.010 of CASR 1998. This is significant because CASR 1998 is gradually replacing CAR 1988. The Order remains in force under CAR 1988, but its definitions now point to the newer CASR regime, creating a hybrid. Operators must understand both sets of regulations.

Civil Aviation Act 1988. The Act gives CASA the power to make Civil Aviation Orders and to enforce them. It also provides the overarching safety objective and enforcement tools (AOC suspension, directions). The Act is not directly referenced in the Order, but it is the legal foundation for the entire regime.

Part 91, 121, 135 of CASR 1998. Although not mentioned, modern air operations under CASR 1998 may impose broader loading and weight requirements. For example, Part 121 (large aeroplanes) and Part 135 (small aeroplanes) contain their own loading rules. CAO 20.16.1 may overlap or be displaced by the specific CASR provisions. Operators subject to CASR Parts 121 or 135 should check whether this Order still applies to them or whether the CASR provisions supersede it. The transitional provisions in the 2014 amending instrument (Table A) state that the Civil Aviation Orders apply to a continued authorisation as if it were the equivalent new authorisation. This suggests that for operations transitioning to CASR, the Order may continue to apply until full transition.

Other Civil Aviation Orders. The Order does not exist in a vacuum. Adjacent orders may deal with fuelling, cargo restraint, dangerous goods, and crew duty. Operators should cross‑reference CAO 20.7 (aircraft performance) and CAO 20.10 (fuel and oil) among others.

Privacy legislation. The passenger list requirement (section 7) involves collecting and leaving personal information (names) at an aerodrome. This may interact with the Privacy Act 1988 if the operator is a business with turnover above the threshold. The Order does not provide any privacy safeguards; the operator must independently ensure compliance with Australian privacy law.

Occupational health and safety laws. Loading aircraft involves manual handling, lifting equipment, and ground safety. While not mentioned, an employer must comply with state or territory WHS laws. The Order does not prescribe safe loading procedures; it only mandates documentation.

No interaction with the Corporations Act or contract law. The Order does not affect commercial agreements between operators and cargo shippers or passengers, except that the load sheet may be used as evidence in a dispute.

The compilation of the Order reflects amendments up to 30 June 2018. The Order was first made in 2004 as CAO 2004 No. R15, notified on 8 December 2004 and commencing that day. It was subsequently amended by three instruments:

1. CAO 20.16.1 2007 No. 1 - registered on FRLI on 20 December 2007, commencing 21 December 2007. This instrument amended subsection 1, subsection 2, subsection 3 Note 1, and subsection 5 of the Order. The nature of the changes is not specified in the source, but the table indicates these provisions were amended (not repealed or substituted).

2. CAO (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1) - registered 29 August 2014, commencing 1 September 2014. This was a broad instrument that repealed and amended multiple Civil Aviation Orders to align with changes to flight crew licensing under CASR 1998. In relation to this Order, it amended subsection 2 (definitions), subsection 3 Note 1, and subsection 5. It also repealed subsection 6 (which is no longer in the Order). The instrument included transitional provisions (Table A) that define "continued authorisation" and "new authorisation" from CASR 1998 and state that the Civil Aviation Orders apply to a continued authorisation as if it were the equivalent new authorisation. This preserves the Order’s effect for operators holding transitional authorisations.

3. CAO 20.16.1 Amendment Instrument 2018 (No. 1) - registered 29 June 2018, commencing 30 June 2018. This instrument amended subsection 2, subsection 3 Note 1, subsection 5, repealed subsection 6, and amended subsection 7. The repeal of subsection 6 means that a previous requirement (likely relating to fuelling or something else) was removed entirely. The 2018 amendments also likely updated definitions and references.

The Table of Amendments shows that subsection 6 was repealed by the 2018 instrument. Section 20.16.1 originally contained a subsection 6 that is no longer part of the legislation. The current Order (as compiled) has only sections 1, 2, 3, 5, and 7. Section 4 was never present in this compilation. The 2007 instrument repealed and substituted subsections 1, 2, 3 Note 1, and 5. The 2014 instrument amended those provisions further. The 2018 instrument again amended them and repealed subsection 6.

The changes over time show a gradual simplification: the removal of subsection 6 suggests a reduction in prescriptive loading rules. The definitions have been refined to point to CASR rather than older references. However, the core requirements (loading system, load sheet, passenger list) have remained stable since 2004.

The instrument does not contain any regulatory impact statement or explanatory memorandum in the compiled text. The policy rationale is not stated. Amendment history is limited to the dates and effects.

The text of the Order does not reference any litigation, and no cases are cited. It is a legislative instrument, not a judgment. There is no publicly apparent record of significant court proceedings directly involving this specific Order. However, loading errors are a common factor in aviation accidents and incidents, and any litigation arising from such events would likely involve broader safety regulations rather than a challenge to this Order itself.

That said, enforcement actions by CASA under this Order (e.g., for failure to complete load sheets or maintain an approved loading system) could be appealed to the Administrative Appeals Tribunal or challenged in the Federal Court on judicial review grounds, but no such cases are recorded in the source. The Civil Aviation Act 1988 provides for merits review of certain CASA decisions (e.g., refusal to approve a loading system), but the Order does not create private rights of action. Any litigation would be between CASA and the operator/pilot.

The absence of litigation may indicate that the Order is either well‑understood and generally complied with, or that enforcement is done through administrative means (warnings, infringement notices) without court action. It does not mean the Order is uncontroversial; simply that its detailed technical nature makes it a poor candidate for precedent‑setting litigation.

Practitioners should note that if a load sheet is found to be false or misleading, the operator could face charges under the Criminal Code (Cth) for providing false information to a Commonwealth official, separate from aviation offences. That is not litigation under the Order itself, but a related criminal law.

The Order is not a contractual document, so it would not typically be litigated in commercial disputes between an operator and a cargo shipper. If a load sheet identifies incorrect weight, and that causes damage to property or injury, the aggrieved party might sue for negligence or breach of duty of care. The non‑compliance with the Order would be evidence of breach of a statutory duty, but not a cause of action in itself. Australia does not generally permit a private right of action for breach of a statutory duty in this context.

Thus, the litigation history is effectively a blank slate. The Order’s significance lies in its daily operational impact, not in courtroom battles.

Several provisions in the Order can trap unwary operators or pilots.

The approved loading system is required for all aircraft except balloons, even if the operator thinks it is impossible to load incorrectly. Section 3 requires compliance with the system where one exists, and Note 1 makes clear that if an aircraft cannot possibly be loaded outside CG limits, it still must have a loading system under CAO 100.7 unless that fact is shown. An operator cannot simply assume an exemption. The demonstration burden is on the operator, and CASA must be satisfied. Many light aircraft owners may be unaware of this requirement, assuming that a simple placard is sufficient. A placard may be acceptable (Note 2), but it must be part of an approved system.

Load sheet exemptions are narrower than they appear. Paragraph 5.1.1 exempts aerial application operations from the load sheet requirement for aircraft over 5,700 kg MTOW. But this does not exempt the aircraft from the loading system requirement, nor does it exempt the same aircraft when conducting other types of flying. The exemption is activity‑specific. Also, the exemption does not apply to aircraft engaged in RPT - even if an RPT operator also does aerial application, the RPT flights still require load sheets.

Supplementary load sheets and standard load reuse must be used with caution. Paragraph 5.2.1 permits a supplementary load sheet for multi‑stage flights based on the initial loading, but only if changes are accounted for. If a change is missed or inaccurately documented, the load sheet is invalid. Paragraph 5.2.2 allows reuse of a load sheet for consecutive flights only if there is no change in any condition that could adversely affect aircraft performance. This is a subjective test: a minor change in ambient temperature might affect take‑off performance, and if the operator does not reassess, they are in breach. The condition is not limited to load changes; weather, runway conditions, NOTAMs all count.

The pilot in command is always on the hook. Even if the operator has a dedicated approved load controller, the pilot in command must ensure the load sheet is completed and the aircraft is loaded per the system. The PIC cannot rely on the load controller’s assurance and walk away. If the load controller makes an error, the PIC shares responsibility. The definition of Approved Load Controller allows the PIC to act as load controller, but that does not reduce the PIC’s overall duty; it only adds the specific responsibilities of the controller.

Retention period of three months for load sheets starts from the flight date, not the end of financial year. An operator who discards load sheets after a routine internal cleanup may be in breach. The requirement applies regardless of whether the flight was eventful. CASA can audit load sheets years later for flights within the previous three months. Digital storage is permitted, but the operator must be able to produce the load sheet on request.

Passenger list must be left at the departure aerodrome, not carried. This is an interesting asymmetry: the load sheet is carried in the aircraft, the passenger list is left on the ground. If the aircraft is lost, the passenger list is at the departure point, which helps authorities identify victims. But for non‑RPT charter flights, there is no requirement to carry a passenger list; if a charter operator does not have a ground agent, they still must find a way to leave the list at the aerodrome (e.g., with the FBO or airport manager). Failure to do so is a breach.

No grandfathering for existing loading systems that are not approved. The transition provisions in the 2014 instrument only deal with continued authorisations under CASR. The Order itself requires all loading systems to be approved. An operator using a legacy system developed before the Order was made must ensure it complies and has been approved. If the system was never formally approved by CASA or a Weight Control Authority, it is not an "Approved Loading System".

The Order applies to "all Australian aircraft" but does not define "Australian aircraft". That definition is in the Civil Aviation Regulations 1988 (regulation 2 or 3). Generally, an Australian aircraft is one registered in Australia or operated by an Australian operator. The operator must ascertain the scope.

The load sheet must include "evidence that the centre of gravity is within the approved limits". This is not a simple statement; it requires a calculation or reference to a loading chart. If the load sheet merely states "within limits" without supporting data, it may not comply with paragraph (g). The evidence could be a weight and balance calculation or a computer output. An operator using a simplified system must ensure the form captures the CG evidence.

No exemption for emergency medical services or other time‑critical operations. The Order contains no waiver for life‑saving flights. A Medevac operator must still complete a load sheet before departure. In practice, this may be done quickly, but there is no formal exemption. The only concession is the standard load reuse provision, which is not designed for emergencies.

The passenger list requirement has no retention period specified. Unlike load sheets, the operator does not need to retain a copy. But the list must be left at the departure aerodrome. If the aerodrome is unattended, the operator may need to secure an agreement with the aerodrome operator to accept the list. Failure to leave the list is a breach; there is no requirement for the aerodrome to keep it, but the operator has discharged the duty by leaving it.

The Order carves out balloons entirely, but does not exempt other types of aircraft such as gliders, gyrocopters, or airships. Gliders are "aircraft" and must comply with the approved loading system requirement. Balloons are the only explicit exemption. That seems inconsistent with the Note to section 3 which mentions balloons being subject to a separate weight control requirement? Actually, the Note only says CAO 100.7 requires all aircraft except balloons to have a loading system. So balloons are excluded from CAO 100.7, and thus from this Order. Gliders are not excluded, but their loading systems may be simple.

The Approved Load Controller definition allows the pilot in command or co‑pilot to act without special authorisation, but they must still be "approved" by CASA? The wording states they may undertake the duties without special authorisation by CASA. That means they are deemed approved for that role by virtue of the definition. But they are not "Approved Load Controllers" in the sense of being on a CASA list; they simply assume the responsibilities. The operator does not need to nominate them. However, if someone else acts as load controller, they need to be approved by CASA. This creates a two‑tier system: flight crew load controllers are automatic; ground load controllers need formal approval.

Compliance requires a systematic approach across three regulatory streams: the approved loading system, load sheets, and passenger lists. The following steps are recommended for an operator subject to the full regime.

Step 1 - Determine applicability. Confirm the aircraft is not a balloon. If it is, the Order does not apply. For all other Australian aircraft, proceed. Determine whether the aircraft has an MTOW exceeding 5,700 kg or is engaged in regular public transport operations. If neither, then the load sheet requirement (section 5) does not apply, but the approved loading system (section 3) does. For RPT operators, even small aircraft require load sheets. For aerial application operators, note the load sheet exemption for heavy aircraft (s5.1.1), but still comply with section 3.

Step 2 - Establish an approved loading system. The operator must have a system that complies with CAO 100.7 and has been approved by CASA or a holder of a Weight Control Authority. The system may be a set of placards, a manual, or a computer program. The operator must apply for approval unless already holding a Weight Control Authority that permits self‑approval. For simple aircraft, a prominently placed placard with load limits and moment or weight indices may suffice, but the placard must be approved. The operator should keep a copy of the approval documentation. The system must cover all loading conditions the aircraft may encounter (passengers, cargo, fuel variations).

Step 3 - Design load sheet forms. For aircraft that require load sheets, design a form that includes all items listed in section 5.3(a) to (h). The form must have fields for: pilot in command name, date, aircraft type and registration, departure and destination aerodromes, empty weight (from CAO 100.7), weights of occupants, cargo, removable equipment, fuel and consumables, loaded weight with evidence of CG within limits, and maximum allowable weight per s20.7.0. The form should include a signature block for the pilot in command, co‑pilot, or approved load controller. The evidence of CG within limits can be a checkbox or a declared value, but there must be a calculation methodology stated.

Step 4 - Develop procedures for load sheet completion. Establish when to use supplementary load sheets (multiple stages same day) and standard load reuse (consecutive flights same day same aerodrome). The procedures must define what constitutes a change in condition that could adversely affect performance (e.g., temperature change >5°C, runway change, different take‑off flap setting, or different cargo weight). The decision to reuse a load sheet should be documented in a checklist. Ensure that for standard load reuse, the first flight’s load sheet is retained and annotated for the subsequent flights.

Step 5 - Train personnel. Train pilots in command, co‑pilots, and any designated load controllers on the loading system and load sheet requirements. Emphasise that the PIC has non‑delegable responsibility to verify the load sheet before departure. Train ground staff on passenger list compilation and where to leave it (departure aerodrome). For RPT operations, ensure a reliable method for leaving a copy of the load sheet on the ground (e.g., email to the airport manager, or physical copy at the check‑in desk). The training should include the consequences of non‑compliance (penalties, AOC jeopardy).

Step 6 - Implement record‑keeping. All load sheets must be retained for three months from the flight date. Implement a system (digital or physical) to store and retrieve load sheets. For RPT, ensure the ground copy is distinct from the air copy. The operator does not need to retain passenger lists beyond leaving them at the aerodrome, but it is prudent to keep a digital record to prove compliance in an audit. The retention system must be secure and searchable.

Step 7 - Compile passenger lists. For each charter or RPT flight carrying passengers, before departure, compile a list with: aircraft registration, passenger names, date, estimated time of departure, places of embarkation and destination. Leave a copy at the departure aerodrome. Ensure the aerodrome operator or handling agent accepts the list and can provide it to authorities if needed. If the departure point is an unattended airstrip, leave the list in an agreed secure location or with the last person on the ground.

Step 8 - Conduct regular internal audits. Periodically check that loading system approvals are current, that load sheets are being completed correctly, and that the three‑month retention period is being observed. Audit a sample of flights to verify that CG evidence is credible and that maximum allowable weights are correct. Correct any non‑compliance and retrain staff. Also audit that the passenger list is being left at the correct place.

Step 9 - Stay updated on regulatory changes. The Order has been amended several times. The operator must monitor CASA’s website for further amendments, especially as CASR 1998 is phased in. The definitions and load sheet requirements may be replaced by CASR Parts 91, 121, or 135. The Order does not sunset, but it may be repealed upon full transition to CASR.

Step 10 - Engage a weight control authority if needed. For operators without a CASA‑approved internal weight control authority, consider obtaining one to self‑approve loading systems and load controllers. This reduces reliance on CASA for day‑to‑day approvals and can speed up operations. The cost of maintaining a weight control authority may be justified for larger operators with many aircraft. Small operators may prefer to rely on CASA or an external authority.

The overall compliance burden is moderate for small operators (placard and training) and significant for RPT operators (full load sheet and passenger list regime). The exemptions and flexibility provisions reduce cost but require careful management to remain within the rule. Non‑compliance carries legal and operational risk out of proportion to the minor paperwork involved.