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GH.OPS.415 Aircraft loading and unloading

Commission Delegated Regulation (EU) 2025/20 · Regulations (EU) 2025/23 and 2025/24 · EAR revision 5 Nov 2025

IRImplementing rule

GH.OPS.415Aircraft loading and unloading

The operational procedures for aircraft loading and unloading shall ensure the following:

(a)aircraft loading is performed in accordance with the written loading instructions, and any loading specifications and requirements related to dangerous goods and other special cargo, mail, baggage items or equipment in compartment are observed;

(b)the aircraft stability is maintained during unloading and loading;

(c)the unloading team has the appropriate inbound flight documentation;

(d)the aircraft cargo compartment is empty prior to loading except in the case of transit flights or where the aircraft operator instructions state otherwise, and there are no damages or leaks; if any damage is identified, the aircraft operator shall be informed;

(e)the loading is performed so as not to damage the cargo compartment or the cargo compartment doors;

(f)the ULDs and other loose equipment are in serviceable condition, do not contain water or snow, and there is no damaged or leaking cargo;

(g)the items and ULDs loaded in the cargo compartments are properly restrained to prevent any movement or shifting during flight;

(h)the ULD type loaded on the aircraft corresponds to what is specified in the loading instructions;

(i)the cargo compartment doors are properly closed;

(j)any last-minute changes related to baggage or cargo loading are recorded on the mass and balance documentation and distributed for the information of the persons identified in the aircraft operator’s procedure;

(k)the mass and balance document containing the loading instructions is signed by the person responsible for loading supervision to confirm that the aircraft loading and load distribution have been completed as per the instructions;

(l)communication related to aircraft loading and load distribution is ensured between the person responsible for loading supervision and the person responsible for load planning and issuance of the related mass and balance documentation, as well as any other intermediary person if load planning is a remote function that is not performed at the departure station;

(m)a copy of the mass and balance documentation containing the loading instructions is retained on the ground and accessible to the ground personnel responsible for flight operations until after the arrival of the flight;

(n)loading and unloading are executed with GSE adequate to the aircraft type and task, as the case may be;

(o)any damage or malfunctions identified to the inplane loading system are notified to the aircraft operator.

IR · GH.OPS.415 — Regulations (EU) 2025/23 and 2025/24 · Regulation (EU) 2025/20 · Ground Handling Easy Access Rules · EAR revision 5 Nov 2025

AMCAcceptable means of compliance

AMC1 GH.OPS.415Aircraft loading and unloading

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AIRCRAFT LOADING AND UNLOADING

(a)The procedures for aircraft loading and unloading should cover the following key risks, as a minimum:

(1)injuries to persons;

(2)damage to the aircraft;

(3)failure to communicate any lastminute changes to the persons responsible for aircraft load planning and the aircrew, in accordance with the aircraft operator’s procedures;

(4)improper restraining and securing of load in the cargo compartment, leading to changes in the aircraft’s centre of gravity or the actual weight of the aircraft due to load shifting during flight;

(5)use of inadequate ULDs or restraint systems;

(6)failure to comply with the loading instructions, with a negative effect on aircraft load limitations and spread limitations;

(7)unfamiliarity with the cargo compartment configuration;

(8)use of inadequate GSE for loading/unloading;

(9)for cargo aircraft only (CAO), additional risk areas may be:

(i)higher amount of dangerous goods in CAO;

(ii)larger and heavier or outsized freight and ULDs (e.g. engines, cars, industrial equipment and machinery, large and heavy live animals);

(iii)aircraft’s main deck as a complex loading hold with different positions and restrictions.

(b)When different team leaders are used for inbound and outbound flights, they should ensure a formal and complete handover of tasks and briefing on special procedures or loading/unloading specificities. The unloading team should have a copy of the inbound container pallet message identifying the position of the ULDs or pallets in the cargo compartments.

(c)The loading/unloading teams should be aware of and apply any instructions of the aircraft operator requiring that its flyaway kit be always carried on board the aircraft.

(d)The procedures and documentation related to restraint equipment should be specific to the aircraft type and in accordance with the aircraft operator’s instructions regarding aircraft mass and balance documentation.

(e)The loading and unloading procedure should include a step covering gross error checks in securing load and restraint devices.

AMC · AMC1 GH.OPS.415 — Regulations (EU) 2025/23 and 2025/24 · ED Decision 2025/007/R · Ground Handling Easy Access Rules · EAR revision 5 Nov 2025

AMCAcceptable means of compliance

AMC2 GH.OPS.415Aircraft loading and unloading

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SAFETY RISK MITIGATION MEASURES FOR LOADING AND UNLOADING DANGEROUS GOODS

(a)The procedures for aircraft loading/unloading should cover the following safety objectives:

(1)prevention of damage to packages and ULDs (pallets and containers);

(2)consolidation of dangerous goods to ensure segregation of incompatible dangerous goods and comply with ICAO’s Technical Instructions;

(3)separation and segregation of packages to prevent interaction between incompatible DG and other cargo;

(4)prevention of movement during ground transport and during flight;

(5)prevention of shipments labelled CAO from being loaded on passenger aircraft.

(b)In case of damaged or leaking packages:

(1)packages found damaged or leaking before loading should not be loaded into an aircraft;

(2)packages found damaged or leaking in the cargo compartment should be unloaded from the aircraft;

(3)if leakage is found in the cargo compartment, check for other contaminated packages and assess if they can be transported;

(4)inform the commander/pilotincommand by applying the NOTOC procedure;

(5)apply any additional procedures, including for reporting, of the aircraft operator and aerodrome operator.

AMC · AMC2 GH.OPS.415 — Regulations (EU) 2025/23 and 2025/24 · ED Decision 2025/007/R · Ground Handling Easy Access Rules · EAR revision 5 Nov 2025

GMGuidance material

GM1 GH.OPS.415(d)Aircraft loading and unloading

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AIRCRAFT CARGO COMPARTMENTS As stated in point GH.OPS.415(d), the aircraft cargo compartments must be empty prior to loading, with several exceptions:

(a)a flyaway kit containing items and tools necessary for aircraft repairs, which is required by the aircraft operator to be carried on all flights (may be carried in a customised ULD or in a different way);

(b)other equipment (equipment in compartment (EIC)), company mail (COMAIL) or company material (COMAT);

(c)ballast;

(d)in the case of transit flights, for which the baggage, cargo and mail loaded for the next or final destination remain on board the aircraft.

GM · GM1 GH.OPS.415(d) — Regulations (EU) 2025/23 and 2025/24 · ED Decision 2025/007/R · Ground Handling Easy Access Rules · EAR revision 5 Nov 2025

GMGuidance material

GM1 GH.OPS.415(h)Aircraft loading and unloading

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LOADING INSTRUCTIONS/REPORT (LIR)

(a)The loading instructions document (also called ‘loading instructions/report’ or ‘LIR’) is generated for the purpose of providing support to the person supervising the aircraft loading in order to facilitate this activity and ensure that the load distribution and aircraft loading are completed as per the instructions.

(b)The loading instructions contain information about the maximum mass of items that may be loaded in each cargo compartment and instructions for the safe and optimal distribution of items to be loaded in the cargo compartments, along with the cargo segregation rules.

(c)The LIR may be part of an existing mass and balance document or a separate form.

(d)Usually, the signature on the LIR of the person responsible for loading supervision is the confirmation that the aircraft has been loaded in accordance with the loading instructions. The function of this signed document is to serve as a report. A signed copy of the LIR is retained on the ground.

GM · GM1 GH.OPS.415(h) — Regulations (EU) 2025/23 and 2025/24 · ED Decision 2025/007/R · Ground Handling Easy Access Rules · EAR revision 5 Nov 2025

All rules in Annexes

Consolidated from the EASA Easy Access Rules (revision 5 Nov 2025, extracted 17 Aug 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.

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