The Federal Aviation Administration (FAA) has issued guidance to airlines wishing to transport cargo in the passenger cabin given reduced passenger demand in the wake of COVID-19. Under 14 C.F.R. § 121.285, airlines may carry cargo in the passenger compartment if the operation meets specific FAA requirements. According to media reports, several major airlines have expressed interest in transporting cargo in the cabin of their passenger aircraft, including removing passenger seating for this purpose.

The FAA issued a Safety Alert for Operators (SAFO), which provides information and non-binding recommendations to help airlines evaluate regulatory and safety risks associated with transporting cargo in passenger cabins, while cautioning that “it is an extraordinary situation … for an entire passenger cabin to be loaded with cargo” and that “passenger cabins are not designed for an all-cargo configuration.”

The FAA recommends that airlines consider weight and balance, fire detection, and hazardous materials issues when conducting the required safety risk assessment. Additionally, the FAA recommends that airlines contemplating such operations take certain precautions, such as determining whether the airline requires additional crew members to inspect for and respond to an in-cabin cargo fire because passenger aircraft cabins do not have smoke detection systems (other than in lavatories). Additionally, the FAA cautions airlines to be mindful of compliance with FAA’s Fatigue Risk Management Plan when scheduling crew rest, flight, and duty time on such flights.

The FAA notes that because airlines must still comply with other regulatory requirements applicable to the type of aircraft and operation, they may need to request relief from the FAA from those requirements.

The full SAFO can be found here.