How to Stay Compliant When Using Contract Cabin Crew on Part 135 Operations
Part 135 operations are commercial charter flights where passengers pay for the service. Because of this, the FAA imposes stricter rules on crew training, documentation, and operational control than for private (Part 91) flights. Contract cabin crew can be used on Part 135 operations, but they must be fully integrated into the operator’s approved system.
Staying compliant means treating contract crew as part of your safety and operations system, not as outside helpers. This guide explains how to stay compliant when using contract cabin crew on Part 135 operations, using the same short‑bullet‑point style you have been using.
1. Understand Part 135 Requirements for Cabin Crew
Part 135 is more structured than Part 91.
Key points:
- Part 135 applies to commercial charter and air‑taxi operations.
- Crew must be integrated into the operator’s approved training and operational system.
- The operator has ultimate responsibility for compliance, even with contract crew.
- Documentation and record‑keeping are extensive and audit‑ready.
2. Define the Contract Crew’s Role Clearly
Clear role definition is the foundation of compliance.
Flight departments should:
- Define whether the role is safety‑focused, service‑focused, or hybrid in the operations manual.
- Specify required training, recurrent checks, and qualifications.
- State reporting lines, duties, and emergency responsibilities.
- Ensure the role aligns with FAA expectations and insurance requirements.
Ambiguous roles create compliance gaps during audits.
3. Ensure Contract Crew Meet Training Requirements
Part 135 requires an approved training program for crew.
Operators must:
- Ensure contract cabin crew complete the operator’s approved initial training.
- Verify completion of emergency procedures, evacuation, fire, and first‑aid training.
- Confirm recurrent training is completed on schedule.
- Keep training records in the operator’s system, not just the staffing partner’s.
Contract crew must be trained as if they were permanent employees.
4. Integrate Contract Crew Into the Operator’s SMS
Part 135 operators must have a Safety Management System (SMS).
Contract cabin crew should:
- Be included in SMS training and safety briefings.
- Know how to report hazards, incidents, and near misses.
- Participate in safety meetings and feedback loops.
- Follow the same safety policies and procedures as permanent crew.
Excluding contract crew from SMS creates compliance and safety risks.
5. Maintain Complete and Audit‑Ready Documentation
Part 135 operations face detailed FAA audits.
Operators must keep on file:
- Licenses, medicals, and type ratings (where applicable).
- Training records, including initial and recurrent training.
- Check‑ride or competency records, if required.
- Background checks and security vetting documentation.
- Duty‑time, rest, and scheduling records.
All records must be up‑to‑date and easily retrievable during an audit.
6. Align Contract Crew With Company SOPs
SOPs are a core part of Part 135 compliance.
Flight departments should:
- Provide contract crew with the current operations manual and SOPs.
- Require crew to study and acknowledge SOPs in writing.
- Conduct briefings before trips that reference SOPs directly.
- Enforce the same SOP adherence for contract and permanent crew.
Contract crew must operate under the same procedures as internal staff.
7. Ensure Insurance and Underwriter Approval
Insurance underwriters often set requirements beyond FAA rules.
Operators should:
- Confirm that contract crew meet the insurer’s minimum flight hours and experience.
- Verify time on type, recent operational experience, and training status.
- Provide underwriters with full documentation for contract crew.
- Avoid using crew who are not approved by the insurer.
Insurance approval is often a deciding factor in whether contract crew can be used.
8. Manage Duty‑Time and Fatigue Compliance
Part 135 operators must manage crew fatigue.
Flight departments should:
- Track duty‑time and rest periods for contract crew like permanent crew.
- Ensure contract crew do not exceed FAA and company limits.
- Prevent “double‑booking” across multiple operators without proper rest.
- Require contract crew to report fatigue and rest issues.
Fatigue mismanagement can lead to violations and safety incidents.
9. Use a Staffing Partner That Understands Part 135
A staffing partner that knows Part 135 reduces compliance risk.
Flight Crew International (FCI) helps operators by:
- Providing contract cabin crew who meet Part 135 training and documentation standards.
- Pre‑screening crew for licenses, medicals, recurrent training, and experience.
- Matching crew to insurance and Part 135 operational requirements.
- Reducing the time needed to verify compliance before deployment.
10. Leverage CrewLocator to Track Compliance
Technology makes it easier to manage contract crew compliance.
CrewLocator helps operators by:
- Tracking training, recurrent checks, and certifications for contract crew.
- Showing who is current, available, and Part 135‑ready.
- Reducing time spent verifying compliance for each trip.
- Supporting consistent documentation across permanent and contract crew.
Key Takeaway for Part 135 Operators
Contract cabin crew can be used on Part 135 operations, but they must be fully integrated into the operator’s approved training, SMS, and SOP system. Compliance is not optional; it is required by the FAA and enforced through audits and insurance reviews.
By defining roles clearly, maintaining complete documentation, and using staffing partners and technology that understand Part 135, operators can use contract crew safely and compliantly.
FAQs
Yes, but they must be integrated into the operator’s approved training and operational system.
Yes. Part 135 has more structured training, documentation, and oversight requirements.
The operator (certificate holder) is ultimately responsible for compliance, even with contract crew.
Yes. They must complete the operator’s approved initial and recurrent training programs.
Licenses, medicals, training records, recurrent checks, background checks, and duty‑time records.
It tracks training, certifications, and availability so contract crew are Part 135‑ready for each trip.
https://fci.aero/Flight Crew International provides vetted, compliant cabin crew for Part 135 and Part 91 operations. Contact can be made at https://www.fci.aero/contact.
