Part 135 passenger briefing requirements: what 135.117 requires before every flight

The passenger safety briefing is one of the most visible compliance touchpoints on a Part 135 flight — it happens in front of the passenger, it has specific required content, and its absence is immediately observable to any FSDO inspector who happens to be riding along. It is also one of the most commonly abbreviated or skipped items in on-demand charter, because charter clients are often repeat flyers who signal impatience at the mention of safety briefings.

The regulation does not care how many times the passenger has flown. 14 CFR 135.117 requires a briefing before every flight.

What 135.117 requires

Before each takeoff, the pilot in command (or a crewmember designated by the PIC) must ensure that each passenger has been orally briefed on the following:

Required for every flight

• Smoking. When, where, and under what conditions smoking is prohibited. For most Part 135 operations, this means smoking is prohibited at all times.
• Use of safety belts and shoulder harnesses. Passengers must be briefed to fasten and keep fastened during taxi, takeoff, and landing, and whenever the seatbelt sign is illuminated. Shoulder harness use must be briefed where installed.
• Location and means of opening the passenger entry door and emergency exits. Point to them. Demonstrate if the aircraft type requires it.
• Location of survival equipment. If survival equipment is carried, where it is located and how to access it.
• Ditching procedures and the use of flotation equipment. Required if the flight will be flown over water beyond power-off gliding distance from shore — or for any flight where flotation equipment is required by the certificate holder's operations specifications.
• The normal and emergency use of oxygen. If the aircraft has supplemental oxygen equipment.
• Location and operation of fire extinguisher. Where it is and how to use it.

For overwater operations

For flights conducted over water beyond a certain distance from shore (typically 50 nautical miles for turbine aircraft, shorter for piston), additional briefing items are required:

• The location and operation of life rafts, life preservers, and other flotation devices
• Ditching procedures — what the crew will do, what passengers should do
• Procedures for exiting the aircraft in the event of a water landing

Can a safety card satisfy the requirement

Yes, with conditions. Under 135.117(b), if the aircraft does not have an aisle, the briefing may be provided by means of an individual printed card or briefing card for each passenger. The card must contain information on the emergency exits (location and operation), the use of safety belts, and the location of survival equipment.

The card is a supplement to the oral briefing in most cases — not a replacement for it. For aircraft without aisles (which is most piston and light turbine charter aircraft), the card can cover some items, but the PIC must still ensure passengers have received the required information before departure.

In practice, most well-run charter operations use a brief, scripted oral delivery that takes 60-90 seconds, sometimes accompanied by a card. The oral delivery ensures the PIC can demonstrate compliance if asked; the card gives passengers a reference they can consult during the flight.

Who delivers the briefing

Under 135.117(a), the briefing must be given by the PIC or a crewmember designated by the PIC. For single-pilot operations (the majority of on-demand charter in light aircraft), the PIC gives the briefing. For operations with a flight attendant or a second crewmember, that crewmember may deliver it — but the PIC remains responsible for ensuring it was given.

There is no provision for a pre-recorded briefing as a standalone compliance tool for Part 135. Video briefings, which are common on Part 121 airlines, are not addressed in 135.117 as a replacement for the oral briefing in on-demand operations.

The repeat-passenger question

135.117 does not provide an exception for repeat passengers, regular clients, or passengers who ask to skip the briefing. The regulation says "before each takeoff" — not "before the first flight with a given passenger" or "unless the passenger objects."

In practice, PICs often adapt the briefing delivery for regular clients — a shorter, more conversational version that covers the required elements without a formal recitation. That is fine as long as the required content is covered. What is not fine is skipping the briefing because a regular client waves it off.

The way to frame it with resistant clients: "FAA requires this on every flight — takes about a minute." That framing puts the requirement where it belongs (on the regulation, not on the PIC) and usually ends the objection.

Documentation

135.117 does not explicitly require written documentation that the briefing was given for each flight. However, the General Operations Manual (GOM) should describe the briefing procedure, and the flight release record — or a separate trip sheet — should have a briefing completion checkbox or line item.

In the event of an incident or FSDO inquiry, the question "was the passenger briefed?" will be asked. The best answer is a completed trip sheet with a briefing completion item signed by the PIC. The second-best answer is credible testimony from the PIC. "We always do it" without documentation is the worst answer — it is not evidence.

Adding a passenger briefing line item to the pre-departure checklist — and including it in the dispatch release documentation — costs nothing and provides a record that the briefing was part of the standard pre-departure process, not an afterthought.

Interaction with portable electronic devices

Part 135 operators must comply with 14 CFR 91.21 on portable electronic devices. If the operator determines that a device will not cause interference with aircraft systems, they may permit its use. If permitted, the conditions of use (including when devices must be stowed for takeoff and landing) should be included in the passenger briefing.

Most Part 135 operators permit phones and tablets throughout the flight, consistent with the FAA's 2013 guidance on PEDs. The briefing should note any restrictions — stow for takeoff and landing is a common condition even when devices are generally permitted.