Part 135 Hazmat Compliance: What Charter Operators Must Know About Dangerous Goods

Your OpSpecs define whether you are authorized to carry hazardous materials. Most Part 135 charter operators hold will-not-carry authorization, which means you cannot accept dangerous goods shipments.

However, even will-not-carry operators must provide hazmat recognition training to crew and ground personnel. Passengers may unknowingly bring prohibited items aboard, and your team must be able to identify and refuse them.

Under 49 CFR 175.20 and 14 CFR 135.323(c), all crew members and anyone who accepts cargo or baggage must receive initial and recurrent hazmat recognition training. Recurrent training is required every 24 months.

Training must cover: identification of hazardous materials in baggage and cargo, emergency procedures for hazmat incidents, passenger notification requirements, and specific prohibited items for your operation type.

The most frequently encountered prohibited items include lithium batteries (especially large spare batteries), flammable liquids in cargo, compressed gas cylinders, and firearms with ammunition. Charter passengers are less familiar with these restrictions than airline passengers.

Brief passengers on prohibited items before each charter flight. Include the briefing in your standard operating procedures and document it.

The FAA conducts unannounced HMASI (Hazardous Materials Aviation Security Inspection) visits. Inspectors verify training records, interview crew and ground personnel, review procedures, and may observe operations.

Keep training records immediately accessible — not in a filing cabinet at a different location. Inspectors expect to see current training certificates for all applicable personnel during the visit.