Direct Answer — Hazmat “Will Carry” Program Records
A Part 135 “will carry” program means the operator is authorized to accept dangerous goods as cargo — an election recorded in its Operations Specifications (commonly the A055 series). Carrying triggers the fuller compliance load. Under 49 CFR §172.704 the operator must train hazmat employees in general awareness, function-specific, safety, and security-awareness training (plus in-depth security training if a security plan applies), with recurrent training at least once every three years, and must keep each training record for as long as the person is a hazmat employee plus 90 days. For each shipment, the operator must run the §175.30 acceptance check (authorized and within limits, shipping paper in duplicate, correct marks/labels, pre-loading inspection for damage and leakage) and provide the pilot-in-command with the §175.33 written notification (NOTOC) before the aircraft moves under its own power. If the operator carries materials listed in §172.800, it also needs a security plan under Subpart I. The records that prove all of this — not just the activity — are what a surveillance inspector or PHMSA reviewer examines.
Carrying is an authorization you have to maintain, not just hold
The most common will-carry failure is letting the supporting records lapse while the carry authorization stays on the OpSpec. A current §172.704 training record for every hazmat employee, a completed §175.30 acceptance check for each shipment, and a retained §175.33 NOTOC are the proof that the authorization is being exercised lawfully. If you cannot carry hazmat to the rules and document it, the safer posture may be a will-not-carry election.
What a “Will Carry” Program Actually Is
The Federal Hazardous Materials Transportation Law (49 U.S.C. Chapter 51) and its implementing regulations in 49 CFR Parts 171–180 govern the transport of hazardous materials, including by aircraft, where the air-mode rules live in 49 CFR Part 175. An air carrier indicates whether it is authorized and trained to carry hazardous materials as cargo through its FAA Operations Specifications. For most Part 135 on-demand and commuter operators, this election is reflected in the A055 series of OpSpecs, which states either that the certificate holder will carry hazardous materials (and is trained and authorized to do so) or that it will not.
Choosing to carry is a business decision with a compliance price. It opens revenue — medical isotopes for a hospital network, lithium batteries, compressed gases, paint and solvents, machinery with installed fuel — but it also commits the operator to the full chain of acceptance, documentation, notification, loading, and (for higher-risk materials) security. Every link in that chain produces a record, and the records have to be current and producible. The remainder of this guide walks the chain in the order an operator lives it: train the people, accept the shipment, notify the captain, secure the higher-risk materials, and keep the proof.
The will-carry compliance chain (each step generates a document)
Hazmat training program for every hazmat employee
Anyone who accepts, handles, loads, or is responsible for the safety of transporting hazmat must be trained under §172.704 — general awareness, function-specific, safety, security awareness, and in-depth security training where a security plan applies.
Acceptance check on every shipment
Under §175.30(a) the operator must confirm the material is authorized and within quantity limits, described and certified on a shipping paper in duplicate per Part 172, and correctly marked and labeled before accepting it.
Pre-loading inspection of each package
Under §175.30(b)-(c) each package or overpack must be inspected immediately before placing it aboard the aircraft (or in a unit load device) and found to show no leakage or other indication that its integrity has been compromised.
Notification of the pilot-in-command (NOTOC)
Under §175.33 the operator must give the PIC accurate, legible written information about the hazmat aboard before the aircraft moves under its own power.
Security plan for higher-risk materials
Under §172.800 (Subpart I), carrying certain higher-risk hazardous materials requires a written security plan and in-depth security training under §172.704(a)(5).
A note on the OpSpec citation: the “A055” designation comes from FAA Operations Specifications and FAA guidance (FAA Order 8900.1), not from the Code of Federal Regulations. The CFR establishes the substantive hazmat duties; the OpSpec is the operator-specific document that records the carry / will-not-carry election and may attach conditions and limitations. Confirm your exact OpSpec paragraph and its current language with your FAA Principal Operations Inspector — paragraph numbering and content can vary by certificate and can change over time.
If your operation does not need the cargo authorization, the lighter posture is covered in the companion guide on the hazmat will-not-carry program and records. For the broader picture of everything a certificate holder must retain, see what records a Part 135 operator must keep, and for how an inspector approaches a file review, how to prepare for a Part 135 FAA surveillance audit. The hazmat program is one accountability of the operator’s required management personnel.
The §172.704 Training Requirements — Exactly What and How Often
Hazmat training is governed by 49 CFR Part 172, Subpart H. The purpose of the subpart, stated in §172.700, is to prescribe requirements for training hazmat employees. Under §172.702, a hazmat employer must ensure each of its hazmat employees is trained in accordance with the subpart, a hazmat employee may not perform a function subject to the subchapter unless instructed in the requirements that apply to it, and the employer must ensure each hazmat employee is tested on the training subjects covered in §172.704. The training itself is broken into the types defined in §172.704(a).
General awareness / familiarization training
§172.704(a)(1)Designed to provide familiarity with the requirements of the subchapter and to enable the employee to recognize and identify hazardous materials. For a will-carry operator this underpins every later step — staff cannot correctly accept, mark, or load what they cannot reliably identify.
Function-specific training
§172.704(a)(2)Concerns requirements of the subchapter — or applicable exemptions and special permits — that are specifically applicable to the functions the employee performs. For a carrying operator this is the heart of the program: acceptance checks, shipping-paper review, marking and labeling verification, loading and segregation, and NOTOC preparation.
Safety training
§172.704(a)(3)Covers emergency response information applicable to the materials the employee may encounter, measures to protect the employee from the hazards, and methods and procedures for avoiding accidents (such as proper handling and stowage).
Security awareness training
§172.704(a)(4)Provides an awareness of the security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This awareness-level training is required for hazmat employees generally — not only for those subject to a security plan.
In-depth security training
§172.704(a)(5)Required only for hazmat employees of a person required to have a security plan under Subpart I. It covers the company security plan and its implementation. A will-carry operator authorized for §172.800 materials must provide it; one carrying only lower-risk materials generally will not trigger it but should document why.
Recurrent interval
Per §172.704(c)(2), a hazmat employee must receive the required training at least once every three years. The clock runs from the most recent training completion date in the employee’s record — which is exactly why that date is one of the five mandatory record elements. For in-depth security training, the rule also requires retraining within a set time after a relevant change to the security plan.
New employees / function changes
Per §172.704(c)(1), a new hazmat employee (or one changing functions) may perform the function before completing training only if under the direct supervision of a properly trained and knowledgeable hazmat employee AND training is completed within 90 days of employment or the function change. Both conditions must hold.
Hazmat training is one of several recurring-training programs a carrying Part 135 operator runs. For how the FAA expects training programs to be documented more broadly, see Part 135 training program recordkeeping requirements and the parallel Part 135 drug and alcohol program records checklist, which runs on its own retention rule under 49 CFR §40.333.
Is every hazmat employee’s training inside the three-year window right now? FileFlo tracks the §172.704 recurrent clock per person and flags what is coming due before an inspector does.
Related Aviation Compliance Guides
Acceptance, Inspection, and Notifying the Captain
Where a will-not-carry operator runs a rejection workflow, a will-carry operator runs an acceptance workflow on every shipment, then notifies the pilot-in-command. Two sections of 49 CFR Part 175 carry the weight: §175.30 (acceptance and pre-loading inspection) and §175.33 (shipping paper and information to the pilot-in-command).
§175.30 — The acceptance check and pre-loading inspection
49 CFR §175.30(a) provides that no person may accept a hazardous material for transport aboard an aircraft unless the operator ensures the material is: authorized and within the quantity limitations specified for carriage aboard aircraft according to §172.101 (or as otherwise provided); described and certified on a shipping paper prepared in duplicate in accordance with Part 172 (or as authorized under Part 171); marked, labeled, and where applicable placarded in accordance with subparts D and E of Part 172; and labeled CARGO AIRCRAFT ONLY where the material may not go aboard a passenger-carrying aircraft. Then, under §175.30(b), no person may carry a hazardous material in a package or overpack aboard an aircraft unless the operator inspects it immediately before placing it aboard the aircraft (or in a unit load device or on a pallet), and §175.30(c) requires that the package or overpack show no leakage or other indication that its integrity has been compromised.
In practice this is captured on an acceptance checklist — a structured form that walks the accepting employee through each verification and is signed and dated. That completed checklist is the record proving the §175.30 check happened for a specific shipment, and it is exactly the document an inspector reviews when reconstructing how a load was accepted.
§175.33 — Information to the pilot-in-command (the NOTOC)
49 CFR §175.33 requires the operator to provide the pilot-in-command with accurate and legible written information about the hazardous materials aboard, which the rule allows to be handwritten, printed, or in electronic form, and which must be provided before departure and — per the regulation — in no case later than when the aircraft moves under its own power. The notification (commonly the NOTOC) must include the items specified in §175.33(a), among them:
- The proper shipping name, hazard class or division, subsidiary risk(s), packing group, and identification number
- The total number of packages
- The net quantity or gross mass, as applicable, for each package
- The loading location of the packages aboard the aircraft
- Confirmation where a package must be carried on cargo-only aircraft
- The airport at which the package(s) is to be unloaded
- A telephone number monitored during the flight for emergency response
- Indication where transport is under a special permit or exemption
§175.33(a) also addresses Class 7 (radioactive) specifics and special provisions for items such as dry ice (UN 1845) and lithium batteries. The complete list of required items should be read against the current text of §175.33. Retain the operator’s copy of the NOTOC: it proves the captain was notified for that flight.
When something is wrong: reports of discrepancies
The acceptance check is also a gate that catches problems. Where a hazardous material is found to be improperly described, certified, labeled, marked, or packaged, 49 CFR §175.31 (“Reports of discrepancies”) addresses notification of the FAA where such a discrepancy is discovered. A will-carry operator should document not just clean acceptances but the discrepancies it catches and how it handled them — that record demonstrates the acceptance program is functioning, not merely papered.
Operations with their own clinical-cargo profile face especially careful acceptance and stowage — see the Part 135 helicopter air ambulance (HEMS) records guide, where oxygen and medical materials demand close screening. And because hazmat sits alongside cabin-safety duties, the passenger briefing and cabin safety records guide covers the adjacent documentation a charter operator keeps.
The Records a Will-Carry Operator Must Keep
The carry authorization generates several record types. The anchor is the training record. Under 49 CFR §172.704(d), the hazmat employer must create and retain a record of current training, inclusive of the preceding three years, for each hazmat employee for as long as that employee is employed by that employer as a hazmat employee, and for 90 days thereafter. The same paragraph specifies exactly what the record must contain.
- The hazmat employee’s name
- The most recent training completion date of that employee’s training
- A description, copy, or the location of the training materials used to meet the training requirement
- The name and address of the person providing the training
- Certification that the hazmat employee has been trained and tested as required by Subpart H
Source: 49 CFR §172.704(d). A record missing any one of these five elements is deficient — most commonly the trainer’s name and address, or the testing certification, is the element left out.
The will-carry records inventory
§172.704 training records
One per hazmat employee, with all five content elements and the most recent completion date driving the three-year recurrent clock. Retained for employment plus 90 days.
The A055 carry authorization (OpSpec)
The current, signed OpSpec page that records the will-carry election and any conditions/limitations. It is the legal basis for accepting cargo hazmat and must be producible.
§175.30 acceptance checklists
A completed, signed check per shipment showing authorization/quantity verification, shipping-paper-in-duplicate confirmation, marking/labeling verification, and the pre-loading inspection result.
§175.33 NOTOC copies
The operator’s retained copy of the written notification given to the pilot-in-command for each flight carrying hazmat.
Subpart I security plan (where applicable)
For §172.800 materials, the written security plan plus the §172.704(a)(5) in-depth security training records — or a documented basis for why Subpart I does not apply.
Shipping papers and discrepancy records
Shipping papers handled in accordance with Part 172, plus any §175.31 discrepancy notifications and the operator’s record of how problems were resolved.
The training retention clock is employment-based, not a fixed number of years
This is the detail operators most often get wrong. Hazmat training records are not “keep for 3 years” or “keep for 5 years.” They are kept for as long as the person is a hazmat employee plus 90 days after they stop. A 12-year employee’s record must be retained for 12 years and 90 days. Contrast this with FAA drug and alcohol program records, which follow the fixed retention periods in 49 CFR §40.333, and aircraft maintenance records, which follow 14 CFR §91.417. Three different programs, three different retention rules — mixing them up is a classic audit finding.
FileFlo as the Hazmat Records Layer
FileFlo is a compliance document intelligence platform — a read-only proof layer for the documents that demonstrate your will-carry hazmat program exists and is current. It does not deliver hazmat training, write your hazmat program, security plan, or OpSpecs, and it does not accept or inspect physical shipments. What it does is classify, index, and surface the records an inspector or PHMSA reviewer asks for.
- Classifies each uploaded training record and checks it against the five §172.704(d) content elements
- Tracks the three-year recurrent interval per hazmat employee and surfaces alerts at 90/60/30 days before due
- Indexes the will-carry OpSpec (A055) so the legal basis for accepting cargo hazmat is always producible
- Holds §175.30 acceptance checklists, §175.33 NOTOC copies, and the Subpart I security plan alongside the training records
- Applies the employment-plus-90-day retention rule so training records are kept exactly as long as §172.704(d) requires
FileFlo classifies 600+ aviation and compliance document types and manages records across Part 91, Part 135, and Part 145 operators in one platform. Pricing: Starter $89/mo, Professional $299/mo. 5-day free trial, no credit card required. FileFlo does not provide or run a safety management system (SMS), dispatch system, or hazmat training program — it keeps the documents that prove compliance audit-ready.
Who the Hazmat Carriage Rules Apply To
The hazmat training and recordkeeping obligations under 49 CFR Part 172 Subpart H attach to the hazmat employer and its hazmat employees — terms defined in 49 CFR §171.8. An air carrier that accepts, handles, loads, or transports hazmat — or whose employees are responsible for the safety of transporting it — is a hazmat employer. The carriage and acceptance rules in Part 175 then apply to the air operator that holds the carry authorization. The depth of the program scales with what is carried.
Typical operator
Charter / on-demand operators authorized to carry hazmat
A055 carry authorization, full §172.704 training, §175.30 acceptance checks, §175.33 NOTOC, loading/segregation, and a Subpart I security plan for §172.800 materials.
Typical operator
Most on-demand charter operators
No cargo hazmat authorization. Still must train staff to recognize/reject hazmat, screen under §175.30, apply the §175.10 passenger exceptions, and keep §172.704 records.
Typical operator
Scheduled / large cargo carriers
Part 175 acceptance, NOTOC, and (for higher-risk materials) Subpart I security obligations apply at scale, with hazmat programs detailed in the carrier’s manuals and OpSpecs.
Because hazmat is one accountability among many, it sits alongside the operator’s pilot records, the broader question of who holds operational control (a term defined at 14 CFR §1.1), and the operator’s Operations Specifications, where the A055 carry election actually lives. Fractional operations carry their own nuances — see Part 91K fractional ownership compliance records.
Looking ahead, the same operators face the new safety-management obligations summarized in our FAA Part 135 SMS 2027 deadline guide, and should keep an eye on the overarching aviation records retention schedule so each program’s clock is tracked separately.
Frequently Asked Questions
What is a hazmat "will carry" program for a Part 135 operator?
A "will carry" program is what an air carrier puts in place when it elects to accept hazardous materials (dangerous goods) for transport as cargo. The authorization to carry is reflected in the operator's FAA Operations Specifications — for most Part 135 operators this is the A055 series, which records whether the certificate holder is authorized and trained to carry hazardous materials. Choosing to carry triggers the fuller compliance load: trained hazmat employees under 49 CFR Part 172 Subpart H, an acceptance check on every shipment under 49 CFR §175.30, shipping papers prepared in duplicate, notification of the pilot-in-command under §175.33, loading and segregation requirements, and a security plan under 49 CFR Part 172 Subpart I if the operator handles materials that require one. Every one of those duties produces a document — and the documents, not just the activity, are what an FAA Aviation Safety Inspector or a PHMSA reviewer examines.
How often is recurrent hazmat training required, and how long must the records be kept?
Per 49 CFR §172.704(c)(2), a hazmat employee must receive the training required by Subpart H at least once every three years. Per §172.704(d), the hazmat employer must create and retain a record of current training, inclusive of the preceding three years, for each hazmat employee, and that record must be kept for as long as that employee is employed by that employer as a hazmat employee and for 90 days thereafter. The retention clock is tied to employment plus 90 days — not a fixed calendar period — which is different from FAA drug and alcohol program records under 49 CFR §40.333 or aircraft maintenance records under 14 CFR §91.417. The training record itself must contain five elements under §172.704(d): the hazmat employee's name; the most recent training completion date; a description, copy, or location of the training materials used to meet the requirement; the name and address of the person providing the training; and certification that the employee has been trained and tested as required.
What must the operator verify before accepting a hazmat shipment for carriage by aircraft?
Acceptance is governed by 49 CFR §175.30. Under §175.30(a), no person may accept a hazardous material for transport aboard an aircraft unless the operator ensures the material is authorized and is within the quantity limitations specified for carriage aboard aircraft per §172.101; is described and certified on a shipping paper prepared in duplicate in accordance with Part 172 (or as authorized under Part 171); is marked, labeled, and (where applicable) placarded in accordance with subparts D and E of Part 172; and is labeled CARGO AIRCRAFT ONLY where the material is forbidden aboard passenger-carrying aircraft. Then, under §175.30(b), no person may carry a hazardous material in a package or overpack aboard an aircraft unless the operator inspects it immediately before placing it aboard the aircraft (or in a unit load device or on a pallet), and §175.30(c) requires that the package or overpack show no leakage or other indication that its integrity has been compromised. The completed acceptance check — typically captured on an acceptance checklist — is the record that proves this verification happened.
What information must be given to the pilot-in-command (the NOTOC)?
Under 49 CFR §175.33, the operator must provide the pilot-in-command — and, in practice, the flight follower or dispatcher — with accurate and legible written information about the hazardous materials aboard, which the regulation allows to be handwritten, printed, or in electronic form. The information must be provided before departure and, per the rule, in no case later than when the aircraft moves under its own power. The notification (commonly called the NOTOC, for Notification to Captain) must include, among other items specified in §175.33(a): the proper shipping name, hazard class or division (and any subsidiary risk), identification number and packing group; the total number of packages and their net quantity or gross mass; the location of the packages aboard the aircraft; confirmation where a package must be carried on cargo aircraft only; the airport at which the package is to be unloaded; and a telephone number monitored during the flight for hazmat emergency response. The PIC's copy and the operator's retained copy of the NOTOC are part of the records that demonstrate the flight was conducted in compliance.
What happens at a surveillance review or ramp check if hazmat records are missing?
A hazmat employer that cannot produce a current, complete training record for each hazmat employee is in violation of 49 CFR §172.704(d) regardless of whether the training actually occurred — an inspector cannot distinguish "the training happened but the record is missing" from "the training never happened." The same logic applies to acceptance checks, NOTOCs, and the security plan: the absence of the record is itself the finding. For air carriers, both FAA Aviation Safety Inspectors and PHMSA can assess civil penalties for hazmat training, acceptance, and recordkeeping violations. Under the civil-penalty framework at 49 U.S.C. §5123 and its inflation-adjusted implementing tables, penalties for knowing violations of the federal hazardous materials transportation law can reach into the tens of thousands of dollars per violation per day, with higher maximums where a violation results in death, serious illness, severe injury, or substantial property destruction. Because the recordkeeping deficiency is independently citable, the record — not just the underlying activity — is the compliance artifact that matters at audit.
Do we need a security plan, and how does that change the training records?
It depends on what you carry. 49 CFR Part 172 Subpart I requires a hazmat security plan for persons who offer for transportation or transport certain higher-risk hazardous materials specified in §172.800. If your carry authorization includes any of those materials, you must develop and adhere to a written security plan and you must also provide in-depth security training under §172.704(a)(5) — the training type that covers the company security plan and its implementation, which is required only for employees of an entity that must have a plan. If your carry authorization covers only materials that do not trigger Subpart I, the in-depth security training and the written security plan generally will not apply, but security awareness training under §172.704(a)(4) still does for hazmat employees generally. From a records standpoint, a will-carry operator should be able to show either the security plan and the §172.704(a)(5) training records, or a clear, documented basis for why Subpart I does not apply to the materials it is authorized to carry.
What is the difference between a "will carry" and a "will not carry" Part 135 operator?
The difference is whether the operator accepts dangerous goods as cargo. A "will not carry" operator declines the cargo authorization and carries no regulated cargo hazmat; it still must train staff to recognize and reject undeclared dangerous goods, follow the §175.30 acceptance screening for anything offered, and apply the passenger and crewmember exceptions in §175.10 — but it avoids the heavier offer/accept/load/notify cycle. A "will carry" operator takes on that fuller cycle: acceptance checks on every shipment under §175.30, shipping papers in duplicate, NOTOC to the pilot-in-command under §175.33, loading and segregation rules, and a security plan under Subpart I where applicable. Both rely on the same §172.704 training and recordkeeping foundation; the will-carry operator simply has more record types to keep current. For the lighter posture, see the companion guide on hazmat will-not-carry records.
Does FileFlo run our hazmat program or just keep the records?
FileFlo keeps the records. It is a compliance document intelligence platform — a read-only proof layer that classifies, indexes, and tracks the documents that demonstrate your hazmat program is in place and current: §172.704 training records (with the five required content elements), recurrent-training due dates on the three-year cycle, your will-carry Operations Specifications, acceptance checklists, NOTOC copies, and the security plan if you carry materials that require one. FileFlo does not deliver hazmat training, does not write your hazmat program, security plan, or OpSpecs, does not accept or inspect physical shipments, and is not a substitute for a qualified hazmat training provider, your hazmat program manager, or your FAA Principal Operations Inspector. What it does is ensure that when an inspector or PHMSA reviewer asks for a specific hazmat employee's current training record, an acceptance checklist for a given shipment, or proof that recurrent training is within the three-year interval, the document is classified, indexed, in-date, and producible in seconds rather than reconstructed under audit pressure.
Don’t reconstruct your hazmat carriage records the week of a surveillance review
FileFlo classifies every uploaded hazmat training record against the five §172.704(d) elements, tracks the three-year recurrent interval per employee, and indexes your will-carry OpSpec, §175.30 acceptance checklists, §175.33 NOTOC copies, and Subpart I security plan — so the document an inspector asks for is producible in seconds. Starter plan $89/mo. Professional $299/mo. 5-day free trial — no credit card required.
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Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. Reviewed June 13, 2026. FileFlo keeps compliance records audit-ready; it is not legal counsel, a hazmat training provider, or your FAA Principal Operations Inspector. Verify all hazmat training, OpSpec authorizations, acceptance procedures, and security-plan applicability with a qualified hazmat training source and your FSDO.