Walk onto the ramp of any Part 135 charter operator and the emergency equipment is almost always there. The life preservers are stowed, the raft is in its valise, the oxygen bottle has pressure, the extinguisher is mounted. What is far less reliably there — and what actually grounds aircraft and produces findings — is the paper that proves each item was serviceable on the date it mattered. An FAA inspector rarely opens a life-raft valise. They open the records.
The emergency-equipment rules in 14 CFR Part 135 are scattered across several sections, and — critically — they are triggered by different conditions. Some apply because of where and how you fly (extended overwater operations). Some apply because of how big the aircraft is (passenger seating configuration). Some apply to nearly every passenger-carrying flight (fire extinguishers, oxygen above certain altitudes). Confusing which trigger fires is one of the most common ways operators end up either over-equipped or, worse, non-compliant.
This guide disentangles the four core emergency-equipment regimes — §135.167, §135.177, §135.157, and §135.155 — states exactly what each requires, lays out the inspection cycle for each item, and shows how those inspection records feed the audit-ready record set you bring to an FAA surveillance audit.
Two Triggers, Not One: Operation Type vs. Aircraft Size
The single most useful mental model for Part 135 emergency equipment is that the requirements fire on two independent triggers. Get the triggers straight and the rest follows. The table below maps each core section to its trigger, what it requires, and the records that prove it.
| Section | Trigger | Core Requirement | Proving Records |
|---|---|---|---|
| §135.167 | Extended overwater (> 50 NM offshore) | Life preservers + liferafts + raft survival kits + survival ELT | Liferaft repack certs, ELT 12-mo inspection, ELT battery date |
| §135.177 | More than 19 passenger seats | Approved first-aid kit (itemized) + crash axe | First-aid kit contents/seal check, crash-axe placement |
| §135.157 | Cabin pressure altitude thresholds | Supplemental oxygen for occupants (by altitude) | O2 system inspection, cylinder hydro dates, quantity log |
| §135.155 | Carrying passengers | Hand fire extinguishers (flight deck + cabin) | Extinguisher inspection tags, hydro dates, weight check |
"Extended Overwater" Is a Defined Term
"Extended overwater operation" is defined in 14 CFR §1.1 as an operation over water at a horizontal distance of more than 50 nautical miles from the nearest shoreline (for aircraft other than helicopters; the helicopter threshold differs). That 50-NM line is what flips §135.167 on. A Gulf-of-Mexico run, a Caribbean island-hop, a Catalina charter, an Alaska coastal leg — these routinely cross the line. The compliance trap is the operator who flies "mostly over land" but has one or two routes that briefly exceed 50 NM offshore and never equipped or documented for it. The rule applies to the operation, not to the fleet on average.
Extended Overwater Equipment — 14 CFR §135.167
§135.167 is the most equipment-dense — and most records-dense — of the emergency-equipment sections. It breaks into three parts: the life preservers and rafts (subsection a), what each raft must carry (subsection b), and the survival-type ELT (subsection c).
§135.167(a) — Life Preservers and Liferafts
For extended overwater operations, the aircraft must carry an approved life preserver equipped with an approved survivor locator light for each occupant of the aircraft, plus enough approved liferafts of a rated capacity and buoyancy to accommodate the occupants of the aircraft. Each required item must be installed in a conspicuously marked location that is easily accessible in the event of a ditching. The records implication: the equipment list and weight-and-balance record must reflect the preservers and rafts, and each raft carries its own service life and repack interval set by the manufacturer and the certified service center that packs it.
§135.167(b) — What Each Liferaft Must Carry
Each required liferaft must be equipped with a survivor locator light and a pyrotechnic signaling device, plus either an approved survival kit appropriate to the route or, individually, the following items:
Because the food rations, water, pyrotechnics, and batteries all have expiration dates, the raft's contents are a recurring inspection item — not a one-time install. The repack certificate from the service center is the document that proves the kit was complete and in-date as of the last repack.
§135.167(c) — The Survival-Type ELT
For extended overwater operations the aircraft must carry an approved survival-type emergency locator transmitter, and it must be attached to one of the required liferafts. The battery used in this ELT must be replaced (or recharged, if rechargeable) when the transmitter has been in use for more than 1 cumulative hour, or when 50 percent of its useful life (or charge life) has expired, as established by the transmitter manufacturer. The new expiration date must be legibly marked on the outside of the transmitter. This is the same battery-life standard the fixed ELT follows under §91.207(c), and the same maintenance-record entry requirement applies — see the inspection-cycle section below.
The raft is on board — but the repack lapsed three months ago
The most common §135.167 finding is not a missing raft; it is a raft whose repack/inspection interval has expired, or whose service certificate the operator cannot produce on the day of the audit. A liferaft with an out-of-date repack is, for compliance purposes, the same as no raft — the operation is not legal until the raft is re-serviced and the certificate is on file. Because raft repack cycles, pyrotechnic expirations, and ELT battery dates all run on independent clocks, tracking them by memory is exactly how they lapse.
For helicopter charter operators — especially helicopter air ambulance (HEMS) operations — the overwater equipment rules interact with additional Part 135 helicopter provisions, and the "extended overwater" distance definition for helicopters differs from the fixed-wing 50-NM threshold. Verify your aircraft category's specific overwater equipment trigger before assuming the fixed-wing rule applies.
Large-Cabin Equipment — 14 CFR §135.177
§135.177 is triggered purely by aircraft size: a passenger seating configuration of more than 19 seats, excluding any pilot seat. This is the threshold that separates the typical light/mid charter aircraft from larger Part 135 commuter-style cabins. Below 20 seats, this section does not apply; at 20 seats and above, it does.
The Approved First-Aid Kit (Itemized)
§135.177 requires at least one approved first-aid kit, properly equipped and stowed, with specified contents — including adhesive bandage compresses, antiseptic swabs, ammonia inhalants, bandage compresses (4-inch), triangular bandage compresses (40-inch), a noninflatable arm splint and leg splint, roller bandages, adhesive tape, bandage scissors, and protective nonpermeable gloves. Because consumable medical items expire, the kit is a recurring check, not a one-time install: the seal-integrity check and the expiration review of the kit's contents are the records that prove it remains compliant.
The Crash Axe — Accessible to Crew, Inaccessible to Passengers
§135.177 also requires a crash axe carried so as to be accessible to the crew but inaccessible to passengers during normal operations. The placement is itself the compliance condition — an axe stowed where a passenger can reach it does not satisfy the rule. The proving record here is less about an expiration date and more about the documented installed-equipment configuration: the equipment list and any cabin configuration record that shows the axe is installed in a crew-accessible, passenger-inaccessible location.
A Note on Megaphones and Other Large-Aircraft Items
§135.177 itself centers on the first-aid kit and crash axe at the more-than-19-seat threshold; it does not, by its own terms, list megaphones or illuminated emergency-exit signs as items under this specific section. Additional emergency-equipment and emergency-exit requirements for larger transport-category cabins are addressed elsewhere in Part 135 and in the aircraft's type-certification basis. The practical takeaway for the records layer: confirm exactly which emergency items your specific aircraft and operations specifications require — don't assume a generic "large aircraft" checklist — and document each one. When in doubt, your principal maintenance inspector and the aircraft's approved configuration are the authority.
Supplemental Oxygen — 14 CFR §135.157
§135.157 sets supplemental-oxygen requirements that scale with cabin pressure altitude and differ between unpressurized and pressurized aircraft. The thresholds are precise, and they drive both the equipment you must carry and the servicing records you must keep.
§135.157(a) — Unpressurized Aircraft
- 10,000–15,000 ft MSL: oxygen for at least 10 percent of the occupants other than the pilots, for the part of the flight at those altitudes lasting more than 30 minutes.
- Above 15,000 ft MSL: oxygen for each occupant of the aircraft other than the pilots.
- Crew oxygen is governed separately, including the §135.89 pilot-use rules.
§135.157(b) — Pressurized Aircraft
- Above FL250 (25,000 ft): at least a 10-minute supply for each non-pilot occupant for use during a descent after loss of cabin pressure.
- On cabin-pressure loss, 10,000–15,000 ft: the same 10-percent / over-30-minute supply as unpressurized.
- On cabin-pressure loss, above 15,000 ft: supply for each non-pilot occupant — one hour, or 30 minutes if the aircraft can descend safely to 15,000 ft within four minutes.
What §135.157 Compliance Looks Like in the Records
§135.157 specifies the supply you must have available; it doesn't spell out one named document. In practice, an inspector confirming oxygen compliance reviews:
- The oxygen system inspection and servicing entries in the maintenance record (system function, leak checks, regulator condition)
- The hydrostatic test dates stamped on the oxygen cylinders — DOT-regulated cylinders carry their own retest interval
- A quantity/pressure check confirming the available supply meets the duration the operation requires at altitude
- For the §135.157(c) equipment standard — a means for the crew to readily determine, in flight, the amount of oxygen available
An undated or expired oxygen-cylinder hydrostatic test is a frequent finding — the gas may be present, but the cylinder is out of certification, which makes the installed equipment non-compliant regardless of pressure.
Hand Fire Extinguishers — 14 CFR §135.155
§135.155 applies broadly: no person may operate an aircraft carrying passengers unless it is equipped with hand fire extinguishers of an approved type. Unlike the overwater and large-cabin sections, this one is in play on essentially every passenger-carrying Part 135 flight.
Where, and How Many
Per §135.155: the type and quantity of extinguishing agent must be suitable for the kinds of fires likely to occur (subsection a); at least one hand fire extinguisher must be conveniently located on the flight deck for the flight crew (subsection b); and at least one must be conveniently located in the passenger compartment of each aircraft having a passenger seating configuration, excluding any pilot seat, of at least 10 seats but less than 31 seats (subsection c). Larger cabins carry additional extinguisher requirements under the aircraft's certification basis.
The Records That Prove an Extinguisher Is Serviceable
A mounted extinguisher is not automatically a compliant one. The proving records are the periodic inspection tag (confirming the gauge is in the green and the unit is sealed), the weight or charge verification, and the hydrostatic test date stamped on the cylinder. An extinguisher past its hydro date, or with a missing/expired inspection tag, is a documentation finding even if it would discharge perfectly. These dates run on their own cycle and are easy to overlook between annuals.
The Inspection Cycles — Why This Is a Calendar Problem
Emergency equipment is governed by multiple independent recurring intervals, each on its own clock. That is precisely why operators lapse: there is no single "emergency equipment annual" that catches everything. The survival-type ELT is the clearest example — and the most heavily documented.
The ELT — §91.207 Inspection & Battery Standard (Fixed ELT) and §135.167(c) (Survival ELT Battery)
12-Calendar-Month Inspection
Under §91.207(d), the fixed ELT attached to the airplane must be inspected within 12 calendar months after the last inspection for proper installation, battery corrosion, operation of the controls and crash sensor, and a sufficient signal radiated from the antenna. No CFR section imposes this interval on the survival-type raft ELT — its checks follow the manufacturer and your approved maintenance/inspection program, commonly aligned with the raft repack.
Battery: 1 Cumulative Hour
Under §91.207(c), the battery must be replaced (or recharged) after the transmitter has been in use for more than 1 cumulative hour — including inadvertent activations.
Battery: 50% Useful Life
The battery must also be replaced when 50 percent of its useful life (or charge life) has expired, as established by the manufacturer — whichever comes first.
Mark It and Record It
The new expiration date for replacing or recharging the battery must be legibly marked on the outside of the transmitter AND entered in the aircraft maintenance record. That entry is the proving document.
The ELT entry is a maintenance record, and it lives inside the broader aircraft maintenance records set — retained, per 14 CFR §91.417, until the work is repeated or superseded, or for one year. The other emergency-equipment intervals each carry their own documentation:
| Item | Typical Recurring Interval | Proving Document |
|---|---|---|
| Survival-type ELT | Battery per §135.167(c); servicing per manufacturer & approved program (the 12-cal-month §91.207(d) inspection applies to the fixed ELT) | Transmitter date marking + maintenance/service entry |
| Liferaft | Per manufacturer / service-center repack cycle | Liferaft repack & inspection certificate |
| Raft pyrotechnics & rations | Per item expiration date | Repack certificate listing contents & dates |
| Oxygen cylinders | DOT hydrostatic retest interval (varies by cylinder) | Hydrostatic test date stamped on cylinder + log |
| Hand fire extinguishers | Periodic inspection + hydrostatic test interval | Inspection tag + hydro date + weight check |
| First-aid kit | Per contents expiration / seal-integrity check | Contents/seal inspection record |
Intervals for liferafts, oxygen cylinders, and fire extinguishers are set by the equipment manufacturer, the applicable DOT cylinder rules, and your approved maintenance program — confirm the exact interval for your specific make/model and document set rather than relying on a generic figure.
Flying with Inoperable Equipment — 14 CFR §135.179
What happens when an emergency-equipment item is unserviceable? You do not simply note it and go. Under §135.179, an aircraft may take off with inoperable instruments or equipment installed only if a tightly defined set of conditions is met.
The §135.179 Conditions for Deferral
- An approved Minimum Equipment List (MEL) exists for that specific aircraft;
- The FAA Flight Standards office has issued operations specifications authorizing use of the MEL;
- The MEL is prepared in accordance with the limitations in §135.179(b) — certain equipment essential to the operation cannot be deferred;
- The aircraft is operated under all applicable conditions and limitations contained in the MEL and the operations specifications authorizing use of the MEL — placarding requirements come from the MEL document itself, not the section text; and
- Records identifying the inoperable instruments and equipment are available to the pilot before flight.
Alternatively, under §135.179(c), the aircraft may be operated under a special flight permit issued under 14 CFR §§21.197 and 21.199.
Many emergency items can't be deferred at all
The MEL is not a blanket permission slip. Equipment that is essential for the operation being conducted — required life preservers and rafts on an overwater leg, required oxygen at altitude, items required by an airworthiness directive to remain operable — either has no deferral provision or can only be deferred under specific MEL conditions and time limits. The compliance record set must capture the MEL itself, the operations specifications authorizing it, and the open-item deferral records. Deferring required emergency equipment without a documented, authorized MEL basis is one of the cleaner ways to convert a maintenance squawk into an enforcement matter — closely related to how MEL and CDL records are scrutinized generally.
The Emergency-Equipment Records Set — What an Audit Actually Checks
Pull all of this together and the emergency-equipment record set is a per-aircraft bundle of dated documents proving each required item is installed, current, and serviceable — and that any inoperable item is properly deferred. This set sits alongside your broader Part 135 maintenance and CAMP records and is part of what a principal inspector reviews during surveillance.
The Emergency-Equipment Document Checklist
Notice the pattern: almost none of these are "do you own the equipment" questions. They are "can you produce the dated document" questions. That is the structural reason emergency-equipment compliance is a document-management problem more than an equipment problem — and it is exactly the layer FileFlo is built for.
Keep every emergency-equipment record current — and audit-ready
FileFlo is a compliance document intelligence platform — a read-only proof layer that classifies and tracks the records your emergency equipment generates. Upload your liferaft repack certificates, survival-type ELT inspection entries, oxygen cylinder hydro records, fire-extinguisher tags, first-aid kit checks, and MEL deferral records, and FileFlo:
- Classifies each document against the governing CFR (§135.167, §135.177, §135.157, §135.155, §135.179, §91.207)
- Extracts each inspection/service date and auto-calculates the next-due date across every independent interval
- Sends 90/60/30-day expiration alerts before any item lapses — the ELT battery, the raft repack, the O2 hydro, the extinguisher tag
- Assembles a per-aircraft, audit-ready emergency-equipment binder organized by section for any FAA surveillance or pre-purchase review
FileFlo does not inspect, repack, weigh, hydro-test, or service any physical equipment, and it is not a maintenance-tracking system of record. The physical work stays with your A&P, your Part 145 repair station, and your certified survival-equipment service center. FileFlo keeps the paper that proves the work was done audit-ready. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
Frequently Asked Questions
What emergency equipment does 14 CFR §135.167 require for extended overwater operations?
14 CFR §135.167(a) requires, for extended overwater operations, an approved life preserver equipped with an approved survivor locator light for each occupant of the aircraft, plus enough approved liferafts of a rated capacity and buoyancy to accommodate all occupants. Section (b) requires each liferaft to carry a survivor locator light, a pyrotechnic signaling device, an approved survival kit (or the individually listed items — canopy, radar reflector, repair kit, bailing bucket, signaling mirror, police whistle, raft knife, CO2 bottle, inflation pump, oars, 75-foot retaining line, magnetic compass, dye marker, flashlight), a 2-day supply of emergency food rations supplying at least 1,000 calories per day per person, water or a sea water desalting kit, and a fishing kit. Section (c) requires an approved survival-type emergency locator transmitter attached to one of the required liferafts. Each required item must be installed in a conspicuously marked, readily accessible location — and the documentation that proves it is present, current, and serviceable is what an FAA inspector reviews.
What is the difference between §135.167 extended overwater equipment and §135.177 large-cabin equipment?
They are triggered by different conditions and are independent of each other. 14 CFR §135.167 is triggered by the type of operation — extended overwater flight, meaning operation over water at a horizontal distance of more than 50 nautical miles from the nearest shoreline — and it governs life preservers, liferafts, raft survival kits, and the survival-type ELT. 14 CFR §135.177 is triggered by aircraft size — a passenger seating configuration of more than 19 seats, excluding any pilot seat — and it requires an approved first-aid kit with specified contents and a crash axe carried so as to be accessible to the crew but inaccessible to passengers. A 12-seat turboprop flying 80 NM offshore is subject to §135.167 but not §135.177. A 30-seat aircraft flying domestic legs over land is subject to §135.177 but not §135.167. A large aircraft on overwater charter is subject to both. The records set you maintain must reflect which sections actually apply to your operation and aircraft.
What does 14 CFR §135.157 require for oxygen equipment, and what records prove it?
For unpressurized aircraft, §135.157(a) requires supplemental oxygen for at least 10 percent of the occupants other than the pilots for the part of any flight at cabin pressure altitudes between 10,000 and 15,000 feet MSL that lasts more than 30 minutes, and for each occupant other than the pilots above 15,000 feet MSL. For pressurized aircraft, §135.157(b) requires at least a 10-minute supply of supplemental oxygen for each occupant other than the pilots above flight altitude 25,000 feet MSL for use when a descent is necessary due to loss of cabin pressurization, plus — on loss of cabin pressure — the same 10-percent/over-30-minute supply between 10,000 and 15,000 feet and supply for each non-pilot occupant above 15,000 feet (one hour, or 30 minutes if the aircraft can descend safely to 15,000 feet within four minutes). The records that prove compliance are the oxygen system inspection and servicing entries, hydrostatic test dates for the oxygen cylinders, and the quantity/pressure check log — none of which §135.157 spells out as a single document, but all of which an inspector expects to see.
How often must the survival-type ELT and its battery be inspected, and where is that recorded?
The emergency locator transmitter required for overwater operations is an approved survival-type ELT under §135.167(c). Its battery must be replaced (or recharged, if rechargeable) when the transmitter has been in use for more than 1 cumulative hour, or when 50 percent of its useful life (or charge life) has expired, as established by the transmitter manufacturer, and the new expiration date must be legibly marked on the outside of the transmitter — that marking is what §135.167(c) itself requires. The fixed ELT attached to the airplane is governed by 14 CFR §91.207: under §91.207(d) it must be inspected within 12 calendar months after the last inspection for proper installation, battery corrosion, operation of the controls and crash sensor, and the presence of a sufficient signal radiated from its antenna, and under §91.207(c) the new battery expiration date must be marked on the transmitter and entered in the aircraft maintenance record. No CFR section imposes the 12-calendar-month inspection on the survival-type raft ELT — its inspection and servicing follow the manufacturer's requirements and the operator's approved maintenance/inspection program, commonly aligned with the liferaft repack. Keeping a dated service entry for the survival ELT — battery replacement performed as maintenance is recorded under §43.9 — is the document that proves its battery is current.
Can a Part 135 aircraft fly with an inoperable piece of emergency equipment?
Only under a Minimum Equipment List (MEL). Under 14 CFR §135.179, an aircraft may be operated with inoperable instruments or equipment installed if there is an approved MEL for that aircraft, the FAA Flight Standards office has issued operations specifications authorizing use of the MEL, records identifying the inoperable instruments and equipment are available to the pilot, and the aircraft is operated under all applicable conditions and limitations contained in the MEL and the authorizing operations specifications (placarding requirements come from the MEL document itself). Many emergency-equipment items — life preservers, liferafts, required oxygen — are essential for the operation being conducted and either cannot be deferred at all or can only be deferred under the specific conditions and limitations in the MEL. The MEL itself, the operations specifications authorizing it, and the deferral records that document each open item are part of the compliance record set. Flying with deferred emergency equipment but no documented MEL authorization is a finding waiting to happen.
What hand fire extinguishers does a passenger-carrying Part 135 aircraft need?
Under 14 CFR §135.155, no person may operate an aircraft carrying passengers unless it is equipped with hand fire extinguishers of an approved type. The type and quantity of extinguishing agent must be suitable for the kinds of fires likely to occur. At least one hand fire extinguisher must be conveniently located on the flight deck for use by the flight crew. At least one hand fire extinguisher must be conveniently located in the passenger compartment of each aircraft having a passenger seating configuration, excluding any pilot seat, of at least 10 seats but less than 31 seats. The records that matter here are the extinguisher inspection tags, the hydrostatic test dates, and the weight/charge verification — the documentation that proves each required extinguisher is present and serviceable on the date of any FAA review.
What emergency-equipment records does an FAA principal inspector actually ask to see?
A principal operations inspector or principal maintenance inspector conducting surveillance typically wants to confirm three things on a per-aircraft basis: (1) that the required equipment is installed and matches the operation — the equipment list and weight-and-balance records showing the life preservers, liferafts, oxygen system, and extinguishers; (2) that each item is currently serviceable — ELT 12-calendar-month inspection entries, ELT battery expiration dates, oxygen cylinder hydrostatic test dates, liferaft repack/inspection dates, fire-extinguisher inspection tags and hydro dates, and first-aid kit seal/expiration checks; and (3) that any inoperable item is properly deferred under an authorized MEL with the deferral documented. The recurring failure mode is not missing equipment — it is missing or undated records that cannot prove the equipment was serviceable on the date in question. That evidentiary gap is exactly what a compliance document layer is built to close.
Does FileFlo inspect, repack, or service my emergency equipment?
No. FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not inspect, repack, weigh, hydrostatic-test, or service any physical equipment, and it is not a maintenance-tracking system of record for your aircraft. What it does is classify the documents your maintenance provider and avionics shop produce — the ELT inspection entries, the liferaft repack certificates, the oxygen cylinder hydro records, the fire-extinguisher tags, the MEL and its deferral records — against the governing CFR sections, extract the next-due dates, send expiration alerts before they lapse, and assemble an audit-ready binder organized by section for an FAA review. The physical work stays with your A&P, your Part 145 repair station, and your equipment vendors. FileFlo keeps the paper that proves the work was done audit-ready.
Related Aviation Compliance Guides
What Records Must a Part 135 Operator Keep
The full Part 135 records map — operational control, maintenance, training, and the documents an inspector expects
How to Prepare for a Part 135 FAA Surveillance Audit
What the PI reviews, how to assemble the binder, and the recurring documentation findings to close first
Part 135 Maintenance Recordkeeping & CAMP
How emergency-equipment maintenance entries fit the broader CAMP and continuous-airworthiness record set
MEL & CDL Minimum Equipment List Records
How deferrals are documented, what can and cannot be deferred, and the OpSpec authorization required
Part 135 Helicopter Air Ambulance (HEMS) Records
Helicopter-specific equipment and the overwater distance definition that differs from the fixed-wing rule
Part 91 Aircraft Records Requirements
The maintenance and ELT records framework under §91.207 and §91.417 that underpins the equipment record set
More Part 135 & Aviation Records Guides
Never let a raft repack or ELT battery lapse again
FileFlo classifies your emergency-equipment records against 14 CFR §135.167, §135.177, §135.157, §135.155, and §91.207, extracts every next-due date across every independent interval, and sends 90/60/30-day alerts before any item lapses. Keep every liferaft repack, survival ELT inspection, oxygen hydro, and fire-extinguisher tag documented and current — in one audit-ready record set organized by section.
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