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Aviation Compliance Education — FAA Part 135

Part 135 Ground Deicing & Icing LimitationsThe Program, the Holdover Discipline, and the Records That Prove It

The clean-aircraft rule in §135.227 looks simple — nothing frozen on the critical surfaces at takeoff — but the way a Part 135 operator proves it complied is anything but. There are three permitted paths in §135.227(b), one of which is a full holdover-time program borrowed wholesale from §121.629(c). Here is the regulation, verbatim, the three paths, and the records that make a winter takeoff defensible.

Compliance document perspective — not legal, operational, or airworthiness advice. This article explains the recordkeeping framework around the Part 135 ground deicing/anti-icing rules. It is not a substitute for an aviation attorney, your principal operations inspector, or your own approved deicing program and ground procedures for any specific flight.

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Direct Answer

A formal ground deicing/anti-icing program is one of three ways a Part 135 operator can comply with the cold-weather takeoff rule — not a universal requirement. §135.227 first sets the clean-aircraft rule, then in paragraph (b) requires §135.341 training plus one of three paths: a pretakeoff contamination check approved for the airplane type within 5 minutes of takeoff, an approved alternative procedure, or a full program complying with §121.629(c).

Under §135.227(a), no pilot may take off an aircraft with frost, ice, or snow adhering to any rotor blade, propeller, windshield, stabilizing or control surface; to a powerplant installation; or to an airspeed, altimeter, rate of climb, flight attitude instrument system, or wing — with the single exception of frost under the wing in the area of the fuel tanks if authorized by the FAA. The icing-flight limits in paragraphs (c) through (f) then govern flight into known or forecast icing.

None of this is a recordkeeping rule on its face — it is an operating limitation. But the program, the holdover timetables, the §135.341 training records, and the deicing-event records are exactly what an FAA inspector samples to confirm a winter takeoff was legitimately authorized. The limit is the regulation; the proof is a compliance document.

Clean-aircraft
No takeoff with frost, ice, or snow adhering to the listed critical surfaces (frost under the wing near fuel tanks excepted if FAA-authorized)
14 CFR §135.227(a)
3 paths
In icing-conducive conditions: §135.341 training plus a pretakeoff contamination check, an approved alternative, or a §121.629(c) program
14 CFR §135.227(b)
Within 5 min
A pretakeoff contamination check must be conducted within 5 minutes prior to beginning takeoff, from outside the aircraft unless the program says otherwise
14 CFR §121.629(c)(4)

Where the Icing Rules Live in Part 135

Section 135.227, titled "Icing conditions: Operating limitations," sits in the flight-operations subpart of Part 135 and does two distinct jobs. The first three layers — the clean-aircraft prohibition in (a) and the icing-conducive-takeoff rule in (b) — are about ground contamination and the act of getting safely airborne. The remaining paragraphs (c) through (f) are about flight into icing: when an aircraft may be flown under IFR or VFR into known or forecast light or moderate icing, the helicopter limitation, the severe-icing prohibition, and the forecast-changed exception. People often treat "icing" as one rule; in §135.227 it is really a ground rule and a flight rule bolted together.

The structural feature that trips operators up is the cross-reference. The most rigorous of the three §135.227(b) compliance paths — paragraph (b)(3) — does not spell out the program in Part 135 at all. It points to §121.629(c), the Part 121 air-carrier deicing rule, and adopts that element list by reference. So a Part 135 operator building a full holdover-time program is, in practice, building a §121.629(c) program even though it holds a Part 135 certificate. For the broader inventory of what a charter operator must retain, see what records a Part 135 operator must keep, and for the certificate-level authorizations that frame these limits, see operations specifications (OpSpecs) explained.

Your approved program — not the CFR floor — is the operating standard

The §135.227(b) paths describe what is permitted. The specifics of which surfaces count as "critical," which fluids are used, how holdover times are read, and who is authorized to release the aircraft come from the operator's approved program and its general operations manual. Where those documents are more restrictive than the regulatory minimum, the operator must fly to the tighter standard — and an inspector will hold it to what its own approved program says. The CFR sets the floor; your approved program is the standard you are measured against.

The Clean-Aircraft Rule and the Three §135.227(b) Paths

Start with §135.227(a), the clean-aircraft prohibition. It is a single sentence, not a list of subparagraphs, and it names the surfaces that must be clean: no pilot may take off an aircraft that has frost, ice, or snow adhering to any rotor blade, propeller, windshield, stabilizing or control surface; to a powerplant installation; or to an airspeed, altimeter, rate of climb, flight attitude instrument system, or wing. The one exception is takeoffs with frost under the wing in the area of the fuel tanks, and only if authorized by the FAA. That is the entire (a) prohibition — broad, surface-specific, and with a single narrow carve-out.

Paragraph (b) is the operational heart of the ground rule. It applies "any time conditions are such that frost, ice, or snow may reasonably be expected to adhere to the airplane." When that condition exists, no certificate holder may authorize a takeoff and no pilot may take off unless two things are true: the pilot has completed all applicable training required by §135.341, and one of three requirements is met. The training prerequisite is easy to miss but load-bearing — it is part of the rule itself, not a separate obligation.

(b)(1)

Pretakeoff contamination check

A pretakeoff contamination check that has been established by the certificate holder and approved by the Administrator for the specific airplane type has been completed within 5 minutes prior to beginning takeoff. A pretakeoff contamination check is a check to make sure the wings and control surfaces are free of frost, ice, or snow.

(b)(2)

Approved alternative procedure

The certificate holder has an approved alternative procedure and, under that procedure, the airplane is determined to be free of frost, ice, or snow.

(b)(3)

Approved deicing/anti-icing program

The certificate holder has an approved deicing/anti-icing program that complies with §121.629(c) of this chapter, and the takeoff complies with that program. This is the full holdover-time program path.

The practical reading: a smaller operator that flies in winter only occasionally may comply through the (b)(1) contamination-check route or the (b)(2) approved alternative without ever building holdover-time tables — but it still must have completed the §135.341 training and have an approved procedure on file. An operator that routinely flies in icing-conducive conditions usually adopts the (b)(3) program because holdover times give it a defensible window to taxi and depart after deicing rather than re-checking within five minutes of every takeoff. The choice is operational; the documentation obligation is real under all three.

The icing-flight limits in (c) through (f)

Past the ground rule, §135.227 governs flight into icing. Under paragraph (c), no pilot may fly under IFR into known or forecast light or moderate icing conditions, or under VFR into known light or moderate icing conditions, unless the aircraft has functioning deicing or anti-icing equipment protecting each listed surface and instrument system, or the airplane has ice protection provisions meeting section 34 of appendix A of the part, or the airplane meets transport-category type-certification provisions including certification for flight in icing conditions. Paragraph (d) addresses helicopters — no pilot may fly a helicopter under IFR into known or forecast icing, or under VFR into known icing, unless it has been type certificated and appropriately equipped for icing operations. Paragraph (e) prohibits flight into known or forecast severe icing except for aircraft meeting the appendix A section 34 or transport-category provisions, and paragraph (f) provides that the forecast-based restrictions in (c), (d), and (e) do not apply if current weather reports and briefing information relied upon by the pilot in command indicate the forecast icing will not be encountered because conditions have changed since the forecast.

Ground rule versus flight rule — keep them separate

The (a)/(b) ground rule and the (c)–(f) flight rule answer different questions. The ground rule asks: is the aircraft clean enough to take off, and how did you establish that? The flight rule asks: is the aircraft equipped and certificated to fly into the icing you expect to encounter? An operator can satisfy the ground rule perfectly — deiced, holdover time valid, contamination check complete — and still be prohibited from the flight under (c) or (e) because the aircraft is not equipped for the icing in the forecast.

From a records standpoint, the flight rule pulls in the aircraft's type-certificate and equipment documentation, while the ground rule pulls in the deicing program and training records. Both leave a documentary trail, and an inspector reconstructing a winter flight will look at both.

Could you show how a winter takeoff was authorized last January — the program, the training, and the check?

FileFlo classifies and indexes the approved deicing/anti-icing program, the §135.341 training records, the holdover timetables, and any deicing-event records that prove a §135.227 takeoff was legitimately authorized — alongside the rest of your Part 135 document set. AI document classification, 600+ document types, one-click audit binder. Starter at $89/mo, Professional at $299/mo. 5-day free trial.

What an Approved Program Must Contain (§121.629(c))

Because §135.227(b)(3) routes the program to §121.629(c), the required elements are the Part 121 list. The regulation says the approved ground deicing/anti-icing program must be in the operator's operations specifications and must include at least the following items. The four-part structure below is the §121.629(c) element list, paraphrased from the regulatory text — read it as the skeleton your approved program must put flesh on.

(c)(1)

A detailed description

  • How the certificate holder determines that conditions are such that frost, ice, or snow may reasonably be expected to adhere to the aircraft, and that ground deicing/anti-icing operational procedures must be in effect
  • Who is responsible for deciding that those procedures must be in effect
  • The procedures for implementing ground deicing/anti-icing operational procedures
  • The specific duties and responsibilities of each operational position or group responsible for getting the aircraft safely airborne while those procedures are in effect
(c)(2)

Initial and annual recurrent training and testing

  • For flight crewmembers, and qualification for all other affected personnel (e.g., aircraft dispatchers, ground crews, contract personnel), covering the specific requirements of the approved program
  • The use of holdover times; deicing/anti-icing procedures including inspection and check procedures and responsibilities; and communications procedures
  • Aircraft surface contamination and critical-area identification, and how contamination adversely affects performance and flight characteristics
  • Types and characteristics of deicing/anti-icing fluids; cold-weather preflight inspection procedures; and techniques for recognizing contamination on the aircraft
(c)(3)

Holdover timetables and procedures for their use

  • The certificate holder's holdover timetables, supported by data acceptable to the Administrator
  • Procedures for flight crewmembers to increase or decrease the determined holdover time in changing conditions
  • The conditions under which takeoff after exceeding maximum holdover time is permitted (a pretakeoff contamination check, an approved alternate procedure, or redeicing with a new holdover time)
(c)(4)

Deicing/anti-icing and check procedures and responsibilities

  • Aircraft deicing/anti-icing procedures and responsibilities
  • Pretakeoff check procedures and responsibilities — a check of the wings or representative surfaces within the holdover time
  • Pretakeoff contamination check procedures and responsibilities — a check, within five minutes prior to beginning takeoff and from outside the aircraft unless the program specifies otherwise, that the wings, control surfaces, and other critical surfaces are free of frost, ice, and snow

The training element is its own record set

Section 121.629(c)(2) requires initial and annual recurrent ground training and testing for flight crewmembers and qualification for other affected personnel — including ground crews and contract deicing personnel. That generates per-person training and qualification records that an inspector can sample by name and by date. And remember §135.227(b) independently requires the pilot to have completed all applicable training under §135.341 before any takeoff in icing-conducive conditions — so the deicing training and the broader Part 135 training program both have to be documented.

The program elements connect to the rest of the operator's document set. The training in (c)(2) sits inside the operator's broader training program recordkeeping, the program description and responsibility assignments live in the general operations manual, and the "who is responsible for deciding" element in (c)(1) ties directly to operational control and the required management personnel who hold it.

Holdover Time: The Discipline That Makes the Program Work

Holdover time is the concept the whole program revolves around. Section 121.629(c)(3) defines it as the estimated time deicing/anti-icing fluid will prevent the formation of frost or ice and the accumulation of snow on the protected surfaces of an aircraft. It begins when the final application of deicing/anti-icing fluid commences and expires when the applied fluid loses its effectiveness. The holdover times must be supported by data acceptable to the Administrator — in practice, operators use published holdover-time guidance for the specific fluid type, concentration, and weather conditions, and the FAA issues holdover-time guidance each winter season that programs commonly reference.

The holdover-time clock, in sequence

01

Final fluid application begins — the clock starts

Holdover time begins when the final application of deicing/anti-icing fluid commences, per the §121.629(c)(3) definition

02

Crew reads the holdover window for the conditions

The determined holdover time depends on fluid type and concentration plus the active precipitation and temperature; the program lets crews increase or decrease it as conditions change

03

Takeoff within the window — a pretakeoff check confirms

A pretakeoff check looks at the wings or representative surfaces for contamination within the holdover time (§121.629(c)(4))

04

Window exceeded — only three ways to still depart

After exceeding maximum holdover time, takeoff is permitted only with a pretakeoff contamination check, an approved alternate procedure, or redeicing and a new holdover time (§121.629(c)(3))

05

The contamination check is rigorous and external

A pretakeoff contamination check confirms the wings, control surfaces, and other critical surfaces are free of frost, ice, and snow — within five minutes of takeoff, from outside the aircraft unless the program says otherwise (§121.629(c)(4))

The discipline matters because the holdover window is the operator's permission to taxi and depart after deicing without re-inspecting at the threshold. Exceed it — a long taxi, a ground-stop, heavier-than-forecast snow — and the regulation does not let the crew simply hope the fluid held. It requires one of the three explicit actions: a pretakeoff contamination check, an approved alternate procedure, or redeicing with a fresh holdover time. That is the single most consequential operational rule in the whole program, and it is also the one most likely to be reconstructed by an inspector after a cold-weather event.

Holdover-time data is a controlled reference — keep the version you flew

Holdover-time tables are updated, and the data acceptable to the Administrator for one fluid or season may not match a later one. From a records standpoint, the table edition the program incorporated is part of the approved program; if it changes, the prior version still governs the flights that were flown under it. Keeping the in-effect holdover-time data retrievable by date is the difference between proving the crew read the window correctly and merely asserting it.

One scope note worth stating plainly: FileFlo does not compute holdover times, read weather, or tell a crew whether its window has expired. Those are operational decisions made with operational tools and the operator's approved program. What a compliance document platform does is keep the program, the holdover-time reference the program incorporates, the training records, and any retained deicing-event record indexed and retrievable — so the operator can show how the decision was governed, not make the decision.

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What Actually Gets Documented — and How FileFlo Tracks It

Section 135.227 is an operating limitation, and §121.629(c) describes a program rather than a single FAA form. But together they generate a recognizable record set, and that set is what surveillance samples on a winter operating day. Here is the documentation the icing rules produce, and how a compliance document platform handles each class. Note the honest scope: FileFlo is the proof layer; it does not deice aircraft, compute holdover times, pull weather, or exercise operational control.

The approved deicing/anti-icing program

14 CFR §135.227(b)(3); §121.629(c)

What the rule requires / depends on

The controlled program document itself — the §121.629(c)(1) detailed description, the responsibility assignments, the implementation procedures, and the deicing/check procedures of (c)(4). For operators using the (b)(3) path, this lives in the operations specifications. For operators using the (b)(1) or (b)(2) paths, the corresponding approved contamination-check or alternative procedure is the controlled document instead.

How FileFlo tracks it

FileFlo stores the current approved program (or the approved (b)(1)/(b)(2) procedure) as a controlled document and keeps prior revisions retrievable, so the version in effect on a given flight date is the one on file — not a superseded one.

Holdover timetables and supporting data

14 CFR §121.629(c)(3)

What the rule requires / depends on

The holdover-time tables the program incorporates, supported by data acceptable to the Administrator, plus the procedures for adjusting holdover time in changing conditions. The edition that governed a given winter operation matters, because holdover-time guidance is reissued and refined over time.

How FileFlo tracks it

FileFlo indexes the holdover-time reference the program incorporates as a versioned document, so the edition in effect for a specific flight date can be produced rather than guessed at.

Deicing / anti-icing training and qualification records

14 CFR §121.629(c)(2); §135.227(b); §135.341

What the rule requires / depends on

The initial and annual recurrent ground training and testing for flight crewmembers, and qualification for other affected personnel (ground crews, contract deicing personnel, dispatchers), required by §121.629(c)(2) — plus the §135.341 training that §135.227(b) makes a prerequisite to any cold-weather takeoff. These are per-person, dated records.

How FileFlo tracks it

FileFlo classifies and tracks training and qualification records by person and date, so the question "was this crewmember current on deicing training when the flight departed" has a documentary answer.

Deicing-event records (operator practice)

Operator procedure under the approved program

What the rule requires / depends on

The record of an actual deicing event — fluid type and concentration, application, the holdover-time window read for the conditions, and the pretakeoff or pretakeoff contamination check that authorized the takeoff. Part 135 does not prescribe a single universal deicing-event form for on-demand operators, so the contents follow the operator's approved program and manual, but the record is what reconstructs how a specific winter takeoff was authorized.

How FileFlo tracks it

FileFlo indexes retained deicing-event records by aircraft and date and assembles them into the audit binder, so a specific cold-weather takeoff can be shown to have been governed by the program.

General operations manual

14 CFR §135.21, §135.23

What the rule requires / depends on

The manual that carries the operator's deicing procedures, the responsibility assignments from §121.629(c)(1), and the way crews are told to apply the program. Section 135.21 requires the manual and §135.23 prescribes its required contents; the deicing program procedures are part of how the operator shows it ensures compliance with §135.227.

How FileFlo tracks it

FileFlo keeps the GOM as a controlled, indexed document tied to the revisions it applies to, so the procedure in effect on a given date — and proof crews had the current version — is retrievable.

Aircraft equipment / type-certificate documentation (flight-into-icing)

14 CFR §135.227(c)–(e)

What the rule requires / depends on

For the flight-into-icing limits, the documentation that an aircraft is equipped with functioning deicing/anti-icing equipment, or has ice protection provisions meeting section 34 of appendix A, or meets transport-category type-certification provisions including certification for flight in icing. This is what establishes whether a flight into known or forecast icing was permitted at all.

How FileFlo tracks it

FileFlo classifies and indexes aircraft and equipment documentation as a controlled document class, so the basis for a flight-into-icing decision is filed with the rest of the aircraft's records rather than scattered.

What a defensible deicing record trail looks like

01

The approved program is current and on file

The §135.227(b)(3) program (or the approved (b)(1)/(b)(2) procedure) is stored as a controlled document, with the in-effect revision retrievable for any flight date

02

The holdover-time reference is versioned

The holdover-time data the program incorporates under §121.629(c)(3) is kept by edition, so the table the crew actually read can be produced

03

Crew and ground-personnel training is documented

Initial and annual recurrent deicing training under §121.629(c)(2), plus the §135.341 training §135.227(b) requires, is tracked per person and per date

04

The deicing event is recorded

Fluid, application, holdover window, and the pretakeoff or pretakeoff contamination check that authorized the takeoff are captured per flight

05

Flight-into-icing eligibility is documented

The aircraft equipment and type-certificate basis for any flight into known or forecast icing under §135.227(c)–(e) is on file with the aircraft records

06

It all assembles for the inspector

Program, holdover data, training, and event records are cross-referenced and produced as one binder for the next surveillance visit

This record trail does not sit in isolation. The deicing program and its training records are sampled alongside the rest of the operator's document set — the training program records, the pilot records, and the broader Part 135 required-records inventory. When the next records inspection lands, the deicing records are pulled with everything else — the surveillance audit preparation guide walks through how those visits actually unfold, and the flight-risk and weather data behind the Part 5 SMS deadline in 2027 increasingly intersects with cold-weather risk decisions. Helicopter air-ambulance operators, in particular, fold icing decisions into the broader HEMS records picture.

FileFlo is the proof layer, not the deicing or flight-planning system

FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the approved deicing/anti-icing program, the holdover-time reference, the training records, the deicing-event records, and the aircraft equipment documentation your operation produces, and proves they exist when an inspector asks. It does not deice aircraft, compute or interpret holdover times, pull or generate weather, determine whether a window has expired, or exercise operational control. The system that gets the airplane safely airborne and the system that proves the paperwork should not be the same system — one is operational, the other is evidentiary.

Frequently Asked Questions

Does 14 CFR §135.227 require a Part 135 operator to have a formal ground deicing/anti-icing program?

No — a formal program is one of three permitted paths, not a universal mandate. Section 135.227(b) says that any time conditions are such that frost, ice, or snow may reasonably be expected to adhere to the airplane, no certificate holder may authorize a takeoff and no pilot may take off unless the pilot has completed all applicable training required by §135.341 and one of three requirements is met: (b)(1) a pretakeoff contamination check approved for the specific airplane type has been completed within 5 minutes prior to beginning takeoff; (b)(2) the certificate holder has an approved alternative procedure under which the airplane is determined to be free of frost, ice, or snow; or (b)(3) the certificate holder has an approved deicing/anti-icing program that complies with §121.629(c) of this chapter and the takeoff complies with that program. So an operator can comply through the 5-minute contamination-check route, an approved alternative, or a full holdover-time program — but the training prerequisite and the clean-aircraft outcome are non-negotiable in all three.

What is the difference between a pretakeoff check and a pretakeoff contamination check?

They are defined differently in §121.629(c)(4), and conflating them is a common error. A pretakeoff check is a check of the aircraft's wings or representative aircraft surfaces for frost, ice, or snow within the aircraft's holdover time. A pretakeoff contamination check is a check to make sure the wings, control surfaces, and other critical surfaces — as defined in the certificate holder's program — are free of frost, ice, and snow; it must be conducted within five minutes prior to beginning takeoff, and it must be accomplished from outside the aircraft unless the program specifies otherwise. The pretakeoff check happens inside the holdover window; the pretakeoff contamination check is the more rigorous, externally conducted check that lets a takeoff proceed even after the holdover time has been exceeded. The §135.227(b)(1) route specifically uses a pretakeoff contamination check approved for the specific airplane type.

What does §135.227(a) actually prohibit?

Section 135.227(a) is the clean-aircraft rule, and it is a single prohibition rather than a list of subparagraphs. No pilot may take off an aircraft that has frost, ice, or snow adhering to any rotor blade, propeller, windshield, stabilizing or control surface; to a powerplant installation; or to an airspeed, altimeter, rate of climb, flight attitude instrument system, or wing — except that takeoffs may be made with frost under the wing in the area of the fuel tanks if authorized by the FAA. That one exception, frost under the wing near the fuel tanks, is the only carve-out in (a), and it requires FAA authorization. Everything else on that list must be clean before the airplane rotates.

What must an approved ground deicing/anti-icing program include under §121.629(c)?

Because §135.227(b)(3) routes a Part 135 program to §121.629(c), the program elements are the Part 121 list. The approved program must include at least: (c)(1) a detailed description of how the certificate holder determines that conditions warrant the program, who is responsible for deciding it is in effect, the procedures for implementing it, and the duties of each operational position responsible for getting the aircraft safely airborne; (c)(2) initial and annual recurrent ground training and testing for flight crewmembers and qualification for other affected personnel, covering holdover times, deicing/anti-icing procedures, communications, surface contamination and critical-area identification, fluid types and characteristics, cold-weather preflight inspection, and techniques for recognizing contamination; (c)(3) the certificate holder's holdover timetables and the procedures for using them, supported by data acceptable to the Administrator, including procedures to adjust holdover time in changing conditions and the conditions under which takeoff after exceeding maximum holdover time is permitted; and (c)(4) deicing/anti-icing procedures and responsibilities, pretakeoff check procedures, and pretakeoff contamination check procedures.

What is holdover time, and when can a takeoff happen after it has been exceeded?

Section 121.629(c)(3) defines holdover time as the estimated time deicing/anti-icing fluid will prevent the formation of frost or ice and the accumulation of snow on the protected surfaces of an aircraft. It begins when the final application of deicing/anti-icing fluid commences and expires when the applied fluid loses its effectiveness, and it must be supported by data acceptable to the Administrator. The program must allow flight crewmembers to increase or decrease the determined holdover time in changing conditions, and it must provide that takeoff after exceeding any maximum holdover time is permitted only when at least one of three conditions exists: a pretakeoff contamination check determines the wings, control surfaces, and other critical surfaces are free of frost, ice, or snow; an approved alternate procedure makes that same determination; or the wings, control surfaces, and other critical surfaces are redeiced and a new holdover time is determined.

What records does a Part 135 ground deicing/anti-icing program generate?

The program itself is a controlled document — the approved procedures, the holdover timetables, and the responsibility assignments required by §121.629(c). On top of that, the training and testing required by §121.629(c)(2) generate per-crewmember training records, and the §135.341 training program (which §135.227(b) makes a prerequisite to any cold-weather takeoff in conditions conducive to icing) generates curriculum and completion records. Operationally, a deicing event typically produces a record of the fluid type, the application, and the holdover-time clock, plus the pretakeoff or pretakeoff contamination check that authorized the takeoff. None of these is a single universal FAA form for on-demand operators — the contents follow the operator's approved program and manual — but together they are what an inspector samples to confirm the program was actually followed on a winter operating day.

How does §135.227 differ from the Part 121 rule in §121.629?

They are closely related but not identical, and they should not be conflated. Section 121.629 governs scheduled air-carrier operations and, in paragraph (c), makes an approved ground deicing/anti-icing program in the operations specifications the default path (with a no-program alternative in paragraph (d) that requires a within-five-minutes, from-outside clean-aircraft check). Section 135.227 governs Part 135 on-demand and commuter operations; its paragraph (b) gives the operator three options — the §135.227(b)(1) pretakeoff contamination check, the §135.227(b)(2) approved alternative procedure, or the §135.227(b)(3) full program complying with §121.629(c). Section 135.227 then adds icing-flight limitations in paragraphs (c) through (f) that have no direct §121.629 analog, covering IFR/VFR flight into known or forecast light or moderate icing, helicopters, severe icing, and a forecast-changed exception. FileFlo does not classify documents against Part 121 unless an operator holds that certificate; the point of the comparison is that the §135.227(b)(3) program inherits the §121.629(c) element list by direct cross-reference.

Why would an FAA inspector ask for deicing records during a Part 135 audit?

Because the clean-aircraft requirement in §135.227 is only as good as the operator's ability to show how a winter takeoff was authorized. During surveillance or after a cold-weather event, an inspector reconstructs a specific flight and asks: was the pilot trained per §135.341, which of the three §135.227(b) paths applied, and — if the program path was used — was the holdover-time discipline in §121.629(c)(3) actually followed, with a pretakeoff contamination check if the holdover time was exceeded? Those questions are answered by the approved program document, the holdover timetables, the crew training records, and any deicing-event record retained with the trip paperwork. An operation that can produce the program, the training, and the event record in minutes is in a very different position than one reconstructing it from memory after the fact.

Your deicing program is only as good as your ability to produce it on demand

FileFlo classifies and indexes the approved deicing/anti-icing program, the holdover-time reference, the §121.629(c)(2) and §135.341 training records, and any deicing-event records that prove your §135.227 takeoffs were legitimately authorized — cross-referenced and assembled into a one-click audit binder for the next surveillance visit. AI document classification. 600+ document types. Starter at $89/mo, Professional at $299/mo. No credit card required for the 5-day free trial.

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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence — June 13, 2026. Regulatory citations verified against the Code of Federal Regulations as of publication date. Operating limits described here are the regulatory floor; an operator's approved deicing program, operations specifications, and manual may be more restrictive.

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