Direct Answer — HAA / HEMS Records Under 14 CFR Subpart L
Helicopter air ambulance (HAA / HEMS) operations run under 14 CFR Part 135 Subpart L (§135.601–§135.621), authorized by OpSpec A021. The records that are unique to HAA: the pre-flight risk analysis worksheet the PIC completes, signs, and dates before each operation (§135.617 — retain the original or a copy for at least 90 days); operations control specialist training records if you operate 10+ air ambulance helicopters and must run an operations control center (§135.619 — retain for the OCS’s duration of employment plus 90 days); and medical-personnel briefing/training records (§135.621 — retain 24 months). Layered on top: HTAWS equipment (§135.605, after April 24, 2017), an approved flight data monitoring system (§135.607, after April 23, 2018), PIC instrument qualifications (§135.603), and the universal Part 135 obligations — §135.267 duty and rest, maintenance records, pilot records, and the drug and alcohol program. The 2024 SMS rule applies to all Part 135 with a single May 28, 2027 deadline.
HAA is the highest-scrutiny corner of Part 135 — the records have to match the rule
Subpart L exists because of a sustained accident history in helicopter EMS. That history means an air ambulance program draws closer FAA attention than a comparable charter operation, and the documentation expectations are correspondingly specific: a signed, dated §135.617 pre-flight risk analysis worksheet for every operation, current §135.621 medical-personnel training, and — for larger operators — an operations control center with documented specialist training under §135.619. The flight can be flown perfectly and still produce a recordkeeping finding if the worksheet is missing.
The Subpart L Map: What §135.601–§135.621 Actually Cover
14 CFR Part 135 Subpart L is the body of rules specific to helicopter air ambulance operations, added by the FAA’s 2014 HAA final rule and phased in across several compliance dates. The first step in getting the records right is knowing which section drives which obligation. Some sections set operating limits (weather, planning, IFR transitions) that generate operational records; others set equipment mandates; and three sections — §135.617, §135.619, and §135.621 — carry explicit document-retention clocks.
| Section | Subject | Record / retention hook |
|---|---|---|
| §135.601 | Applicability and definitions (defines HAA, positioning/repositioning flights, medical personnel, mountainous areas) | Scoping — determines which flights are HAA |
| §135.603 | PIC instrument qualifications (after Apr 24, 2017: helicopter instrument rating or ATP not limited to VFR; also meet §135.243) | Pilot qualification records |
| §135.605 | Helicopter Terrain Awareness and Warning System (HTAWS) — after Apr 24, 2017, TSO-C194; RFM must include procedures | Equipment / RFM documentation in aircraft record |
| §135.607 | Flight data monitoring system — after Apr 23, 2018; operates continuously across the flight | Equipment approval in aircraft record |
| §135.609 | VFR ceiling and visibility requirements for Class G airspace (local flying areas) | Operational / dispatch records |
| §135.611 | IFR operations at locations without weather reporting | Operational records |
| §135.613 | Approach/departure IFR transitions | Operational records |
| §135.615 | VFR flight planning | Operational / planning records |
| §135.617 | Pre-flight risk analysis — PIC completes, signs, dates a worksheet before the first leg | Retain worksheet ≥ 90 days |
| §135.619 | Operations control centers (required for 10+ HAA helicopters); OCS duties and training | OCS training record: employment + 90 days |
| §135.621 | Briefing of medical personnel; FAA-approved medical-personnel training program | Training record: 24 months |
HAA authority is granted through an operations specification — OpSpec A021, the operations specification the FAA issues to authorize helicopter air ambulance operations. Your A021 (along with the other paragraphs of your OpSpecs) defines the specific authorizations, limitations, and provisions your certificate carries, and it is itself a controlled document your principal operations inspector will reference. For how operations specifications fit into the broader certificate, see what operational control means in Part 135 and the full Part 135 records overview.
The HAA-Specific Records — and the Universal Ones That Still Apply
An air ambulance program keeps two layers of records: the documents that exist only because of Subpart L, and the full Part 135 record stack that applies to every on-demand operator. Both layers are in scope on an FAA surveillance visit. Below are the HAA-specific records with their governing section and retention clock.
Pre-flight Risk Analysis Worksheets
≥ 90 days from the operation14 CFR §135.617The PIC must complete a pre-flight risk analysis worksheet before the first leg of each helicopter air ambulance operation, sign it, and record the date and time. The certificate holder must retain the original or a copy at a location specified in its operations manual for at least 90 days from the date of the operation. The worksheet documents that the operator considered flight risks (obstacles, terrain, landing zones, fuel), human factors (crew fatigue and stressors), weather along the route, and whether another operator had already refused the flight. This is the single most distinctive HAA record — and the one most likely to be examined after any event.
Operations Control Specialist (OCS) Training Records
Duration of employment + 90 days14 CFR §135.619Required if you operate 10 or more helicopter air ambulances and therefore must maintain an operations control center. The certificate holder must keep a training record for each operations control specialist for the duration of that individual’s employment and for 90 days after. The record documents initial training (a minimum of 80 hours, or 40 hours with at least two years of relevant aviation experience), recurrent training (a minimum of 40 hours annually), and the dates and results of the required knowledge and practical examinations.
Medical-Personnel Briefing & Training Records
24 months from completion14 CFR §135.621Before each operation, medical personnel must be briefed on the required safety topics — unless they completed the certificate holder’s FAA-approved medical-personnel training program (at least 4 hours of ground training plus at least 4 hours of training in and around an air ambulance helicopter) within the preceding 24 calendar months. The certificate holder must keep a training record for each person — name, completion date, and a description of the training — for 24 months after completion. A lapsed 24-month window means the per-flight briefing requirement is back in force.
PIC Instrument-Qualification Records
Per the pilot records rule14 CFR §135.603 / §135.243After April 24, 2017, an HAA pilot in command must hold a helicopter instrument rating or an airline transport pilot certificate (with appropriate category and class ratings) that is not limited to VFR, and must meet §135.243. The records that prove this — certificates, ratings, and the §135.243 currency items — live in the pilot record alongside the other airman qualification documents. See the Part 135 pilot records guide for the full set.
HTAWS & Flight Data Monitoring Documentation
With the aircraft record14 CFR §135.605 / §135.607The HTAWS installation (TSO-C194, required after April 24, 2017) and the associated Rotorcraft Flight Manual revision, plus the approved flight data monitoring system (required after April 23, 2018), are documented in the aircraft record. These sit next to the other airworthiness records — airworthiness directive compliance, inspection sign-offs, and maintenance entries. See airworthiness directive compliance records and §43.9 maintenance-entry requirements.
The universal Part 135 record stack still applies on top of Subpart L
Every HAA operator is also a Part 135 operator, which means the general records do not go away. Maintenance records (kept until the work is repeated, superseded, or for one year, with the longer-retention items like total time-in-service, current status of ADs, and major alterations held differently), pilot records, training records, the drug and alcohol program, and the duty and rest records under §135.267 are all in scope. The HAA-specific records are additions, not replacements. For the complete picture, start with what records a Part 135 operator must keep and the drug and alcohol program records checklist.
The Pre-flight Risk Analysis Worksheet: The Record That Defines HAA Compliance
If there is one document that distinguishes a helicopter air ambulance program from any other Part 135 operation, it is the pre-flight risk analysis worksheet required by 14 CFR §135.617. The certificate holder must establish and document an FAA-approved pre-flight risk analysis, and the pilot in command must complete the worksheet before the first leg of each operation, sign it, and record the date and time. The certificate holder then retains the original or a copy at a location named in its operations manual for at least 90 days.
The 90-day floor is the regulatory minimum, not the practical one. Because the worksheet is the contemporaneous evidence of how the crew evaluated risk before launch, it becomes central in any accident or incident investigation, in insurance review, and in internal safety trend analysis. Many operators keep these worksheets for years. The recordkeeping failure modes are specific and recurring:
Unsigned or undated worksheets
The rule is explicit that the PIC signs and records the date and time. A worksheet that exists but is unsigned, or missing the time entry, does not demonstrate the analysis was completed before the leg — it is a finding waiting to be written.
Worksheets stored somewhere other than the operations manual location
The rule ties retention to a location specified in the operations manual. If worksheets are scattered across base offices, crew tablets, and email, the operator cannot reliably produce them at the named location — which is itself the obligation.
The "other operator refused" element not documented
The pre-flight risk analysis must address the procedure for determining whether another operator already declined the flight (an explicit element of the §135.617 analysis). When that determination is not captured on the worksheet, the analysis is incomplete on its face.
Worksheets purged at exactly 90 days
Treating 90 days as a destruction date rather than a retention floor leaves the operator without the record precisely when a delayed investigation or claim reaches back past three months.
Where the operations control center fits into the worksheet
For operators required to run an operations control center under §135.619, the operations control specialist participates in the pre-flight risk analysis — confirming the worksheet is completed, verifying entries, assisting with risk mitigation, and providing a written acknowledgment, with date and time, that the flight can proceed. That makes the worksheet a shared record between the PIC and the OCS, and both the worksheet and the OCS’s acknowledgment need to be retained and retrievable. FileFlo indexes and tracks these records; it does not act as your operations control center or perform the risk analysis.
Know which §135.617 worksheets and training records are missing before the FAA does
FileFlo is a compliance document intelligence platform that classifies and tracks over 600 document types — including HAA pre-flight risk analysis worksheets, OCS and medical-personnel training records, pilot instrument-qualification records, and HTAWS and flight data monitoring documentation — against the governing CFR section. It surfaces retention gaps and assembles an inspector-ready binder. It is the proof layer, not your OCC, dispatch, or safety program. Starter $89/mo. Professional (unlimited) $299/mo. 5-day free trial, no credit card required.
Operations Control Centers and the OCS Training Record (§135.619)
Under 14 CFR §135.619, a certificate holder that operates 10 or more helicopter air ambulances must establish and maintain an operations control center staffed by operations control specialists. The threshold is the fleet size — operators below 10 air ambulance helicopters are not required to run an OCC, though they may still use operations control functions. For those that must, the section creates both duty requirements and a distinct training-record obligation.
OCS duties the records must support
- Two-way communication capability with HAA pilots
- Weather briefings — current and forecast conditions along the planned route
- Monitoring the progress of each flight
- Participating in the pre-flight risk analysis: confirming the worksheet is complete, verifying entries, assisting with risk mitigation
- Providing written acknowledgment, with date and time, that the flight can proceed safely
What the OCS training record must show
- Initial training — minimum 80 hours (or 40 hours with 2+ years relevant aviation experience)
- Recurrent training — minimum 40 hours annually
- Dates and results of required knowledge and practical examinations
- A chronological log of training courses and hours completed
- Retention: duration of employment plus 90 days after
The retention rule here is unusual: it is keyed to employment status, not a fixed number of years. The training record must be kept for as long as the specialist is employed and for 90 days after they leave. That makes employee offboarding a recordkeeping event — when an OCS departs, the clock starts, and the record still has to be retrievable for another 90 days. An operator that purges personnel files immediately on departure can find itself non-compliant on a record it was required to hold. FileFlo tracks the record and its retention clock; it does not run the operations control center or perform any operations control function.
Duty and Rest (§135.267) and the 2027 SMS Deadline
§135.267 — Flight Time and Rest for Unscheduled Crews
Helicopter air ambulance flying is, by its nature, unscheduled on-demand flying — so the governing flight-time and rest rule is 14 CFR §135.267 (unscheduled one- and two-pilot crews), not the scheduled-operations sections. The records that prove compliance — flight time logs, duty start/end times, and rest periods — are squarely in scope on an FAA visit.
| Limit | §135.267 requirement |
|---|---|
| Daily flight time — one-pilot crew | May not exceed 8 hours (combined with any other commercial flying in the same 24-hour period) |
| Daily flight time — two-pilot crew | May not exceed 10 hours (combined with any other commercial flying in the same 24-hour period) |
| Required rest | At least 10 consecutive hours of rest during the 24-hour period preceding the planned completion time of the assignment |
| 14-hour duty exception | Flight time may occur within a regularly assigned duty period of no more than 14 hours, if immediately preceded and followed by at least 10 consecutive hours of rest |
FileFlo is the proof layer, not your scheduling system. §135.267 is a flight-time and rest limit; complying with it is a scheduling and operations function that lives in your operations control and crew-scheduling tools. FileFlo classifies, indexes, and retention-tracks the records that prove the limits were met — it does not build duty rosters, run flight-following, or schedule crews, and it does not connect live to those systems.
The 2024 SMS Rule — All Part 135, One Deadline
The FAA’s 2024 final rule extended the Safety Management System requirement of 14 CFR Part 5 to all Part 135 certificate holders. There is no aircraft-count threshold and no helicopter air ambulance carve-out — Part 5.1(b) extends the requirement to any person holding or applying for a Part 119 certificate authorizing Part 135 operations. The compliance deadline is a single date: May 28, 2027.
For HAA operators, an SMS is in many ways a formalization of discipline they already practice. The §135.617 pre-flight risk analysis is, in substance, safety risk management applied flight-by-flight. The SMS rule wraps that into the four required components — safety policy, safety risk management, safety assurance, and safety promotion — and adds an explicit documentation and records dimension: the hazard reports, risk assessments, and safety-assurance data that demonstrate the system is functioning. Those records join the binder.
The SMS deadline does not change the HAA records — it adds a layer on top of them. For the full breakdown of the rule, the four components, and what records the FAA will expect, see the FAA Part 135 SMS 2027 deadline guide. To pressure-test how an inspector approaches an HAA program end to end, see how to prepare for a Part 135 FAA surveillance audit.
Frequently Asked Questions
What CFR sections govern helicopter air ambulance (HAA / HEMS) operations under Part 135?
Helicopter air ambulance operations are governed by 14 CFR Part 135 Subpart L, sections §135.601 through §135.621. The subpart was added by the FAA’s 2014 HAA final rule and phased in over several years. Key sections: §135.601 (applicability and definitions), §135.603 (pilot-in-command instrument qualifications), §135.605 (Helicopter Terrain Awareness and Warning System / HTAWS), §135.607 (flight data monitoring system), §135.609 (VFR ceiling and visibility for Class G airspace), §135.611 (IFR operations at locations without weather reporting), §135.613 (approach/departure IFR transitions), §135.615 (VFR flight planning), §135.617 (pre-flight risk analysis), §135.619 (operations control centers), and §135.621 (briefing of medical personnel). On top of Subpart L, HAA operators remain subject to all the general Part 135 requirements — duty and rest under §135.267, maintenance recordkeeping, pilot records, and the drug and alcohol program. HAA authority itself is issued through an operations specification (OpSpec A021).
How long must a Part 135 HAA operator retain pre-flight risk analysis worksheets?
Under 14 CFR §135.617, the pilot in command must complete a pre-flight risk analysis worksheet before the first leg of each helicopter air ambulance operation, sign it, and record the date and time. The certificate holder must retain the original or a copy of each completed worksheet at a location specified in its operations manual for at least 90 days from the date of the operation. This 90-day floor is a minimum — because the worksheet is the contemporaneous record that the operator evaluated weather, obstacles, terrain, fuel, crew fatigue, and whether another operator already refused the flight, many operators retain these worksheets far longer to support accident investigation, insurance, and trend analysis. A missing or unsigned worksheet for a flight that drew FAA attention is a recordkeeping finding independent of the flight itself.
How long must operations control specialist (OCS) training records be kept?
Under 14 CFR §135.619, a certificate holder that operates 10 or more helicopter air ambulances must establish an operations control center (OCC) staffed by trained operations control specialists. The certificate holder must maintain a training record for each operations control specialist for the duration of that individual’s employment and for 90 days thereafter. The record must document the OCS training program — initial training (a minimum of 80 hours, or 40 hours for candidates with at least two years of relevant aviation experience), recurrent training (a minimum of 40 hours annually), and the dates and results of required knowledge and practical examinations. Operators below the 10-aircraft threshold are not required to run an OCC, but if they choose to use operations control specialists, the supporting documentation still needs to demonstrate the specialists are qualified for the duties they perform.
How long must HAA medical-personnel briefing and training records be retained?
Under 14 CFR §135.621, before each helicopter air ambulance operation the pilot in command (or a designated crewmember) must brief medical personnel on safety topics including the passenger briefing items in §135.117(a) and (b), physiological aspects of flight, patient loading and unloading, safe operations around the helicopter, in-flight and emergency procedures, and communications with the pilot. The full briefing may be omitted if the medical personnel completed the certificate holder’s FAA-approved medical personnel training program — at least 4 hours of ground training plus at least 4 hours of training in and around an air ambulance helicopter — within the preceding 24 calendar months. The certificate holder must keep a training record for each person, containing the individual’s name, the completion date, and a description of the training, for 24 months after completion.
What are the flight time and rest limits for HEMS pilots under §135.267?
Helicopter air ambulance flying is almost always unscheduled on-demand flying, so it falls under 14 CFR §135.267 (flight time limitations and rest requirements for unscheduled one- and two-pilot crews) rather than the scheduled-operations rule. A crewmember’s assigned flight time, when added to any other commercial flying in the same 24-hour period, may not exceed 8 hours for a one-pilot crew or 10 hours for a two-pilot crew. Each assignment must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment. There is a limited exception that allows flight time to occur within a regularly assigned duty period of no more than 14 hours, provided that duty period is immediately preceded and followed by at least 10 consecutive hours of rest. Operators must keep the duty and rest records that prove these limits were met. Note: §135.267 is about flight time and rest, not duty-time scheduling software — FileFlo tracks the records that prove compliance, it does not run your scheduling or dispatch system.
Does the 2024 FAA Safety Management System (SMS) rule apply to helicopter air ambulance operators?
Yes. The FAA’s 2024 final rule expanding 14 CFR Part 5 applies to all Part 135 certificate holders — there is no aircraft-count threshold and no carve-out for helicopter air ambulance operators. Part 5.1(b) extends the SMS requirement to any person who holds or applies for a Part 119 certificate authorizing Part 135 operations. The compliance deadline is a single date: May 28, 2027. For HAA operators, the SMS overlays the safety-risk-management discipline they already practice through the §135.617 pre-flight risk analysis, but it formalizes it into the four SMS components (safety policy, safety risk management, safety assurance, and safety promotion) and adds a documentation and records expectation. The pre-flight risk analysis worksheets, hazard reports, and safety assurance data become part of the evidence an operator must be able to produce.
When was HTAWS and the flight data monitoring system required on air ambulance helicopters?
Two equipment mandates from the HAA rule carry their own dates. Under 14 CFR §135.605, after April 24, 2017, no person may operate a helicopter in helicopter air ambulance operations unless it is equipped with a Helicopter Terrain Awareness and Warning System (HTAWS) meeting TSO-C194, and the Rotorcraft Flight Manual must include HTAWS procedures and the correct crew response to its warnings. Under 14 CFR §135.607, after April 23, 2018, no person may operate a helicopter in air ambulance operations unless it is equipped with an approved flight data monitoring system that operates continuously from before takeoff through flight termination. From a records standpoint, the supporting documentation — the HTAWS installation and the flight data monitoring system approval, plus the RFM revision — belongs in the aircraft record alongside airworthiness directive and inspection records.
How is FileFlo used by a Part 135 HAA operator?
FileFlo is a compliance document intelligence platform — the proof layer, not the operation. It classifies and indexes the documents an HAA program generates (pre-flight risk analysis worksheets, OCS and medical-personnel training records, pilot instrument-qualification records, HTAWS and flight data monitoring approvals, duty and rest logs, drug and alcohol program records), maps each to the governing CFR section, tracks expirations and retention clocks, and assembles an inspector-ready binder. It does not run your operations control center, your dispatch or flight-following, your safety management system, or your maintenance-tracking program, and it does not connect live to those systems. It tells you which records exist, which are expiring, and which are missing — so a §135.617 worksheet gap or a lapsed medical-personnel training record surfaces weeks before an FAA surveillance visit, not during it.
Related Part 135 & Aviation Records Reading
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