Every charter passenger has heard a version of it: belts low and tight, exits here and here, oxygen if the cabin depressurizes. On a Part 135 flight, that briefing is not customer-service theater — it is a regulatory duty the pilot in command owes before every takeoff. But here is the part that trips operators up during an audit: the briefing itself is an operational act, performed and gone, while the FAA’s interest is overwhelmingly in the documents that prove the program behind it exists — the manual procedure, the printed cards, and the crew training.
That gap is where this guide lives. The briefing requirements in 14 CFR Part 135 are concentrated in a single dense section — §135.117 — with the cabin seat-belt and child-restraint rule sitting alongside it in §135.128. Smoking and alcohol, which operators often assume live inside the briefing rule, are actually separate sections. Untangling which obligation is which — and, more importantly, which produces an auditable document — is what keeps a cabin-safety surveillance review from turning into a finding.
We’ll walk the §135.117(a) briefing items exactly as the rule enumerates them, cover who is allowed to give the briefing under (c) and (d), the printed-card requirement in (e), the §135.128 restraint rule including the child-under-two and child-restraint-system provisions, and the separate smoking and alcohol sections — then show how all of it collapses into the four document homes an FAA surveillance audit actually checks.
The Distinction That Matters: Operational Act vs. Auditable Record
Before any of the specific rules, internalize the single most useful idea in this whole topic. A great deal of cabin safety under Part 135 is performed, not filed. The pilot in command physically briefs passengers; the crew physically verifies belts and seat backs; a flight attendant or crewmember physically secures a child restraint. None of those acts produces a piece of paper you tuck into a per-flight folder. The FAA does not expect a stack of signed briefing receipts.
What the FAA does expect — and what an inspector reviews during surveillance — are the documents upstream of the flight that prove the operator has a compliant program and qualified people to execute it. Those fall into four homes:
General Operations Manual (GOM)
The briefing procedure, seat-belt and child-restraint procedures, smoking and alcohol policies, and the designation of who is qualified to brief passengers.
Printed Passenger Safety Cards
The §135.117(e) cards — exit diagrams and emergency-equipment instructions — matched to each specific aircraft configuration.
Crew Training & Checking Records
Initial and recurring training proving each crewmember was trained on passenger briefings, cabin safety, and emergency procedures.
Aircraft Equipment / Configuration
The exits, survival equipment, fire extinguishers, and flotation gear the briefing and cards reference — and the records that confirm them.
Why this framing protects you
Operators sometimes over-engineer cabin safety by trying to capture every briefing as a record, and under-engineer the things that are actually audited — like keeping the GOM briefing procedure current with the fleet, or proving recurring crew training happened on schedule. The rule structure tells you where to spend effort: get the manual, the cards, and the training documentation right, and the operational act takes care of itself because trained crews following a current procedure do the briefing correctly by default.
The Pre-Flight Briefing Items — 14 CFR §135.117(a)
Under §135.117(a), before each takeoff each pilot in command of an aircraft carrying passengers must ensure that all passengers have been orally briefed on the items the section enumerates. Two of those items are conditional — they apply only when the flight meets a specific condition (extended overwater, or operations above 12,000 feet MSL). The rest apply to the ordinary passenger-carrying flight.
| Item | What the PIC must brief | Applies |
|---|---|---|
| (a)(1) | Smoking — when, where, and the conditions under which it is prohibited | Always |
| (a)(2) | Use of safety belts, including how to fasten and unfasten them | Always |
| (a)(3) | Placement of seat backs in an upright position before takeoff and landing | Always |
| (a)(4) | Location and means for opening the passenger entry door and emergency exits | Always |
| (a)(5) | Location of survival equipment | Always |
| (a)(6) | Ditching procedures and the use of required flotation equipment | Extended overwater operation |
| (a)(7) | The normal and emergency use of oxygen | Operations above 12,000 ft MSL |
| (a)(8) | Location and operation of fire extinguishers | Always |
| (a)(9) | Use of life preservers and ditching procedures | Certain rotorcraft ops beyond autorotational distance from shoreline |
Item descriptions paraphrase the enumerated topics of 14 CFR §135.117(a). Read the full section text for the exact regulatory language and any conditions specific to your aircraft category and operation. The helicopter overwater item turns on flight beyond autorotational distance from the shoreline rather than the fixed-wing distance threshold.
The conditional items are where briefings quietly go wrong
The oxygen briefing (a)(7) is required when the flight involves operations above 12,000 feet MSL, and the overwater ditching/flotation briefing (a)(6) is required for extended overwater operations. A crew that flies a standard land route 95 percent of the time can fall out of the habit of giving the conditional items on the rare leg that triggers them. The defense is procedural: a GOM briefing procedure that explicitly cues the conditional items by trigger, reinforced in recurring training. That is the documented program an inspector wants to see — not a record of any single flight. For the equipment those briefings reference, see our guide to Part 135 emergency & survival equipment records.
Note that §135.117(a) requires the briefing on the location and means for opening the passenger entry door and the emergency exits — which is exactly what the printed safety card (covered below) must depict for that specific aircraft. The oral briefing and the printed card are designed to reinforce each other, and an inspector will expect them to be consistent with the actual aircraft configuration documented in your aircraft records.
Who Is Allowed to Deliver the Briefing — §135.117(b), (c) & (d)
The briefing is not just a list of topics; the rule also constrains who delivers it and adds a duty for passengers who need help.
§135.117(b) — Passengers Who May Need Assistance
Separate from the general briefing, §135.117(b) addresses passengers who may need the assistance of another person to move expeditiously to an exit in an emergency — and any attendant of such a passenger. This is the individual-assistance briefing, and it is distinct from the general oral briefing under (a). A common drafting error is folding this into the standard briefing language; the rule treats it as its own obligation, and your manual procedure should too.
§135.117(c) — Given by the PIC or a Crewmember
The required oral briefing must be given by the pilot in command or a crewmember. This is the default rule and it covers the vast majority of operations. The compliance implication for records: the people delivering briefings must be trained crewmembers, and the proof of that training is a crew training record — not the briefing itself.
§135.117(d) — The Small-Aircraft Alternative
For an aircraft certificated to carry 19 passengers or less, §135.117(d) provides that the oral briefing shall be given by the pilot in command, a crewmember, or another qualified person designated by the certificate holder and approved by the Administrator. The phrase that matters for the records layer is “qualified… designated by the certificate holder and approved by the Administrator.” If you rely on this alternative, the designation and the qualification need to be evidenced — in your manual and your personnel/training documentation — not merely asserted. Do not collapse this to “anyone can brief on a small aircraft”; the qualification and approval conditions are part of the rule.
A note on larger cabins and public-address systems
On larger Part 135 aircraft, the way a briefing is delivered can interact with cabin-equipment rules — for example, 14 CFR §135.150 requires a public address system and a crewmember interphone system on aircraft having a passenger seating configuration of more than 19 seats. That is a separate equipment requirement, not part of §135.117, but it is the kind of adjacent rule an inspector may probe when reviewing how cabin briefings and crew communication actually work on a given aircraft. Confirm which equipment rules apply to your specific aircraft and operations specifications rather than assuming.
Printed Passenger Safety Cards — 14 CFR §135.117(e)
This is the one part of §135.117 that produces a tangible, auditable artifact on the aircraft. Under §135.117(e), the oral briefing must be supplemented by printed cards for the use of each passenger, located in convenient locations on the aircraft, containing a diagram of and methods of operating the emergency exits and other instructions necessary for the use of emergency equipment on board the aircraft.
The card is a per-aircraft-type document
Because the card must depict this aircraft’s exits and this aircraft’s emergency equipment, a generic card is not enough — and a card built for a different variant of the same type can be wrong. Operators with mixed fleets must control card revisions by aircraft configuration, the same way they control checklists. The card is, in effect, a controlled document.
The recurring finding: missing, illegible, or wrong-configuration cards
An inspector conducting a cabin check confirms the cards are present in convenient locations, legible, and correct for that aircraft. The failure modes are mundane and common: cards that walked off the aircraft, cards faded past legibility, or cards that reflect an older interior configuration after a cabin modification. Each is a documentation finding even though the exits and equipment themselves are fine. Tracking card revisions against each aircraft’s configuration is precisely the kind of thing that lapses when it lives in someone’s memory rather than a tracked record.
Keep your cabin-safety documents current — and audit-ready
FileFlo is a compliance document intelligence platform — a read-only proof layer for the documents behind your cabin-safety program. Upload your GOM revision pages, your per-aircraft safety-card revisions, and your crew training and checking records, and FileFlo:
- Classifies each document against the governing topic — §135.117 briefing, §135.128 restraints, §135.121/§135.127 smoking & alcohol, crew training
- Extracts revision dates and recurring training due-dates and tracks them per aircraft and per crewmember
- Flags when a manual revision, a safety-card revision, or a recurring training event is approaching or overdue
- Assembles an audit-ready binder organized by topic for an FAA surveillance review
FileFlo does not deliver passenger briefings, run your safety or training program, fly the aircraft, or act as your system of record for crew qualifications or maintenance. The operational work stays with your crews and your director of operations. FileFlo keeps the paper that proves the program audit-ready. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
Seat Belts & Child Restraints — 14 CFR §135.128
Sitting alongside the briefing rule is §135.128, which governs the use of seats, safety belts, and child restraint systems. The general rule is straightforward and absolute: each person on board an aircraft operated under Part 135 must occupy an approved seat or berth with a separate safety belt properly secured about him or her during movement on the surface, takeoff, and landing.
The child-under-two exception
The rule includes an exception for a child who has not reached his or her second birthday, who may be held by an adult who is occupying an approved seat or berth, provided the child does not occupy or use a restraining device prohibited by the section. This is the “lap child” allowance — but note it is an allowance, framed around an adult in an approved seat, not a blanket permission.
Approved child restraint systems — and what is not approved
A child may be transported in an approved child restraint system furnished by the certificate holder or by the passenger, when the system bears the required FAA-recognized labeling and is secured to a forward-facing seat in accordance with the manufacturer’s instructions. Importantly, the section provides that the certificate holder may not prohibit a parent, guardian, or attendant from using an approved child restraint system. Several device types are generally not approved for use during surface movement, takeoff, and landing:
Read the exact section text for the precise labeling dates and any limited exceptions; the categories above reflect the device types the rule restricts during the critical phases of flight.
Where §135.128 lands in the records layer
Like the briefing, §135.128 is fundamentally an operational compliance rule the crew executes — there is no per-passenger restraint filing. The documents that touch it are your GOM procedures for seating, belts, and child restraints, and the crew training that ensures crewmembers know which restraint devices are and are not approved and how to secure them. When operators get this wrong in an audit, it is almost always because the manual procedure is stale or the training did not clearly cover the prohibited device types — both of which are documentation problems, not in-flight ones.
Smoking & Alcohol — Separate Sections, Not Part of the Briefing Rule
A frequent manual error is treating smoking and alcohol as if they live inside §135.117. They don’t. The briefing rule only requires that passengers be told about the smoking prohibition (item (a)(1)); the operational smoking and alcohol rules are their own sections.
Smoking — §135.127
14 CFR §135.127 covers passenger information requirements and prohibitions on smoking — including the display of “No Smoking” information, prohibitions on smoking in lavatories, and related provisions. The briefing item (a)(1) tells passengers when and where smoking is prohibited; §135.127 is the substantive operational and signage rule behind that prohibition.
Alcohol — §135.121
14 CFR §135.121 governs alcoholic beverages: a passenger may not drink alcohol aboard the aircraft unless the certificate holder served it, the certificate holder may not serve a person who appears to be intoxicated, and a person who appears to be intoxicated may not be allowed to board. This is not a briefing item at all — it is an independent operational rule for the crew and operator.
Why the distinction shows up in audits
When a GOM cites the wrong section for a policy — say, anchoring its alcohol policy to §135.117 instead of §135.121 — it signals a manual that was assembled loosely, and it invites a closer look. Getting the citations right in your manual is part of what makes the document set credible. This is the same discipline that underpins a well-built General Operations Manual and a clean set of operations specifications.
The Cabin-Safety Records Set — What an Audit Actually Checks
Pull it together and the “cabin safety record set” is not a pile of per-flight briefing slips — it is a small, high-leverage bundle of documents that prove the program exists, is current, and is internally consistent. This set sits alongside your broader Part 135 training program records and is part of what a principal operations inspector reviews during surveillance.
The Cabin-Safety Document Checklist
Notice the pattern: every line is a “can you produce the current document” question, not a “did you do the briefing” question. That is the structural reason cabin-safety compliance is a document-management problem — the manual has to be current, the cards have to match the aircraft, and the training has to be on schedule. Each of those is a date that can quietly expire. Closely related document sets feed the same audit: check airman and flight instructor records, required management personnel qualifications, and the operator’s grasp of operational control.
Make the cabin-safety binder a non-event
Because the cabin-safety record set is small but date-driven, it is exactly the kind of thing a compliance document layer keeps effortlessly current. FileFlo classifies your GOM revisions, your per-aircraft safety cards, and your crew training records against the governing topics; extracts the revision and training due-dates; sends advance alerts before a manual revision or a recurring training event lapses; and assembles the audit-ready binder organized by topic for any FAA surveillance review.
FileFlo is a read-only proof layer. It does not deliver passenger briefings, run your safety or training program, fly the aircraft, or serve as your system of record for crew qualifications or maintenance. The operational work stays with your crews and your director of operations. FileFlo keeps the paper that proves it audit-ready.
Frequently Asked Questions
What does 14 CFR §135.117(a) require a Part 135 pilot to brief passengers on before each takeoff?
Section 135.117(a) requires that before each takeoff, the pilot in command of an aircraft carrying passengers ensure that all passengers have been orally briefed on a list of items. The enumerated topics are: smoking (when, where, and the conditions under which it is prohibited); use of safety belts and how to fasten and unfasten them; placement of seat backs in an upright position before takeoff and landing; location and means for opening the passenger entry door and emergency exits; location of survival equipment; ditching procedures and use of required flotation equipment if the flight involves an extended overwater operation; the normal and emergency use of oxygen if the flight involves operations above 12,000 feet MSL; location and operation of fire extinguishers; and, for certain rotorcraft operations beyond autorotational distance from the shoreline, the use of life preservers and ditching procedures. Two of these items are conditional — they apply only when the flight is extended overwater or above 12,000 feet MSL. Most of the briefing is an operational act performed at the gate; what is durably documented is the procedure in your manual and the crew training that proves the crew knows how to deliver it.
Is the passenger briefing itself a record FileFlo or the FAA tracks per flight?
Generally no. The oral briefing under §135.117(a) is a real-time operational duty the pilot in command performs before each takeoff — it is not, by the rule's own terms, a per-flight document you file and retain the way you retain a maintenance entry or a training record. What is documented and auditable is upstream of the flight: the briefing procedure written into your General Operations Manual (GOM), the printed passenger safety/briefing cards required by §135.117(e), and the crew training and checking records that prove each crewmember was trained to give the briefing correctly. An FAA inspector does not ask for a stack of per-flight briefing receipts; they ask to see the procedure in your manual, the current cards on the aircraft, and the training records behind the crew. That distinction — operational act versus the documents that prove the program exists — is the entire point of this guide.
What does §135.117(e) require for printed passenger safety cards?
Section 135.117(e) requires that the oral briefing be supplemented by printed cards for the use of each passenger, located in convenient locations on the aircraft. Those cards must contain a diagram of, and methods of operating, the emergency exits, and other instructions necessary for the use of emergency equipment on board the aircraft. In practice this means the card is a per-aircraft-type document: the exit diagram and equipment instructions must match the actual configuration of that make and model. The compliance question an inspector raises is whether the cards on the aircraft are present, legible, and correct for that specific aircraft configuration — a card for the wrong variant, or a missing card, is a documentation finding even though the equipment itself may be perfectly serviceable.
Who is allowed to deliver the §135.117(a) passenger briefing?
Under §135.117(c), the required oral briefing must be given by the pilot in command or a crewmember. Section 135.117(d) provides the rule for smaller aircraft: notwithstanding paragraph (c), for an aircraft certificated to carry 19 passengers or less, the oral briefing required by paragraph (a) shall be given by the pilot in command, a crewmember, or another qualified person designated by the certificate holder and approved by the Administrator. The point that matters for the records layer: whoever the operator designates to give the briefing must be qualified and, where the rule requires it, approved — and that qualification and approval is something the operator should be able to evidence through its manual and personnel/training documentation rather than assert.
What does 14 CFR §135.128 say about seat belts and child restraint systems?
Section 135.128 governs the use of seats, safety belts, and child restraint systems. The general rule is that each person on board an aircraft operated under Part 135 must occupy an approved seat or berth with a separate safety belt properly secured about him or her during movement on the surface, takeoff, and landing. There is an exception for a child who has not reached his or her second birthday, who may be held by an adult, and there are provisions for an approved child restraint system. Approved child restraint systems must bear the required FAA-recognized labeling, and certain device types — booster-type, vest-type, harness-type, and lap-held child restraints — are generally not approved for use during movement on the surface, takeoff, and landing. The certificate holder may not prohibit a parent or guardian from using an approved child restraint system. This is an operational compliance rule for the crew; the documentation that touches it lives in your manual procedures and crew training, not in a per-passenger filing.
Does §135.117 cover smoking and alcohol, or are those separate sections?
Smoking appears in two places and alcohol in a third. The smoking briefing item — telling passengers when, where, and under what conditions smoking is prohibited — is item (1) of the §135.117(a) oral briefing. The broader operational smoking rules, including passenger information signage and lavatory smoking prohibitions, are in a separate section, 14 CFR §135.127 (passenger information requirements and prohibitions on smoking). Alcoholic beverages are governed by their own section, 14 CFR §135.121, which prohibits a passenger from drinking alcohol aboard the aircraft unless the certificate holder served it, bars serving anyone who appears to be intoxicated, and prohibits boarding a person who appears to be intoxicated. So the briefing rule, the smoking-information rule, and the alcohol rule are three distinct sections — and a manual that conflates them is a common drafting weakness an inspector will notice.
Where do cabin-safety obligations actually get documented in a Part 135 operation?
In four document homes. First, the General Operations Manual (GOM): the passenger briefing procedure, the seat-belt and child-restraint procedures, the smoking and alcohol policies, and who is designated and qualified to deliver briefings all live in the manual. Second, the printed passenger safety/briefing cards required by §135.117(e), which must match each aircraft configuration. Third, crew training and checking records — initial and recurring training that proves crewmembers were trained on passenger briefings, cabin safety, and emergency procedures. Fourth, the aircraft equipment/configuration records that the cards and briefings reference (exits, survival equipment, fire extinguishers, flotation gear). An FAA surveillance review of cabin safety is essentially a check that those four document sets are present, current, internally consistent, and consistent with the aircraft — which is a document-management problem more than an in-flight one.
Does FileFlo deliver passenger briefings, run my cabin-safety program, or manage my crew training?
No. FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not deliver passenger briefings, run your safety or training program, fly the aircraft, or act as your system of record for crew qualifications or maintenance. What it does is classify and track the documents that prove your cabin-safety program exists and is current: your GOM revision pages covering the §135.117 briefing and §135.128 restraint procedures, the printed safety-card revisions per aircraft type, and the crew training and checking records that show crewmembers are trained to brief passengers. It extracts revision dates and training due-dates, flags when a manual revision or a recurring training event is approaching or overdue, and assembles an audit-ready binder organized by topic for an FAA review. The operational work — actually briefing passengers, actually training crews — stays with the operator. FileFlo keeps the paper that proves it audit-ready.
Chad Griffith
Founder, FileFlo — compliance document intelligence
FileFlo helps Part 135 operators keep the documents that prove their compliance programs — manuals, safety cards, training records, and the rest — classified, tracked, and audit-ready. This guide is a compliance-document perspective on the §135.117 and §135.128 cabin-safety rules; it is not legal, operational, or airworthiness advice, and it is not a substitute for your director of operations, your principal operations inspector, or counsel interpreting your specific manual and aircraft.
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 Training Program Recordkeeping
Where the crew training behind passenger briefings and cabin safety is actually documented
Part 135 Emergency & Survival Equipment Records
The flotation, survival, and fire-extinguisher equipment the briefing items and safety cards reference
Part 135 GOM & MOM Manual Requirements
The manual home for the briefing, restraint, smoking, and alcohol procedures
What Is Operational Control in Part 135
The §1.1 definition that frames who is responsible for the operation the cabin briefing supports
More Part 135 & Aviation Records Guides
Prove your cabin-safety program — without managing it for you
FileFlo classifies the documents behind your §135.117 briefings and §135.128 restraint procedures — your GOM revisions, your per-aircraft safety cards, and your crew training records — extracts every revision and training due-date, and sends advance alerts before any of them lapses. Keep the small-but-date-driven cabin-safety record set current and audit-ready in one place, organized by topic.
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