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Aviation Compliance Guide — 14 CFR Part 135 Maintenance Reporting

Part 135 Service Difficulty Reports §135.415 SDRs, the 96-Hour Clock, and the §135.417 Monthly MIS

Two reporting rules sit in Part 135 Subpart J that apply to every certificate holder — single Caravan or 30-jet fleet, nine seats or thirty. One runs on a 96-hour clock after a defined 24-hour window; the other runs on a monthly calendar. Here is exactly what each one requires, the full list of reportable occurrences, and the maintenance records that have to stand behind every report you transmit.

Quick Answer

14 CFR §135.415 requires every Part 135 certificate holder to report each failure, malfunction, or defect in 16 listed occurrence categories — plus, under §135.415(c), any other failure that in the operator's opinion has endangered or may endanger safe operation. Reports cover a 24-hour period from 0900 to 0900 local time and must be submitted to the FAA collection point in Oklahoma City within the next 96 hours (weekend reports may roll to Monday; holiday reports to the next workday). Separately, §135.417 requires a monthly Mechanical Interruption Summary — due before the end of the 10th day of the following month to the responsible Flight Standards office — covering flight interruptions, unscheduled aircraft changes, stops, and diversions in multiengine aircraft caused by known or suspected mechanical difficulties below the SDR threshold, plus in-flight propeller featherings. Both rules apply on both §135.411 maintenance tracks.

Chad Griffith, Founder, FileFloLast reviewed: June 10, 202614 min read

Compliance document perspective, not legal advice. This guide explains what 14 CFR §135.411, §135.415, §135.417, and §135.65 require at the reporting and records layer — it is not a substitute for your Director of Maintenance, your Principal Maintenance Inspector, or an aviation attorney's judgment on whether any specific event is reportable.

HomeBlogAviation ComplianceService Difficulty Reports & the MIS

Most of Part 135 Subpart J is about doing maintenance — programs, organizations, inspections, releases. Two sections are different in kind: they obligate the certificate holder to tell the FAA what is breaking. 14 CFR §135.415 is the Service Difficulty Report — the event-driven report with a 96-hour clock. §135.417 is the Mechanical Interruption Summary — the monthly roll-up of the mechanical events that did not rise to SDR level.

Both rules generate paper in two directions. Outbound: the report itself, transmitted on a deadline. Inbound: the maintenance-log entries, corrective actions, and analysis records that an FAA inspector will expect to find behind every report — and behind every event that should have produced one. This guide walks the full text of both sections: who must report under the §135.411 applicability split, the 16 listed occurrences, the timing mechanics, the narrow exceptions, the monthly MIS contents, and the records layer underneath.

For the master index of every Part 135 record — pilot files, drug-and-alcohol, training, maintenance — start with What Records Must a Part 135 Operator Keep and treat this as the reporting-rules deep dive.

96 hrs
SDR submission window after each 0900-to-0900 local reporting period (weekend reports may roll to Monday)
14 CFR §135.415(d)
16
Listed failure / malfunction / defect categories — plus the §135.415(c) endangerment catch-all
14 CFR §135.415(a)
10th day
Monthly MIS deadline — multiengine mechanical interruptions and propeller featherings, to the responsible Flight Standards office
14 CFR §135.417

Who Must Report — §§135.415 and 135.417 Apply on Both Maintenance Tracks

14 CFR §135.411(a) sorts every Part 135 aircraft into one of two maintenance regimes by its type-certificated passenger seating configuration, excluding any pilot seat. Almost everything in Subpart J lands on one side of that line or the other. The two reporting rules land on both:

§135.411(a)(1)Nine passenger seats or fewer

These aircraft "shall be maintained under parts 91 and 43 of this chapter and §§ 135.415, 135.417, 135.421 and 135.422." The maintenance and recordkeeping baseline is the Part 91/43 framework — but the SDR and MIS reporting duties ride on top of it.

§135.411(a)(2)Ten passenger seats or more

These aircraft "shall be maintained under a maintenance program in §§ 135.415, 135.417, 135.423 through 135.443" — the continuous-airworthiness program the industry calls a CAMP. Note the rule text leads with the two reporting sections before the program block. Our CAMP recordkeeping guide covers the §§135.423–135.443 side in depth.

The practical takeaway

There is no seat-count, engine-count, or fleet-size threshold on the reporting duties themselves. A single-pilot, single-Caravan operator owes the FAA the same §135.415 service difficulty reports as a 30-aircraft jet charter — and if the operator flies any multiengine aircraft, the same monthly §135.417 summary. The §135.411 split changes the maintenance program and the records rules underneath (§91.417 versus §135.439); it does not change the reporting obligation. Three smaller wrinkles complete the applicability picture: §135.411(b) lets an operator not otherwise required elect the (a)(2) program; §135.411(c) adds §135.421(c), (d), and (e) for single-engine aircraft used in passenger-carrying IFR operations; and §135.411(d) requires an operator electing §135.364 operations to use the (a)(2) program plus Appendix G.

The 16 Reportable Occurrences — §135.415(a)

Section 135.415(a) requires each certificate holder to "report the occurrence or detection of each failure, malfunction, or defect in an aircraft" concerning the items below. Two words deserve emphasis before the list. Occurrence or detection: the duty attaches when the problem happens in service or when it is found later in the hangar. And concerning: the list scopes subject areas, not exact fact patterns — when an event sits near a listed item, the safe reading is that it is in scope.

The 16 items, reproduced from §135.415(a)(1) through (a)(16) (category tags are ours, added for navigation):

1

Fires during flight and whether the related fire-warning system functioned properly

Fire
2

Fires during flight not protected by related fire-warning system

Fire
3

False fire-warning during flight

Fire
4

An exhaust system that causes damage during flight to the engine, adjacent structure, equipment, or components

Exhaust
5

An aircraft component that causes accumulation or circulation of smoke, vapor, or toxic or noxious fumes in the crew compartment or passenger cabin during flight

Smoke / fumes
6

Engine shutdown during flight because of flameout

Engine
7

Engine shutdown during flight when external damage to the engine or aircraft structure occurs

Engine
8

Engine shutdown during flight due to foreign object ingestion or icing

Engine
9

Shutdown of more than one engine during flight

Engine
10

A propeller feathering system or ability of the system to control overspeed during flight

Systems
11

A fuel or fuel-dumping system that affects fuel flow or causes hazardous leakage during flight

Systems
12

An unwanted landing gear extension or retraction or opening or closing of landing gear doors during flight

Systems
13

Brake system components that result in loss of brake actuating force when the aircraft is in motion on the ground

Systems
14

Aircraft structure that requires major repair

Structure
15

Cracks, permanent deformation, or corrosion of aircraft structures, if more than the maximum acceptable to the manufacturer or the FAA

Structure
16

Aircraft components or systems that result in taking emergency actions during flight (except action to shut-down an engine)

Emergency

What "during flight" means — §135.415(b)

The rule defines its own clock: for the purpose of this section, during flight means "the period from the moment the aircraft leaves the surface of the earth on takeoff until it touches down on landing." Note that item (13) is deliberately scoped outside that window — brake-actuating-force loss is reportable when the aircraft is "in motion on the ground." Taxi events count.

The catch-all — §135.415(c)

Beyond the 16 listed items, the certificate holder must report "any other failure, malfunction, or defect in an aircraft that occurs or is detected at any time if, in its opinion, the failure, malfunction, or defect has endangered or may endanger the safe operation of the aircraft." The judgment is the operator's — which means the operator should be able to document how it made that judgment for events it chose not to report.

Items (14) and (15) are where SDRs meet your structural records

Structure requiring major repair, and cracks, deformation, or corrosion beyond the maximum acceptable to the manufacturer or the FAA, are usually detected — during scheduled inspections, AD compliance work, or a repair-station visit — rather than experienced in flight. That makes them easy to miss as SDR triggers, because the discovery shows up first as a line in an inspection discrepancy list. If the finding leads to a major repair, it also generates its own records trail: the §43.9 maintenance entry and, where an airworthiness directive drove the inspection, the AD compliance record. One hangar finding, three document streams.

The 96-Hour Clock — How and When SDRs Are Filed

Section 135.415(d) builds the deadline in two stages — a fixed daily reporting window, then a submission clock that starts when the window closes:

§135.415(d), unpacked

Each report covers a 24-hour period "beginning at 0900 local time of each day and ending at 0900 local time on the next day," and goes "to the FAA offices in Oklahoma City, Oklahoma." Each report of occurrences during a 24-hour period "shall be submitted to the collection point within the next 96 hours." Two scheduling reliefs are written in: "a report due on Saturday or Sunday may be submitted on the following Monday, and a report due on a holiday may be submitted on the next workday."

1

0900 → 0900 window

The occurrence falls into the 24-hour reporting period running 0900 local to 0900 local.

2

+96 hours

The report for that window must reach the collection point within the next 96 hours.

3

Weekend / holiday roll

Due Saturday or Sunday → following Monday. Due on a holiday → next workday.

What goes in the report — §135.415(e)

The report is transmitted "on a form and in a manner prescribed by the Administrator" and must include as much of the following as is available:

  • The type and identification number of the aircraft.
  • The name of the operator.
  • The date.
  • The nature of the failure, malfunction, or defect.
  • Identification of the part and system involved, including available information pertaining to type designation of the major component and time since last overhaul, if known.
  • Apparent cause of the failure, malfunction or defect (e.g., wear, crack, design deficiency, or personnel error).
  • Other pertinent information necessary for more complete identification, determination of seriousness, or corrective action.

The form and the system, in practice

The CFR text names a place — the FAA offices in Oklahoma City — and leaves the form and manner to the Administrator. In practice, the FAA administers this data through its Service Difficulty Reporting System (SDRS), and operators typically file electronically through the FAA's SDRS web portal rather than mailing paper; the long-standing paper instrument is the FAA's Form 8070-1 family. The submitted data becomes part of a publicly searchable database the FAA and manufacturers use to spot fleet-wide trends. Treat the filing channel as something to confirm with your Principal Maintenance Inspector and document in your manual procedures — the regulatory obligation is the report and the deadline; the transmission mechanics are FAA practice and can change.

Could you produce every SDR you have ever filed — tonight?

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Exceptions, the No-Withholding Rule, and Supplements — §135.415(f)–(h)

§135.415(f) — the duplicate-report relief is narrower than it looks

Paragraph (f) excuses an SDR only for "a certificate holder that is also the holder of a type certificate (including a supplemental type certificate), a Parts Manufacturer Approval, or a Technical Standard Order Authorization, or that is the licensee of a type certificate" — and only if that holder has already reported the failure, malfunction, or defect under §21.3 or §37.17 of 14 CFR, or under the accident reporting provisions of 49 CFR part 830 (the NTSB rules). A charter operator that holds no design approval is outside the class the paragraph describes — so for the typical Part 135 operator, an NTSB notification does not substitute for the SDR. When an event touches both regimes, the conservative practice is to satisfy both.

§135.415(g) — incomplete information is not an excuse

"No person may withhold a report required by this section even though all information required by this section is not available." Read together with paragraph (e)'s "as much of the following as is available," the structure is unambiguous: the 96-hour clock outranks completeness. File what you know; never sit on a report waiting for the teardown results.

§135.415(h) — the supplement duty most operators forget

When the certificate holder gets additional information — "including information from the manufacturer or other agency" — concerning a report it has filed, it "shall expeditiously submit it as a supplement to the first report and reference the date and place of submission of the first report." This is where the records layer earns its keep: you cannot reference the date and place of the first report if you did not keep a copy of what you filed and when. A teardown report that arrives six weeks later is not the end of the story — it is a new filing obligation.

The enforcement frame

Reporting failures are documentation failures the FAA can see from its side of the table: the SDRS database shows what you filed, and your maintenance logs show what happened. A pattern of unreported reportable events is the kind of finding that turns a routine surveillance visit into an enforcement investigation, and FAA civil penalties for regulatory violations can reach $75,000 per violation (49 U.S.C. §46301(a)(1), as implemented in the penalty schedule at 14 CFR §13.301). The cheapest insurance is a clean, dated file of every report and supplement you have ever transmitted.

The Monthly Mechanical Interruption Summary — §135.417

Where §135.415 is event-driven, §135.417 is a calendar rule. Each certificate holder "shall mail or deliver, before the end of the 10th day of the following month, a summary report of the following occurrences in multiengine aircraft for the preceding month to the responsible Flight Standards office." Three scoping facts fall straight out of that sentence: the cadence is monthly with a 10th-day deadline, the destination is your responsible Flight Standards office (not the Oklahoma City collection point SDRs go to), and the subject matter is multiengine aircraft occurrences only.

§135.417(a)Mechanical interruptions

"Each interruption to a flight, unscheduled change of aircraft en route, or unscheduled stop or diversion from a route, caused by known or suspected mechanical difficulties or malfunctions that are not required to be reported under § 135.415." Note the two hedges that widen the net: known or suspected — you do not need a confirmed diagnosis — and the express carve-out that makes the MIS the bucket for everything mechanical that interrupted an operation but fell below the SDR threshold.

§135.417(b)Propeller featherings

"The number of propeller featherings in flight, listed by type of propeller and engine and aircraft on which it was installed." One exclusion: "Propeller featherings for training, demonstration, or flight check purposes need not be reported." The listing requirement matters — the count is broken out by propeller type, engine, and airframe, which means your engine and propeller records need to support that breakdown. Our engine and propeller time-tracking guide covers that records layer.

What a §135.417(a) event looks like on the ground

A King Air turns back ten minutes after departure for a generator fault. A PC-24 swaps to the backup aircraft mid-rotation because a bleed-air fault will not clear. A Navajo diverts for a rough-running engine that turns out to be a fouled plug. None of these necessarily hits a §135.415(a) category or the (c) endangerment threshold — but each is an interruption, unscheduled aircraft change, stop, or diversion from a known or suspected mechanical cause, so each belongs in that month's MIS. The discrepancy and its fix also land in the aircraft maintenance log, and where the fix is deferred, the deferral record — typically under your minimum equipment list — becomes part of the same paper trail an inspector will walk.

A nil month is still a month

The rule's text obligates a summary of the listed occurrences for the preceding month; it does not spell out a nil-report procedure. Many operators file or record a no-occurrences summary anyway, and many Flight Standards offices expect one, because a gap in the monthly sequence is indistinguishable from a missed filing. Whatever convention you and your responsible Flight Standards office settle on, write it into your manual procedures and keep every month's submission — including the nil months — in the file. Consistency of cadence is itself evidence of a functioning reporting system. The format of the summary is likewise something to align with your office, since the section prescribes the content and deadline but no standard form.

SDR vs MIS — Which Report Does an Event Belong In?

The two rules are engineered not to overlap: §135.417(a) expressly excludes anything "required to be reported under § 135.415." So the sorting logic always starts with the SDR question.

DimensionService Difficulty Report
§135.415
Mechanical Interruption Summary
§135.417
TriggerOccurrence or detection of a failure, malfunction, or defect in the 16 listed categories — plus the (c) catch-all for anything the operator judges has endangered or may endanger safe operationFlight interruption, unscheduled aircraft change en route, or unscheduled stop or diversion from known or suspected mechanical difficulty — only when not SDR-reportable; plus in-flight propeller featherings
Aircraft scopeAny aircraft operated under the certificate — no seat- or engine-count limit in the sectionMultiengine aircraft only
Cadence & deadlineEvent-driven: within 96 hours after the 0900-to-0900 reporting period (Sat/Sun reports may roll to Monday; holiday reports to the next workday)Monthly: mail or deliver before the end of the 10th day of the following month
DestinationThe FAA offices in Oklahoma City, Oklahoma (the collection point; electronic filing via SDRS in practice)The responsible Flight Standards office
FormA form and manner prescribed by the Administrator (§135.415(e))No form prescribed in the section — content and deadline only
Overlap ruleWins — an SDR-reportable event is excluded from the MIS§135.417(a) expressly excludes events required to be reported under §135.415

The three-question sort

1. Is it a §135.415 event?

In one of the 16 listed categories — or, in your documented opinion under (c), did it endanger or may it endanger safe operation? File the SDR within 96 hours of the reporting period. It does not also go in the MIS.

2. Did mechanics interrupt an operation?

A multiengine flight interrupted, aircraft swapped en route, or an unscheduled stop or diversion — from a known or suspected mechanical difficulty that is not SDR-reportable? It goes in the monthly MIS, due before the end of the 10th day of the following month.

3. Was a propeller feathered in flight?

Count it in the MIS, listed by propeller type, engine, and aircraft — unless the feathering was for training, demonstration, or flight check purposes.

Whatever the answer, the underlying irregularity still gets recorded in the §135.65 aircraft maintenance log and corrected or deferred — the reports describe events; they never replace the maintenance records.

The Records Behind the Reports

Every SDR and every MIS line item is the visible tip of a records chain that starts in the cockpit. Under 14 CFR §135.65, each certificate holder must provide an aircraft maintenance log, carried on board each aircraft, "for recording or deferring mechanical irregularities and their correction." The pilot in command must enter (or have entered) each mechanical irregularity that comes to the pilot's attention during flight time, and before each flight must determine the status of each irregularity entered at the end of the preceding flight. Whoever takes corrective action — or defers it — must record the action taken in that log under the applicable maintenance requirements. And §135.65(d) requires a procedure, written into the §135.21 manual, for keeping copies of the log in the aircraft for access by appropriate personnel.

That log entry is the seed document. From it grow the corrective-action records — on the nine-or-fewer track, the §43.9 maintenance entry (and §43.11 entries for inspections); on the ten-or-more track, the manual procedures and airworthiness-release chain covered in our CAMP recordkeeping guide — plus the report itself, any §135.415(h) supplement, and the analysis your program does with the data. Your manual's reporting procedures belong in the General Operations / Maintenance Manual, and where maintenance is contracted out, the repair station's records feed the same chain — a defect detected at the repair station is still your reportable detection.

§135.65 aircraft maintenance log

The on-board log of each mechanical irregularity, its correction or deferral, and the PIC status check before each flight — the origin record for every SDR and MIS line.

SDR copies + supplements

A dated copy of every report transmitted within the 96-hour window, plus every §135.415(h) supplement — which must reference the date and place of the first report.

MIS monthly file

Each month's summary — interruptions, unscheduled changes, stops, diversions, and the propeller-feathering counts by propeller, engine, and airframe — including nil months.

Corrective-action records

The §43.9 / §43.11 entries (nine-or-fewer track) or the manual-procedure and airworthiness-release chain (ten-or-more track) that close each irregularity.

Non-report rationale

For judgment calls under §135.415(c): a short documented basis for why an event was assessed as not endangering safe operation. The opinion is yours; the file proves you formed one.

Analysis & SMS stream

On the ten-or-more track, the §135.431 continuing analysis and surveillance system consumes this data; and every Part 135 operator's Part 5 SMS (required by May 28, 2027) builds its safety-assurance loop on the same events.

Retention: the reports point to records kept under other rules

Neither §135.415 nor §135.417 states a retention period for the operator's copy of the report. The substantiating maintenance records live under the records rules for your track — §91.417 on the parts 91/43 side, §135.439 on the program side — and the supplement duty in §135.415(h) presumes you can produce the first report's date and place on demand. The practical standard most inspectors apply is simple: a continuous, dated file of everything transmitted, kept as long as the aircraft is on your certificate. The §135.415 data also feeds forward — the FAA's 2024 SMS rule pulls every Part 135 operator into Part 5 Safety Management Systems by May 28, 2027, and your SDR/MIS history is exactly the kind of safety data the safety-assurance component is built to analyze.

Keep every SDR, MIS, and log entry audit-ready

FileFlo is a compliance document intelligence platform — the proof layer for the records this article describes. It does not file your SDRs, connect to the FAA's SDRS, or run your maintenance tracking, CASS, or SMS. You upload the documents; FileFlo:

  • Classifies each document against the governing rule — SDR copies and supplements (§135.415), monthly MIS summaries (§135.417), maintenance-log pages (§135.65), corrective-action entries (§43.9, §135.439)
  • Indexes everything by aircraft, date, and document type, so the report, the log entry, and the corrective action that belong together are findable together
  • Tracks the recurring-document cadence — a month with no MIS in the file is visible instead of invisible
  • Generates an audit-ready reporting binder for a surveillance visit: every report, every supplement, every underlying record, organized by section

FileFlo sits alongside your Director of Maintenance and your PMI — it keeps the documents that prove your reporting system works; it does not perform maintenance, make reportability judgments, or transmit reports. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.

One more connection worth making: your reporting discipline is visible to the FAA in a way most compliance is not. Inspectors preparing a surveillance visit can query your SDR history before they ever walk in — and then compare it against your maintenance logs on site. The operators who come through clean are the ones whose log entries, reports, and corrective actions reconcile line for line. That reconciliation is a records problem, and it is entirely winnable in advance.

Frequently Asked Questions

What is a Service Difficulty Report (SDR) under Part 135?

An SDR is the report 14 CFR §135.415 requires each Part 135 certificate holder to file when it experiences or detects a failure, malfunction, or defect in an aircraft. Paragraph (a) lists 16 specific occurrence categories — fires during flight, false fire warnings, exhaust-system damage, smoke or toxic fumes in the crew compartment or cabin, engine shutdowns from flameout, external damage, foreign object ingestion or icing, shutdown of more than one engine, propeller feathering-system problems, fuel-system problems, unwanted landing gear extension or retraction, loss of brake actuating force on the ground, structure requiring major repair, cracks or corrosion beyond acceptable limits, and components or systems that result in emergency actions during flight (except engine shutdown). Paragraph (c) adds a catch-all: any other failure, malfunction, or defect that occurs or is detected at any time must also be reported if, in the certificate holder's opinion, it has endangered or may endanger the safe operation of the aircraft.

What is the SDR filing deadline under §135.415(d)?

Reports are organized around a 24-hour reporting period that begins at 0900 local time each day and ends at 0900 local time the next day. Each report of occurrences during that 24-hour period must be submitted to the collection point — the rule names the FAA offices in Oklahoma City, Oklahoma — within the next 96 hours. The rule builds in two exceptions: a report due on Saturday or Sunday may be submitted on the following Monday, and a report due on a holiday may be submitted on the next workday.

Does §135.415 apply to operators of nine-or-fewer-seat aircraft?

Yes. 14 CFR §135.411 splits Part 135 maintenance into two tracks by type-certificated passenger seating configuration (excluding any pilot seat), but §§135.415 and 135.417 appear on both sides of the line. Section 135.411(a)(1) requires aircraft of nine passenger seats or fewer to be maintained under parts 91 and 43 plus §§135.415, 135.417, 135.421, and 135.422; §135.411(a)(2) requires aircraft of ten passenger seats or more to be maintained under the maintenance program in §§135.415, 135.417, and 135.423 through 135.443. Service difficulty reporting and the mechanical interruption summary are the two Subpart J obligations every Part 135 certificate holder carries regardless of aircraft size or maintenance track.

What is the Mechanical Interruption Summary (MIS) report under §135.417?

The MIS is a monthly summary report. Under 14 CFR §135.417, each certificate holder must mail or deliver, before the end of the 10th day of the following month, a summary of two kinds of occurrences in multiengine aircraft for the preceding month to the responsible Flight Standards office. Paragraph (a) covers each interruption to a flight, unscheduled change of aircraft en route, or unscheduled stop or diversion from a route, caused by known or suspected mechanical difficulties or malfunctions that are not required to be reported under §135.415. Paragraph (b) covers the number of propeller featherings in flight, listed by type of propeller and engine and aircraft on which it was installed — except that propeller featherings for training, demonstration, or flight check purposes need not be reported.

Do single-engine aircraft events go in the monthly MIS?

No. The text of §135.417 requires a summary of the listed occurrences "in multiengine aircraft," so a mechanical diversion in a single-engine aircraft does not belong in the monthly MIS. But two things still apply to single-engine equipment: §135.415 service difficulty reporting covers any aircraft the certificate holder operates — it has no engine-count or seat-count limit — and the underlying irregularity still has to be recorded and corrected or deferred through the §135.65 aircraft maintenance log and the operator's applicable maintenance rules. Single-engine aircraft used in passenger-carrying IFR operations also carry the additional maintenance requirements of §135.421(c), (d), and (e) under §135.411(c).

What if I do not have all the SDR information within 96 hours?

File anyway. Section 135.415(g) states that no person may withhold a report required by the section even though all information required by the section is not available, and §135.415(e) requires only "as much of the following as is available" — aircraft type and identification number, operator name, date, the nature of the failure, the part and system involved, the apparent cause, and other pertinent information. When additional information arrives later — including information from the manufacturer or another agency — §135.415(h) requires the certificate holder to expeditiously submit it as a supplement to the first report, referencing the date and place of submission of the first report.

If an event was already reported to the NTSB, is an SDR still required?

Read §135.415(f) carefully — the relief is narrower than many operators assume. Paragraph (f) excuses a report only for a certificate holder that is ALSO the holder of a type certificate (including a supplemental type certificate), a Parts Manufacturer Approval, or a Technical Standard Order Authorization, or is the licensee of a type certificate — and only if that certificate holder has already reported the failure, malfunction, or defect under §21.3 or §37.17 of 14 CFR or under the accident reporting provisions of 49 CFR part 830. A charter operator that holds no design approval is not within the class paragraph (f) describes, so the section's text gives it no duplicate-report relief. The conservative practice when an event touches both regimes is to satisfy both: make the part 830 notification to the NTSB and file the §135.415 SDR.

What does "during flight" mean for SDR purposes?

Section 135.415(b) defines it for the section: during flight means the period from the moment the aircraft leaves the surface of the earth on takeoff until it touches down on landing. That definition scopes the during-flight items in the paragraph (a) list — fires, fume events, engine shutdowns, unwanted gear movement, and emergency actions. Two parts of the rule reach beyond that window: item (a)(13) expressly covers brake system components that result in loss of brake actuating force when the aircraft is in motion on the ground, and paragraph (c) covers any other failure, malfunction, or defect that occurs or is detected at any time — which is how cracks or corrosion found during a hangar inspection still become reportable.

More Part 135 & Aviation Compliance Guides

What Records Must a Part 135 Operator Keep

The master index: every Part 135 record mapped to its CFR cite, owner, and retention period

Part 135 Maintenance Recordkeeping (CAMP)

The §135.411 split, CASS under §135.431, §135.439 records, and the §135.443 airworthiness release

Prepare for a Part 135 FAA Surveillance Audit

The documents an FAA inspector requests during a SAS surveillance visit, in order

FAA Part 135 SMS 2027 Deadline

The Part 5 Safety Management System rule — applies to all Part 135 by May 28, 2027

Document AD Compliance for a Ramp Check

Logbook wording, recurring-AD next-due math, and §91.417(a)(2)(v) retention

What a §43.9 Maintenance Entry Must Contain

The required elements of every compliant aviation maintenance record entry

Part 91 Aircraft Records Requirements

The §91.417 framework that applies to nine-or-fewer-seat aircraft on the parts 91/43 track

MEL & CDL Records Requirements

Deferral documentation — the paper trail behind every inoperative-equipment dispatch

Engine & Propeller Overhaul Time Tracking

TBO status, time-since-overhaul, and the records that support feathering and shutdown reporting

Part 135 GOM & Maintenance Manual Requirements

What §135.21 and §135.23 require your manual to contain — including reporting procedures

Part 145 Repair Station Recordkeeping

What §145.219 demands of the repair stations that perform your contracted maintenance

Operations Specifications (OpSpecs) Explained

How OpSpecs bind your certificate — and the document control they demand

Prove your reporting records before the FAA asks

FileFlo classifies your SDR copies, monthly MIS summaries, maintenance-log pages, and corrective-action records against 14 CFR §135.415, §135.417, §135.65, and your track's records rule — indexed by aircraft and date, with the gaps made visible. When the inspector pulls your SDR history, your file answers it line for line.

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About this guide

Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. Reviewed June 10, 2026. Regulatory citations verified against the Cornell Legal Information Institute (14 CFR §135.411, §135.415, §135.417, §135.65) as of the publication date. This article is a compliance-document perspective and is educational only — it is not legal advice, and it is not a substitute for your Director of Maintenance, Principal Maintenance Inspector, or aviation counsel on whether any specific event is reportable.

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